Working with Planners
ELLEN GRIST & ANDREW STANSBURY, HOUSING FESTIVAL
In a climate where traditional housing delivery is slowing down due to the volatility of house prices, the adoption of factory manufactured housing solutions is an opportunity to do things differently and deliver affordable housing at pace, at a time when we need it most. Through the Bristol Housing Festival’s living-lab approach and the Innovate UK funded Enabling Housing Innovation for Inclusive Growth programme, Bristol has had the opportunity to support and evaluate the delivery of eight Modern Methods of Construction (MMC) housing developments, which have secured planning permission in the city.
The Local Planning Authority have now granted permission to more than nine MMC housing developments, with more coming forward. The vast majority went to a planning committee for decision, where many were then unanimously approved. Planning is often cited as a barrier to the adoption of MMC housing [1]and in this blog we explore Bristol's first-hand experience of navigating and overcoming the challenges planning poses for MMC.
Why we need planning permission granted for innovative new homes
The planning regimes embodied in the NPPF states that planning should be blind to the method of housing delivery and thus should be adequate for MMC [2]. Bristol’s diverse portfolio of MMC scheme confirms this is true. However, in practice, the unfamiliarity of MMC raises multiple questions and concerns that can create blockers in the planning process. In a local context ‘on the ground’, it’s simply more comfortable to stick with what is known - hence innovation can be stymied. It’s not a policy or black letter law issue, but an implementation issue. Planning uncertainty adds a further element of risk and the recognition that planning teams are under huge pressure (a real and often under-appreciated impact of austerity) adds to the list of reasons to avoid MMC.
Reflecting across the eight MMC developments from the Enabling Housing Innovation for Inclusive Growth Programme, and Vistry’s experience at their Blackberry Hill site, there is common learning, challenges and opportunities for both MMC providers and planning authorities in navigating MMC planning applications. Through the Innovate UK project, we have identified three headline lessons learnt about taking MMC schemes through planning:
Forge a positive, open conversation with the local planning authority, where the limitations and opportunities of the proposed solution can be explored
Early stakeholder engagement and a Pre-App is even more important where the scheme uses MMC.
Planning is an already complex process and the newness of MMC may require applicants to go above and beyond to alleviate planning concerns.
Lesson 1. Forge a positive, open conversation with the local planning authority
Working with a local authority with an active will to innovate and walk the learning journey with MMC has enabled an open dialogue with the local planning team around MMC technology, allowing wider benefits to be understood, as well as for questions and uncertainties to be addressed and worked through within a positive narrative and approach.
For planners unused to MMC, working through a proposal requires a more open approach where collaboration is needed to find solutions to planning regulation issues that are feasible with the constraints of the design. Careful thought needs to be given to the surrounding services for an MMC proposal where it is placed in an unconventional setting, and fresh thinking within the planning authority is essential to moving projects forwards.
One example of this was the Hope Rise development in Bristol. The development consisted of eleven volumetric modular homes on a platform above an operational public car park, was not only a first for MMC supplier ZED PODS, but a highly innovative urban housing concept;
“When you start using a public car park for housing, the very principle there throws up interesting planning conundrums... Where will the bins go, how it will be lit?... All the detailed practical stuff is often much more important to people than the design!” BCC Planning
Planners must be educated, so they understand that the ‘off-the-shelf’ nature of MMC housing products, is fundamental to unlocking value through the manufacturing process;
“I always push to get everything absolutely 100% perfect but it’s just not possible, when you’ve got such a heavily constrained site. You’ve got to make some compromises. There was a lot of positive aspects - policy compliant affordable housing, new areas of open space. The positive aspects outweighed the aspects that were less than perfect.” BCC Planning
Furthermore, familiarity of local planning authorities with the benefits of MMC, as well as an understanding of the off-the-shelf nature of MMC housing products, paves the way for other schemes. When Vistry decided to switch to utilising Ilke’s volumetric MMC homes, in place of the traditional homes planned for the third phase of their Blackberry Road development, they were pleasantly surprised by the positivity and support of the planning officers. With small choices to match the colour of the brickwork and other external details, the switch of build system was granted as a non-material amendment within 28-days. Local residents welcomed the reduced disruption associated with the new MMC build solution.
