The UK planning system finally recognises the ‘Agent of Change’ principle. So now what?

A woman dances in a nightclub. Image: Getty.

In August 2018, the UK Parliament passed an amendment to the National Planning & Policy Framework (NPPF), including a few sentences collectively referred to as the ‘Agent of Change’ Principle. Now, in England, any new development – residential, commercial or otherwise –planned for a site next to a noise-making premises would need to mitigate any potential risk to the existing premises, before receiving planning permission.

The new rule applies not just for music venues and nightclubs on high streets next to new developments; but also light industrial, factories and ‘back-of-house’ creators, such as art studios, instrument makers and textile manufacturers. It also defends existing residential developments: if a music venue wished to open in a quiet neighbourhood, it would need to demonstrate soundproofing, quiet dispersal and other requirements to get planning permission.

This is a step in the right direction, but it’s not a panacea, because there isn’t one. Local plans need to be rewritten and this rule must be respected in local decisions. There will be missteps – but the introduction of Agent of Change is a start to creating a more sustainable, healthy and supportive music and creative ecosystem in London and across England.

But we need to do more. So, what’s next on the list?

Here’s a few ideas that I feel are worth pursuing, so we can make the UK the world’s best place for musicians, creatives and all of us who benefit from, or interact with, their creative output.

1. Ratify Agent of Change in Wales, Scotland and Northern Ireland

This is a simple request, but one which requires local change in each country. Both Scotland and Wales have brought bills to their parliament to introduce this in their planning systems. It would be beneficial for the entire country, not just England, to make Agent of Change law.

2. Re-engage a debate about licensing

This is not specifically a British problem – mixing alcohol, live music and regulation, primarily at night, causes headaches everywhere. From Pittsburgh to Tbilisi, Tokyo to Bogota, striking a balance in regulating the night time economy is a challenge that divides communities.

But the current system here in the UK certainly doesn’t work. Local engagement in licensing hearings is low, and the people who chair and run these committees are often not the same people experiencing, and benefitting from, the activities they are regulating. The average age of a UK Councillor is over 60 (although this is gradually changing); and reactionary decisions create a mistrust in civic society: look at the London Borough of Hackney, for example.


In addition, since last year’s thorough licensing review by the House of Lords, which outlined the failures in the interpretation of the 2003 Licensing Act, nothing’s been done. A reduction in local authority staff and an increase in workload has compounded this problem: complicated, life-altering decisions are being made by those who lack the experience to do so.

The current failing regime is even putting further unnecessary stress on our health and social care system. Folkestone’s licensing framework, for example, recently introduced changes to limit evening and night time economy uses: Kent Online referred to the changes as a “final nail in the city’s coffin”, because it will further lead to the city attracting pensioners, rather than the young workers needed to support social care. This is not inevitable: further up the coast, Margate, is doing the opposite.

Across England, there have been a number of successful schemes promoting the benefits of the Night Time Economy. London has a Night Czar, Manchester a Night Mayor and Plymouth a Night Time Manager. More cities have joined the Purple Flag accreditation scheme for places that offer a good night out.

But such progress is still not reflected in policy. Licensing decisions are still based on negatives. And when locals can object to a business before its doors even open, that objection will be based on what it represents, rather than what it is.

So: let’s talk more about licensing.

3. Prioritise Our Small Towns and Cities More

I’m proud of being a small cog in the big machine that has worked to improve the music policy ecosystem in London. While we’ve had successes, there’s much work to do there.

But I feel now’s the time to prioritise the music infrastructure in our small towns and cities – and recognise that, to incubate talent, we need to start at all sources. Many small towns and cities, from Peterborough to Wells, Oban to Fishguard, have seen decreases in their music infrastructure since 2010. Only a few local music organisations remain – the rest were victims of austerity – and venues in which to play are closing, with new artists now relying on their parents, or infrequent night buses, to take advantage of performance opportunities.

This creates a talent development framework that relies more on uploading covers to YouTube than on engaging with one’s peers. Mix that with a reduction in music education provision, less budget for music services and the closure of youth clubs, and you get a perfect storm in which, in essence, we forget about the talent in our small towns and cities.

This must change. We need a national music towns strategy to audit existing infrastructure, ensure it is protected through the planning and licensing system as best as possible, and provide the tool for local authorities to better promote venues. We need a mechanism to turn vacant buildings over to creatives, on peppercorn rent, as practice facilities. We need all BIDs and LEPs to develop music policies and treat music as an industry, like any other. All this is possible.

We have much work to do in the UK. Here’s hoping next year, we have more to celebrate to ensure we’re continually creating the most music friendly country on the planet.

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What Citymapper’s business plan tells us about the future of Smart Cities

Some buses. Image: David Howard/Wikimedia Commons.

In late September, transport planning app Citymapper announced that it had accumulated £22m in losses, nearly doubling its total loss since the start of 2019. 

