Municipalities cannot continue with their software for publishing and amending environmental plans on the Digital System of the Environment Act (DSO). It is still unclear when the release with new functionalities, which has been delayed for months, will be ready. The stability and availability of the DSO are also still at stake.
In the progress letter that was sent to the House of Representatives at the end of last week, Minister Keijzer (Public Housing and Spatial Planning) paints the usual rosy picture. Anyone who continues reading will learn that municipalities have so far published only 29 draft environmental plans with the new DSO software in the whole of 2024. That is an exceptionally low number and a sign of the ICT problems that municipalities encounter.
Complex standard
The technically difficult to implement planning software under the Environmental Act has been a concern for some time. Municipalities are struggling with the complex STOP standard, which links the local systems of municipalities with the national provision of the Digital System for the Environment Act (DSO). A frequently heard problem is that plans remain stuck in the system.
Under the old regime of the Spatial Planning Act (Wro), municipalities usually put hundreds of draft zoning plans online every month.
Release B
Municipalities and software suppliers are also eagerly awaiting the arrival of ‘Release B’ of the STOP standard, which supports complex changes to planning documents and the parallel publication of plans. It is currently not possible to prepare and publish multiple plan changes at the same time. Much to the annoyance of municipalities that want to make progress with new functionalities for their DSO software.
Delayed
Gemeente.nu reported a month ago that Release B has been delayed. In her letter, Minister Keijzer acknowledges that the DSO organization should have delivered the standard in June.
The minister does not provide a specific delivery date for the DSO standard in her progress letter. She briefly mentions that its arrival is ‘expected’ for this autumn. Municipalities and other authorities still do not know where they stand.
They also still have to implement the new DSO standard. ICT specialists expect that municipalities will have a tough time adapting their own systems to the new software. As release B comes out later, the conversion operation will only get bigger.
TAM-route
The result is that municipalities are trying to avoid ICT under the Environmental Act en masse by falling back as much as possible on the Temporary Alternative Measures (TAM) that were introduced earlier. This way they can publish plans with the old IMRO standard. 2 in 3 municipalities do this. Keijzer wants to extend the TAM option until the end of 2025. She still has to arrange this legally, she writes in the progress letter. The procedure at the Council of State is still ongoing.
No answer
Municipalities recently made a plea to extend the TAM term until 2032, the year in which they must have one environmental plan for their entire territory. The Environmental Act software with the STOP standard creates too much uncertainty to successfully complete this enormous operation, municipalities say. Minister Keijzer does not want to respond to this.
Unstable DSO
Keijzer optimistically concludes in her progress letter that the number of DSO disruptions in the third quarter fell significantly to 217 incidents (compared to 413 in the first quarter and 295 in the second quarter). Converted to an average of 2.5 disruptions per day over the past 3 months. The question is whether this represents a stable DSO. Instability does not bode well if municipalities soon have to publish more plans on the DSO, with once again a high risk of errors due to all the technical adjustments for the new release.
The minister is also satisfied that the national DSO facility is available 98 percent of the time. In the ICT sector, this is a fairly poor result, especially with such an important ICT infrastructure as the DSO, where ‘downtime’ directly affects the services provided to residents and the business operations of municipalities. In that case, a requirement of 99.9 percent is very common in business.
Ketentest
On LinkedIn, Member of Parliament Saskia Kluit, a critical follower of the digitization of the Environmental Act, also concludes that the planning chain via the STOP standard still does not function sufficiently. She refers to the latest report on the chain tests with the planning software. In such a test, various competent authorities put the DSO through its paces in simulated work processes. The OW viewer to view plans on the DSO also causes problems, according to Kluit.
The reactions to Kluit’s post are telling. For example, an environmental lawyer from the province of North Brabant notes that even simple things such as correctly displaying the applicable zoning plan in the viewer regularly go wrong. And that the correct rules do not always appear on the map. The cause, he inquired with the DSO organization, lies in the technical design of the DSO.
Back to square one
The latter would mean that the DSO would have to be given a fundamentally different structure in order to solve these technical glitches. The government would then be more or less back to square one. According to an earlier study by KPMG, the transition costs to the Environmental Act for all municipalities together amount to between 1.1 and 1.7 billion euros. Of these, 45 percent have already been spent in 2020 and 2021.
Test environment
When building the software for the Wro, the ministry explicitly called on software suppliers. Their involvement made ICT under the Wro with its relatively simple IMRO standard a success.
There is now plenty of criticism in the field that the ministry has seriously neglected the possible contribution from the software market to the DSO. For years, software suppliers lacked their own test environment to check in advance whether their software indeed meets the requirements to connect to the national DSO.
The Supplier Test Environment (LTO) previously announced by the minister would be ready in September, but is still not operational, Keijzer writes in her progress letter. The test environment is crucial if the new STOP standard becomes available.
