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How one LPA shaved two weeks off application determinations

by on October 18, 2012

Back in April I told you about Bristol City council and its newly launched Agent Accreditation Scheme.

Six months on and the scheme is going from strength to strength. Our head of LPA engagement Scott Alford recently attended their first meeting between the agents and the local authority.

As part of the scheme, participating agents have to attend one of two annual meetings with the council’s planning team to let them know how the scheme is working.

The general view from the agents was that this is a positive scheme as evidenced by quicker decisions on household applications, including one decision received after just four weeks.

Bristol agreed to share the key statistics from the first six months:

  • 58 Agent Accreditation applications received in the first six months
  • 69% decided within 6 weeks (compared to 9% of all Householder applications)
  • 76% of applications on the case officer desk within 24 hours
  • 58% submitted via the Portal
  • 54% of fees paid by cheque
  • 33% of fees paid by Bristol’s Paying Online process
  • 1.3 days the average time to reach case officer’s desk

Missing the 24 hour target was largely a result of payments by cheque slowing up the process and the application not initially being identified as an accreditation application.

To help with this, Agents asked to ensure they used an ‘Accredited Agents Checklist’ (Part of the scheme’s commitments), and to look at other ways (other than a cheque) to pay the planning fees.

Bristol City Council can support payment via their own website to let the applicant pay immediately and is also reviewing the introduction of telephone payments. (Both options will be available via the Portal if approved.)

The conclusion of the meeting was that the scheme has been positive and that it should carry on until a review in April 2013.

I know there are many Agent Accreditation Schemes operating all over the country. I’d be happy to maintain a list of these schemes on the blog or on the Portal as long as you let me know where they’re running.

If you want to let me know about a scheme please let me know by adding a comment below.

46 Comments
  1. Hi,
    I’m accredited to the scheme with Sefton MBC and have been for 2-3 years. It a great scheme which recognises the hard work some agents put in. Please give Sefton a mention, they are a pro-active and approachable local authority.

  2. I can confirm that this scheme works really well for my company, it’s possible to get householder extension schemes though in under six weeks from submitting applications on the Portal which is really flying. I find the BCC planning officers really positive and good to work with, I just wish that other authorities in this area could adopt the same approach.

  3. Recently, our Head of LPA Engagement Scott Alford got a call from an LPA with a few questions about this scheme. He put these to Bristol’s Bryan Cadman (Team Manager Service Development) to answer.

    Q. How many applications had been received from accredited agents that had failed to meet the schemes criteria and therefore invalid?

    A. None – but we did get one with an incorrect ownership certificate and decided to be generous and get it amended within 24 hours and let it count. I don’t think we will allow other ones to slip through from now on. Also, we did have two applications from different agents who were trying to get accreditation which we made invalid meaning they had to go back to the beginning in pursuit of meeting the 3 right first time criteria.

    Q. Does Bristol have a householder team of planning officers that determine them or shared them across all planning officers. The LPA (which doesn’t have a householder team) wanted to know how Bristol achieved 69% determined in 6 weeks, and whether the remainder were all determined by 8 weeks?

    A. We don’t have a HH team, but we allocate all Agent Accreditation applications to a limited number of junior planning officers. (These were the BCC people who attended the meeting on 8 October). We achieve the 6 week target partly as we currently limit the AA scheme to HH applications and so are starting with the premise that all such applications should be relatively straightforward and have limited officer contact time, partly as we are saving around a week in the ‘getting to the case officer’s desk’ time, and partly by prioritising them. We have not got the stat for what happens to the other 31%, but will now add this into our statistics for the next quarter.

    Bryan tells us that he’s had similar questions from other LPAs. If you have a question about Bristol’s agent accreditation scheme, please post it here and we’ll make sure it gets to Bryan.

  4. Michael Hayes permalink

    There are multiple problems with Agent Accreditation.

    – Potential clients will be misled into choosing Agents with accreditation in the false belief that they are being officially endorsed/promoted by the LPA.

    – It is a barrier to entry into the market for new Agents and thus anti-competitive.

    – It is impractical for Agents who deal with many different LPAs to be accredited with all of them.

    – It ties up our already over-bureaucratic planning system in yet more red tape.

