Tackling the Inertia of Area Action Plans - dDAM

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dDAM; tackling the inertia of Area Action Plans Harry Postins Radical Practice March 2020


dDAM; tackling the inertia of Area Action Plans

It is not a stretch of the imagination to suggest the model of 'Area Action Planning' that London boroughs currently employ, is grossly out of date. Having worked in detail within a couple of these AAPs, the author can confidently suggest the information they provide is both difficult to decipher, and in most cases, archaic. Even with the amendments that are released at sporadic intervals, the consultation process takes so long, that by the time anything is published, opinions have changed. This essay proffers the notion that in the future, the AAPs will be contained within, and governed by a central 3D model, one which contains various real-time feedback loops, designed to be increasingly accurate when consulted. The model will encompass all levels of planning policy relevant to a certain area, from AAPs right up to the London Plan and onwards. It will also contain a standardised vocabulary, one which can be used seamlessly across all regions. The focus of this paper however, is to interrogate the mode of feedback, suggesting that we must incorporate both quantitative ​and​ qualitative, but also a method of opt-in, tacit, feedback.

fig.01. Company make up of the governing body in charge of dDAM Area Action Plans are a specific part of the planning framework, designed to provide greater clarity to an area of importance within a district. It is the highest resolution possible for an area, before getting into specifics regarding local and national listings. AAPs work in tandem with conservation area documents, and the borough's local plan. These in turn, also all work within the London Plan, and therefore the national planning policy framework. This proves an issue in practice, as throughout a building's design, there is a horde of documentation that must be deciphered both before, and during, the process. This essay will focus on the Hackney Central Area Action Plan, as the author considers themselves familiar with vast areas of the borough, having lived there for years, and has spent a considerable amount of time negotiating the planning process in work. The current Hackney Central AAP was adopted on 24-10-2012, after many years of consultation. According to the document; 'the overall purpose of the AAP is to establish the basis for shaping the regeneration of the area and to ensure the continued role of Hackney Central as a District Town Centre. Proposals are framed to respond to the needs of existing and future communities and plan for housing growth to 2026.' It allocates areas within Hackney Central which are prime for development, as well as areas in need of future investment in order to maintain the character of the area. However, the plan was adopted over seven years ago, and surprisingly perhaps, there is no new AAP in the pipeline. Hackney Council have decided instead to develop their Local Plan 2033, which will replace the Hackney Central AAP. Consultation for LP33 began in late 2016, and adoption was scheduled for 2019, though it is yet to be finalised. In addition to Hackney Central AAP, LP33 will replace Dalston AAP [2013], Manor House AAP [2013], Hackney's Core Strategy [2010], Development Management Local Plan and the Site Allocations Local Plan [2016]. Despite this move to try and consolidate the development plan documents, the sheer number of different scales within Greater London mean there will always be addendums and supplementary documents, whether that is an architect-designed masterplan, or the Mayor's office City Fringe Opportunity report [​Proposed Submission Local Plan 2033​, 2018, p. 6].


fig. 02. Diagram of the various DPDs that govern a plot in Hackney Central In London, the consultation-and-response process is extremely transparent and relatively rigorous. It does require one to find and download each separate DPD, but the process is clearly spelled out for the suitably intrigued. They also have a detailed account of the representations received during the consultation stages. Taking the Hackney Central AAP for example; it is possible to find online the thirteen representations received by the council. What proves interesting, is that the vast majority of these responses are made up by large conglomerate stakeholders; Thames Water, English Heritage, Highways Agency to name a few. There is only one response from a residents' association, a meagre percentage, and it provides very little opinion from them [​Hackney Central AAP Evidence Base, ​2019]. The council apparently only reaches out to the larger companies, as they don't have the resource to host an engagement programme with the Hackney public. If this wasn't problematic enough, each of the representations received are through different media. Some are paper-based responses, some are emails, some are online forms. The whole operation is a mixed-media mashup, and is in dire need of consolidation.

fig. 03. Snapshot of the Hackney interactive planning map [MapHackney 4.0, ​2020]