Lesson 2. The value of early stakeholder engagement & Pre-App
As MMC is still perceived as a relatively new housebuilding technology, early engagement with stakeholders and planners was a key lesson learnt across all the Enabling Housing Innovation for Inclusive Growth Programme projects. As MMC can often be used to build on sites that would otherwise prove to be unviable and utilises innovative techniques and technologies, early stakeholder engagement proved to be essential to help the planners and local community to understand and shape the proposal and demonstrate how the development dovetails with the locality.
“How you integrate a new development into an existing one, is by getting the community positively involved and them being able to see that actually ‘we helped shape this” Turley
For planners, early pre-application engagement allowed for the system being proposed to be examined, understood and appraised ahead of the full planning process. This enabled planners to grow in confidence with the limitations and individualities of the MMC systems and gave the MMC suppliers the chance to answer questions, adapt design and alleviate concerns ahead of entering full planning.
Lesson 3: Where you might need to go over and above
It is widely recognised that planning is a complex and expensive system to navigate. National Government acknowledges that the current system is ‘inefficient, opaque and leads to poor outcomes’[3]. For new developers, including those entering the UK market from overseas, this unfamiliar process presents a challenge, irrespective of the construction technology.
Reflecting on their experience of getting planning permission for their MMC development on Airport Road, BoKlok UK commented;
“We have about 17 more sub-consultants in the UK than you might in any other BoKlok market e.g. ecology...flood...That’s what complicates the planning process in the UK and what makes it more expensive than BoKlok has experienced elsewhere.” BoKlok UK
They found the planning system to be expensive and complex in comparison to other European countries they were familiar developing homes in.
Given that MMC technology is still relatively new, there are fewer planning and built examples available for planners to gain familiarity with the technologies and design intricacies involved in comparison to traditional build developments. With this in mind, we found that the MMC projects that took initiative in having examples, samples and design concepts available for planners to see within their application had greater success in navigating the planning process. At Blackberry Hill, the selection of an established MMC product, used elsewhere in country, gave the planners confidence in the quality of the proposed solution. This project will have brought familiarity and confidence in MMC as a general approach to new build housing, but diversification and expansion of the MMC marketplace will still rely on client-planning teams willing to go further to establish the necessary shared understanding and confidence in new solutions too.
With relatively unproved MMC technologies, we have found that planners require and depend on these supporting works to mitigate concerns around the unproved nature of MMC. Further to this, applicants must be prepared to provide physical examples of their build and finish to give planners increased confidence in the look and feel of their homes.
Conclusion
On the strength of our experience, we suggest that planning as a barrier to MMC is structural as opposed to local.
Forced to close their North-Yorkshire factory, Legal and General Modular Homes have pointed to “long planning delays” (and Covid-19) for the weak demand[4]. Delays in planning resulting in insufficient orders to a factory quickly make the overheads associated with large factories unviable. Arguably, there is a mismarriage between the required order book and the consistent throughput of modular housing factories, and the highly site-specific and circumstantial nature of the current planning process. This will need to be addressed to support the sector if it is to unlock the potential benefits associated with MMC, including higher quality, lower carbon homes.
However, at a local level Bristol has shown that engaging with the MMC suppliers, and building out a range of innovative developments, has been an effective in creating greater confidence within planning teams and the wider delivery ecosystem, which we expect will continue to pave the way for new schemes.
[1] https://www.propertyweek.com/legal/modular-construction-uptake-hindered-by-planning-system/5124415.article?adredir=1 (subscription required)
[2] https://publications.parliament.uk/pa/cm201719/cmselect/cmcomloc/1831/183110.htm
[3] https://www.gov.uk/government/consultations/planning-for-the-future/planning-for-the-future
[4] https://www.bbc.co.uk/news/uk-england-york-north-yorkshire-65488044