    – It is a tacit admission that the standard service provided by LPAs is not good enough.

    • Michael,
      Whilst I’m very happy to publish your views I have to say I don’t share them.

      I can’t see how there is any barrier to entry, where the scheme is as open to any Agent.

      Also rather than adding red tape, once accredited the evidence shows that it is avoided to the point where considerably faster outcomes are delivered for clients. Faster planning for those accredited also benefits everyone else in that it frees up resource.

      Rather than proving that an LPA’s services are sub-standard, I think the scheme demonstrates that where LPA and Agents are willing to engage in meaningful discussion and agreed processes then added benefits can be found for all.

      • Michael Hayes permalink

        There is a barrier to entry because Agents have to make 3 applications before they can join the scheme.

        There is additional red tape because applying for accreditation and subsequently complying with the rules is a bureaucratic process.

        LPAs services are sub-standard because seasoned professional Agents with many years experience are regularly being tripped up by the obstacle course that validation has become. The problem is the failure on the part of LPAs to formulate straightforward and minimalistic validation procedures.

        My other two points, which you didn’t counter, were firstly that LPAs adopting an Accreditation scheme will be perceived to be commercially promoting Agents within the scheme, and secondly that it is impractical for Agents who deal with different LPAs to join multiple Accreditation schemes.

      • I think we’re just going to have to agree to disagree on this one, as I fail to see who suffers here.
        What I have done is post this thread to relevant LinkedIn groups to try and widen the conversation and draw in other opinions.

  5. Keith Baker permalink

    I am obliged to expand on my previous comment. This scheme and others like it need to be “nipped in the bud” The T&C Planning Act and associated SIs etcetc must be applied without favour or fear by all authorities on a consistent equitable impartial and fair basis to all applications. It cannot be fair impartial or equitable to skip normal “statutory” validation and or prioritise applications on the basis of the agent applying.

    • Keith Baker permalink

      Update. I have lodged a formal complaint against the Legality of AAS with BCC.

  6. Jeff Rhodes permalink

    Some interesting comments. I head up the planning function for a UK-wide environmental services business and am responsible for planning applications across the UK. I can therefore identify with points 2 and 3 raised above by Michael Hayes and can also identify with the sentiment of point 5. As such accreditation schemes are currently (I believe) confined to householder projects they are not relevant to our projects, but were it to become a model across the board we could not possibly register with every Council and certainly not if 3 previous applications are a pre-requisite for entry. The fear would then be we would always be at the back of the queue, receiving a second rate service. Whilst I applaud the effort and thinking behind such creative schemes, and they may well serve a useful, specific purpose, in specific circumstances, it is hard to see how they can be widely applied without resulting in unfairness and a two speed system. With current moves in the Growth & Infrastructure Bill to simply information requirements and, hopefully, re-introduce common sense into the validation “game”, the test of success of those reforms should be that accreditation schemes are not necessary anyway.

  7. Chris,

    I have to agree with the thrust of Michael Hayes, Keith Baker and Jeff Rhodes’ comments. In your response to Michael you ask “who suffers here”. The answer is anyone who cannot register in all the authorities where they might make an application, such as Jeff’s company or me or a large number of people! We will get a second class service, whilst those few agents who are accredited get a premium service not to mention an unfair commercial advantage. From a commercial view point, it would be foolish to appoint an unaccredited agent, who will get a second class service, so that the accreditation scheme is intrinsically anti-competative and shows an improper partiality in a public service.

    I’m all for speeding up validation as a way of getting quicker decision making but this just doesn’t seem right.

    • I do understand the genuine fear of a two tier system and actively fight myself to ensure a level playing field in all we do at the Portal. However in my simple view if this system means that simple applications take less of an officers time, doesn’t that mean that there’s more left to speed up all applications?

      Would your views be different if a scheme was operated regionally or even nationally?

      • The accredited application doesn’t take less of an officer’s time; they would still have to consider the application, not to mention decide if there was actually sufficient information for it to be determined, Surely a valid application ought to contain sufficient information to determine it, yet I would guess that with most valid applications I have made in the least few years I’ve subsequently been asked for further information by the officer dealing with it. The time saved is in the often farcical to and fro involved in either persuading an admin officer that a “standard” local requirement is either not relevant in a particular case or else .
        providing uneccessary information simply to pass the validation test.