So, in practice, it is clear that this is not an efficient mode of operation, and we can start to differentiate between the inefficiencies. The first, is within the council. The tardiness of implementation and consultation is born out of an archaic paper-based system. With a simple technological update for this, the process could start to seamlessly integrate with the societal pressures of the moment.The second, is in the discipline of design. Often it falls at the feet of the architect to navigate the multi-stacked DPDs, and propose a harmonious solution. In larger, commercial, architectural practices, it is often left down to the least experienced architectural assistants to trawl through the documents, armed with little other than a brief description of what they are looking for and a loose description of what is deemed 'useful'. Even if an individual extracts any information of value from all the documents, this then has to be transmitted to the team, and translated from a qualitative statement, into meaningful design practice; a process which inherently lacks rigour.​ ​Without a central database comprising of a user-friendly interface and all the information, this process cannot undergo a much-needed revitalisation. After navigating this warrenous structure, the building can finally be built, completed and occupied. However, this is where the crux of the paper lies. The percentage of buildings that are effectively surveyed post-occupancy is minimal, and the percentage of those surveys which then have an impact on future practice, is negligible. There is already the preconception of architects as self-aggrandising artists who care only about creating the perfect piece of art. How can the profession be seen to be adapting and growing with the population, if there is no concrete evidence to suggest we care about how well our developments function? A small percentage of developments carry out post-occupancy surveys to score an easy, measly BREEAM point, but they have very little impact. It is imperative that the construction industry re-imagines its role within the built environment, and that should start with an appreciation of its obligation to society as a whole.

fig.04. Suggestion of how the dDAM integrates with the existing RIBA stages So where does dDAM fit into this structure? An intricate, centralised, fully-loaded 3D model of the entire borough, incorporating all facets of the multitude of development planning documents, building regulations, and the national planning framework. Now, a system like this is already in the pipeline, and the public have access to a similar 2D map version. But where this model differs, is the employment of machine learning algorithms to increase the speed and efficiency of community feedback loops. Employing a process similar to that of 'Turnaround', a bus transport critique in New York City, the model proposes an opt-in mode of tacit feedback. Turnaround was established in 2016 by the 'Bus Turnaround Coalition' amid the rising levels of dissatisfaction with the state of the MTA bus service. As a group of exasperated citizens, Turnaround harnessed the opinions of the masses in order to appraise the efficiency of all the routes and award them a scorecard. This rating of each route can then be harnessed as evidence/ammunition when building a case against the transport authority. The routes can score between A and F, much like school grades, and the grading system is open for scrutiny on their website. The Bus Turnaround Coalition release an annual report, designed to have real and meaningful impact on the relevant services. This continued publicity has led to standing protests, a swathe of satirical awards, and increased pressure on the bus route policies from the competing political parties. The revolutionary part of the campaign though, is the method of taking part. The instruction for taking part is: 1.

When your bus is late or moving too slowly, ​tweet ​at ​@NYCMayor​ and ​@NYCTBus​ and use the hashtag # ​ busturnaround

This is real-time feedback that can be collected and collated, to create up-to-date statistics [​Bus Turnaround, 2 ​ 019]. It is also an opt-in mode, that provides anonymous data that can be weaponised easily and quickly. You can start to see how this might translate into the dDAM. When the new tenants move into their apartment, they are provided instructions on how to create a twitter post with gravitas, through specific hashtags or handles. This can be anything regarding building quality, maintenance issues, council responsibilities. This system will quickly bypass a traditional post-occupancy survey, both in accuracy and reach. The A.I. will learn what areas need more attention, which buildings


are functioning correctly, and will be able to continue refining the model to greater levels of detail, providing not only a granular synopsis of neighbourhoods, but also an insight into the effectiveness of recent developments. Developers can then be held to account, regarding the quality of their interventions. This marks the first type of integrated feedback that the model hopes to incorporate.

Tenant permissions granted to access and analyse tweets which are hashtagged with certain triggers. Tweets are taken anonymously but geolocated for accuracy.

This information is then fed back into the dDAM, and an algorithm can continue to refine the model of areas that react well to development, and those which are proving more stoic. It may also prove a valuable tool when assessing whether new developments are suitably sensitive to existing demographics in the area. This however, would involve a more indepth process of volunteering data. If when a new tenant moves into an area, they may have to provide, with consent for use by dDAM, their socio-economic background and where they have moved from. This data would clearly only be used by the model, and the ethics team would ensure that it remains private.

