LAND JOURNAL

Hybrid planning systems could unlock opportunities

Opinion: Planning regimes around the world struggle to find the right balance between regulation and market forces – but learning from others can drive better outcomes, as some countries show

Author:

  • Jonathan Manns FRICS

06 March 2025

Almere city, Netherlands

Almere city, Netherlands

When it comes to urban planning, there are two broad schools of thought.

The first is to create a system akin to that in the UK: a discretionary approach that allows for quite significant degrees of subjectivity on a site-by-site basis. The second is a zoning system, such as in New Zealand: a prescriptive model that enables almost anything within the rules.

Both have merits and drawbacks. Fans of the UK system celebrate its scope for flexibility, interrogation and compromise. Detractors obsess about the time, cost and lack of certainty. On the other side of the world, Kiwis celebrate speed and certainty, but devolve nearly all control over outcomes such as the mix of uses and detailed design to the market. The first hangs on advocacy and the second on procedure.

Every country operates somewhere on this spectrum and it's not surprising that policymakers worldwide are trying to find an elusive sweet spot. However, there's a reasonable chance that, except where markets and politics fleetingly align, it doesn't actually exist. But it's a search which, if open-minded, has the potential to bring about real improvements.

Policy expands and contracts in response to pressure

Everyone is in the same boat. Between 1990 and 2012, national guidance in England grew to more than 1,000 pages and has since reduced to an 82-page National Planning Policy Framework but with reams of supporting practice guidance and case law elsewhere.

Meanwhile, New Zealand's Resource Management Act 1991 grew from 382 pages in the year it was published to 796 by 2017, and was then cut back over five years only to be identified for reform in 2024 after just 123 days in place.

Wherever you go, policymakers seek to regulate for the outcomes they want. Cultural and institutional forces swing the pendulum in one direction and then back the other. However, small tweaks and individual improvements can still accumulate into a bureaucratic burden. So why not think bigger?

Development management systems are politically driven and entirely adaptable. When it comes to the standards that are set, processes followed or evidence required, they can be as onerous or hands-off as needed. Iteration is neither impossible nor forbidden. The focus should simply be on making more strategic and effective changes.

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Bespoke regimes blend zoning and discretion

It's all about whether to be hands-on or hands-off. In the UK, HTA Design has long proposed the concept of 'Superbia', where permitted development rights would enable homeowners to redevelop properties in England's suburbs without the need for an application.

New Zealand introduced Medium Density Residential Standards (MDRS) in 2022, which enabled broadly the same: the redevelopment of single-family houses into a maximum of three homes of three storeys without resource consent, the equivalent of planning permission. The idea is sound, but local authorities have already recognised the loss of control over where and when that change happens.

This balance of intervention is where systems can be tailored. Some countries allow targeted deregulation, blending zoning and discretionary systems by spatially defining where each approach applies. It has played an important role, for instance, in Singapore's transformation over the past 60 years, from an underdeveloped country to global trade-hub and self-professed garden city; balancing the need to preserve heritage while providing growth and intensification.

It's also broadly how the German system works, as new development is zoned while historic areas manage change on a discretionary basis. The result, in both instances, is to enable growth at pace but make allowances for greater nuance where needed.

The challenge then is to ensure that design quality is not sacrificed on the altar of speed and cost. Here too there are examples of effective solutions around the world, most notably the use of design codes for zoned sites. 

These have proven effective in Italy, France and perhaps most notably the Netherlands, where 95 urban extensions increased the national housing stock by 7.6% in only a decade, allowing an extra layer of influence over layout, mix of uses and architectural style.

Open-minded approach can enable change

When looking for improvements, there is a tendency to tweak, refine and fiddle. This is not the way to achieve significant change. Big shifts in output or outcome require big ideas that do not lose sight of the detail. That's where we can learn from the balance that others have struck.

It need not be daunting. What seems bold or radical from one position will be completely normal from another. The chances are that somebody else has already considered and tested the same thing, enabling confident and evidence-based policy decisions. There is no need to believe that planning is stuck the way it is, if we want options, we only need to look around.

Jonathan Manns FRICS is chief executive at affordable housing provider Te Toi Mahana, New Zealand

Contact Jonathan: Email | LinkedIn

Related competencies include: Commercial real estate, Corporate real estate, Housing strategy and provision, Masterplanning and urban design, Planning and development management