Like Uber and Lyft, Citymapper survives on investment funding rounds, hoping to stay around long enough to secure a monopoly. Since the start of 2019, the firm’s main tool for establishing that monopoly has been the “Citymapper Pass”, an attempt to undercut Transport for London’s Oyster Card. 

The Pass was teased early in the year and then rolled out in the spring, promising unlimited travel in zones 1-2 for £31 a week – cheaper than the TfL rate of £35.10. In effect, that means Citymapper itself is paying the difference for users to ride in zones 1-2. The firm is basically subsidising its customers’ travel on TfL in the hopes of getting people hooked on its app. 

So what's the company’s gameplan? After a painful, two-year long attempt at a joint minibus and taxi service – known variously as Smartbus, SmartRide, and Ride – Citymapper killed off its plans at a bus fleet in July. Instead of brick and mortar, it’s taken a gamble on their mobile mapping service with Pass. It operates as a subscription-based prepaid mobile wallet, which is used in the app (or as a contactless card) and operates as a financial service through MasterCard. Crucially, the service offers fully integrated, unlimited travel, which gives the company vital information about how people are actually moving and travelling in the city.

“What Citymapper is doing is offering a door-to-door view of commuter journeys,” says King’s College London lecturer Jonathan Reades, who researches smart cities and the Oyster card. 

TfL can only glean so much data from your taps in and out, a fact which has been frustrating for smart city researchers studying transit data, as well as companies trying to make use of that data. “Neither Uber nor TfL know what you do once you leave their system. But Citymapper does, because it’s not tied to any one system and – because of geolocation and your search – it knows your real origin and destination.” 

In other words, linking ticketing directly with a mapping service means the company can get data not only about where riders hop on and off the tube, but also how they're planning their route, whether they follow that plan, and what their final destination is. The app is paying to discount users’ fares in order to gain more data.

Door-to-door destinations gives a lot more detailed information about a rider’s profile as well: “Citymapper can see that you’re also looking at high-profile restaurant as destinations, live in an address on a swanky street in Hammersmith, and regularly travel to the City.” Citymapper can gain insights into what kind of people are travelling, where they hang out, and how they cluster in transit systems. 

And on top of finding out data about how users move in a city, Citymapper is also gaining financial data about users through ticketing, which reflects a wider trend of tech companies entering into the financial services market – like Apple’s recent foray into the credit card business with Apple Card. Citymapper is willing to take a massive hit because the data related to how people actually travel, and how they spend their money, can do a lot more for them than help the company run a minibus service: by financialising its mapping service, it’s getting actual ticketing data that Google Maps doesn’t have, while simultaneously helping to build a routing platform that users never really have to leave


The integrated transit app, complete with ticket data, lets Citymapper get a sense of flows and transit corridors. As the Guardian points out, this gives Citymapper a lot of leverage to negotiate with smaller transit providers – scooter services, for example – who want to partner with it down the line. 

“You can start to look at ‘up-sell’ and ‘cross-sell’ opportunities,” explain Reades. “If they see that a particular journey or modal mix is attractive then they are in a position to act on that with their various mobility offerings or to sell that knowledge to others. 

“They might sell locational insights to retailers or network operators,” he goes on. “If you put a scooter bay here then we think that will be well-used since our data indicates X; or if you put a store here then you’ll be capturing more of that desirable scooter demographic.” With the rise of electric rideables, Citymapper can position itself as a platform operator that holds the key to user data – acting a lot like TfL, but for startup scooter companies and car-sharing companies.

The app’s origins tell us a lot about the direction of its monetisation strategy. Originally conceived as “Busmapper”, the app used publicly available transit data as the base for its own datasets, privileging transit data over Google Maps’ focus on walking and driving.  From there it was able to hone in on user data and extract that information to build a more efficient picture of the transit system. By collecting more data, it has better grounds for selling that for urban planning purposes, whether to government or elsewhere.

This kind of data-centred planning is what makes smart cities possible. It’s only become appealing to civic governments, Reades explains, since civic government has become more constrained by funding. “The reason its gaining traction with policy-makers is because the constraints of austerity mean that they’re trying to do more with less. They use data to measure more efficient services.”  

The question now is whether Citymapper’s plan to lure riders away from the Oyster card will be successful in the long term. Consolidated routing and ticketing data is likely only the first step. It may be too early to tell how it will affect public agencies like TfL – but right now Citymapper is establishing itself as a ticketing service - gaining valuable urban data, financialising its app, and running up those losses in the process.

When approached for comment, Citymapper claimed that Pass is not losing money but that it is a “growth startup which is developing its revenue streams”. The company stated that they have never sold data, but “regularly engage with transport authorities around the world to help improve open data and their systems”

Josh Gabert-Doyon tweets as @JoshGD.