fig. 05. Example of the hashtagging system in use on Twitter

A second use of the social medias, might be geo-located photos. Again, having handed over permissions directly to dDAM, users would post photos with a geo-location embedded. This functionality is already built into the Instagram and Twitter interface [even if it's kept private]. It would be a case of then compiling these photos, perhaps through photogrammetric software, to show a detailed view of the borough. Whilst it might take years for the algorithms to


decipher the state of disrepair a photo is displaying, the sheer density of snaps in an area is likely to suggest the popularity of that area, therefore the inverse would indicate areas of poverty or underprivilege. Photographers Nate Larson and Marni Shindelman created a project in 2016, using a series of publically available, geolocated tweets. They travelled to the location of the tweet and photographed what they found there. When paired with its associated caption, the photos become powerful, surreal landscapes, that paint a bleak picture of the individuals' twitter streams [​Tracking down the spots where Twitter users post tweets, ​2016]. Whilst this is not necessarily a function that may be directly translated for planning use, the effect remains the same. Permissions are given directly and discreetly to dDAM to harness the geolocation of various photos, in order that a photogrammetric software can build the 3D version of the borough, showing the most accurate areas as most privileged, and vice versa. These methods provide a basis for the structure of a revolutionised post-occupancy feedback procedure. Whilst in this context, it functions as part of the wider dDAM model, the process of submitting and analysing data on social media is an easy way to engage with the younger demographics, and update the post-occupancy surveys. This system could easily be implemented very soon, as shown with the MTA Turnaround scheme. Even without waiting for new builds to be completed and occupied, the opt-in hashtagging system would work for existing public realm, new council developments, communal playgrounds etc. To manage the system, a private institution would have to be set up, but founded as an ethics-first big data company. They could then trade with the council to help identify areas of exclusion or poverty, and areas that have adapted well to development. As previously mentioned, this could involve posts that display a disgruntled message to the council regarding refuse disposal, or a lack of maintenance in a public square, or something as small as a vandalised bin in a newly built park. But, it can also be positive feedback; something simple like a public square bathed in sunlight that people are engaging with and lingering in the space. All these are relatively simple issues, and people are already readily posting them to their various data streams. All that dDAM is proposing, is to harness them for the power of ethically sound, completely transparent progress. Part of the dDAM company model, comprises the Director of Ethics and the Community Outreach Officer. The outreach is a simple campaign to get people to knowingly engage with the hashtagging for the council's sake. It happens regularly in contemporary discourse, often with a distinct flavour of satire. Whether that is people directly tweeting Mcvities about a sub-par packet of digestives, or tweeting The Met about an incident in Central London. If the President of the United States can run the most powerful nation in the world from his Twitter account, what is there stopping Twitter becoming a steadfast platform for gathering useful and effective post-occupancy data.


Appendix Conversation with Jack Ricketts, phone call 11am, 10 March Jack's role, in his words: I’ve been a planner for about 15 years, the last 12 at LB Southwark. Worked in transport, enforcement, S106/cil, policy, but for the last 24 months I’ve been leading service transformation projects. This has been with an emphasis on leveraging innovations in digital an data usage, but in reality it has been more about encouraging cultural change and shifting working practices and mind set. I suppose my role has been as a product owner, according to the DDaT framework. It seems that the role of a PO is to put together a really great team, answer any of their questions and deal with stakeholders, but then essentially just get out of their way. The projects / ‘products’ I’ve run are here, here and here. The back office work (BoPS) has been funded by MHCLG’s Local Digital Fund, and I’ve been working closely with both the Local Collaboration Unit and the Digital Land team. I’ve also been involved from the early days with VU.CITY. DM, master planning and consultation / engagement. Page 28 of this. (please don’t judge me. It was my first ever attempt at writing something an they printed a draft unedited version) Consultation is now starting to be done with Commonplace. How is data currently used in the development of local plans/area action plans? ❏ ❏ ❏ ❏ ❏ ❏ ❏

in brief, it isn't! LB Southwark submitted new southwark plan, took 6 years to pull together. A lot of evidence used for that has been sourced from consultants, or various spreadsheets around the council or historic legacy There is no live data stream Arup did work for Catapult, 2.5 million for development of local plans, it is not published but he can send over A plan that takes years to write, could make decisions based on old evidence Digital land team look at how to make better use of data. ideally the system would be live rather than static

What issues surround the use of data in medium scale planning? Do changes in policy need to be considered? If so, what, why and how? ❏ ❏

GDPR springs to mind - for example, in consultation this is an issue. Can’t publish names and addresses of feedback If planning system is digitised, we don’t need to worry about redacting. People have rights to the consultation responses. e.g google drive - addresses etc not seen then there is no problem

How might we use new and diverse data sources in the planning process? What might these data sourc​es include? ❏ ❏ ❏ ❏ ❏ ❏ ❏ ❏

Passed to authorities as package of data rather than paper. Information exchange also much more accurate this way. Collecting it at an increased rate means analysing it more effectively. Even predicting future development - an app to predict how many built. etc as not all planning applications built Even enquires in pre-app predicting how many are actually built. etc All data open source so can tie in with land registry, or right move etc Unique property reference number (existing) - comes from central government. every time a house is built and needs an address - it will be assigned one of these. People starting to look at that as unique identifier. to create a log book for property- a golden thread , everything can relate to this. At the moment all this information is in different places.


Do you often collaborate with experts and practitioners from other disciplines in the process? If not, do you think it would be beneficial? ❏ ❏ ❏ ❏ ❏ ❏ ❏ ❏ ❏ ❏ ❏

I never collaborate with data-experts e.g. sit next to building control in meetings but no collaboration. Currently no cross collaboration across teams But it's beginning to change. Anything they can’t do, they outsource to developers and consultants. e.g. arup, atkins. Currently he puts things on digital marketplace - procurement framework where you can advertise opportunity to help with air quality assessment etc. Outcomes from that work won’t be in pdf document - more open source. More funding required but MANY MORE BENEFITS than not doing it at all. Sitting next to digital land team - local digital collaboration, They help councils collaborate/ contact with other councils etc. He thinks collaboration very essential for the process. What is difficult now, is getting authorities to accept or change in mindset and change in culture (in anything not only digital/data).

Do you think that you and your colleagues would benefit from regular sessions that improve/update skills in digital technology to align with real-time developments? ❏ ❏ ❏ ❏

Yes , would benefit. Don’t have anything like that, things are slowly changing being upskilled would be super beneficial local digital collaboration unit been set up to help with that.

At what point in the development of Area Action Plans is public engagement and consultation carried out? ❏ ❏ ❏ ❏ ❏ ❏ ❏

Consultation happens all the way through, a number times and scales throughout the development. Even smaller documents, SPDs. Consultation crying out for change and transformation. Currently updates are posted up in halls, mail outs, contact database -council wide (where people can sign up to be informed for planning decisions etc. ) Although this is self selecting - always the same people and mentioning same thing. not enough diversity in responses. Same demographic - pointless. How can we get a bigger range of consultation responses, and how to engage with harder to reach people. ‘Commonplace’ - a tool - council recently signed a contact with them

How are local communities currently informed about consultations events, or other modes of engagement? ❏ ❏ ❏ ❏ ❏ ❏ ❏ ❏

The council wide mailing list, traditional posters, leaflets through doors. very expensive even though they hold consultation events - public have said they prefer leaflets. Not what we should be doing in 2020 Everyone has a mobile, somehow geo-sense an application site? or an area that has an aap being written - alert to phone? ‘Vu.city’ - 3d modelling platform, modelled london, dubai, woking etc, - can access via mobile, tablet/ laptop they are working with ‘Commonplace’, looking at developing augmented reality. Can hold phone up to see proposed project etc what a space can look like in a few years time.

Do you believe a data-based system could allow for more efficient engagement and feedback from the public? ❏ ❏ ❏ ❏ ❏ ❏

Similar to PlanX. Dynamic form. people are asked a question based on previous answers. They are not asked not non relevant or things authority don’t know the answer to Consultation could be similar to this. People can only answer or make relevant responses. Guiding people away.. Being able to capture those responses.. able to collect without manual redacting etc and just give access - would be perfect. e.g. Several thousands response for local plan southwark, planning inspector wanted redacted and printed 3 times, waste of resource and money even when 99% of those emailed in.


❏ ❏ ❏ ❏ ❏

need to visualise the data- collecting as standardised data is ideal. so can pull together all information across london / uk and can be accurate and more current vision of what’s happening. even plans and drawings- visualise in 3d? can improve consultation. can see and visualise exactly what is being proposed. shown cgi by developer - can’t interrogate yourself. issue of public just in local authorities. using 3d platform that allows people to interrogate themselves. ‘more trust in planning system’. - article see google.

Who do you believe should have access and be responsible for the access to data-based information? Would a board of ethics or a system of management be a viable component to the organisation of data collection and use? ❏ ❏ ❏ ❏ ❏

going back to GDPR. Who owns that data. is it us or people who have submitted that information What if sourcing from third party? What happens then? difficult question, but currently being questioned in the system. board of ethics- where does it sit? See Richard Pope - wrote papers - english, profeessor. Ethics at Harvard.


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