        I think you might be claiming benefits for accreditation schemes that don’t exist while perhaps overlooking harms that clearly do.

      • Adam,
        just to be clear, the figures quoted are those provided by the Local Authority and not the Portal.
        Any Accreditation scheme (and there are many) are operated by Local Authorities and their agents.

      • Chris,

        None of the figure in the article support the benefit you have claimed, that less officer time was spent on applications from accredited agents. The time saved it seems was in getting an application from the validation clerk’s desk (albeit electronic) to an officer’s desk. Once there it would seem it still took as long to get a decision, so no officer time was freed up as you suggest.

        I, along with others who have posted here, think the accrediation scheme does more harm than good in promoting good and efficient planning for the reasons stated and, with respect, you seem unprepared to seek constructive solutions to the flaws identified in these schemes herein.

      • Hi Adam,
        I can assure you that I do take all the feedback given here seriously.

        On your first point I’m happy to be contradicted and your view may be correct, but as I’ve said previously these schemes are not run by the Portal, but by LPAs up and down the land working locally with their agents.

        On the matter of our Smarter Planning initiative, as a direct result of the feedback received here I have directed our team to review the literature and terms of the scheme. I am absolutely committed to the Portal continuing to support all our customers as has always been the case. I hope to be able to set out anyrevisions in the next day or so.

  8. Ben Hunt permalink

    I agree to a large extent with the last two respondents. I can see some potential benefits, but I think it is naive to think that there will not be downsides – and as in all aspects of the planning system, the two sides need to be weighed and balanced against each other, and the problems at least avoided, and removed where possible. It seems to me that a statement that BCC and the participating agents decided the scheme is positive and should carry on is an endorsement from only one set of people.

    The term “accreditation” implies some sort of quality standard for the application submitted. In reality, it is nothing of the sort. Yes, it could be argued that it demonstrates that “accredited” agents consistently submit applications that, without further amendment, fulfill the legal requirements as to forms, certification, minimum plans etc – and that this is a good thing. For householder applications getting the application validated and in the system may often (but not always) be a major element of a successful outcome.

    What “accreditation” does not do is establish that the quality of the submission is high – for instance the Design and Access Statements subitted by an “accredited agent” may be regularly rubbish. Unfortunately, it may well appear to the public that an “accredited agent” is a good agent, whilst a non-accredited agent is not a good agent. This has the potential to be misleading, as I would suggest that prompt positive outcomes result more often from a high quality scheme and submission than from some sort of guarantee that there will not be a few days delay while something in the application is corrected. Good agents try to deliver applications that are “right first time” (and I have problems with that term as well), in all respects, not just satisfying validation requirements.

    So whilst it might be possible to have an accreditation system that would – on balance – be appropriate for some types of application, I think that this should be approached with caution, and with a careful eye out for the full range of consequences, some of which may not be intended.

  9. Keith Baker permalink

    Its pleasing to see that these schemes are not universally supported.The point of these schemes is to exclude not include.Those agents whom do as the LA says, regardless of their clients expense or interest, will be allowed in, whilst those whom leave no stone unturned for their clients or whom might disagree with thr LA will be kept out.
    I am not saying that is the primary purpose but for some LAs, if these schemes are allowed to proliferate, it will be a useful tool to sideline proactive or as they see them difficult agents.
    Whilst we are on this topic readers should be aware that the PP is contemplating something similar called “Smarter Planning”

    • Keith,
      I blogged about “Smarter Planning” two days ago and there is more information on the main Portal site

      The idea of our scheme is to encourage e-planning, which is what Government has tasked us with and what we’ve been doing for 10 years. It’s simply a way of engaging with those who may be slower to take up the benefits of our service and recognise those that are committed to our aims.

      We are restricted from paying for marketing and communications so we try and grab peoples attention however we can. Putting work under a banner such as Smarter Planning allows us to focus our resources in a positive way.

      • Keith Baker permalink

        I have seen that and the toolkit’s. The point is that you are putting pre-conditions on showing support and risk alienating agents such as I by that. Our single guiding principle/priority is our clients interest, our own commercial interest being secondary. We will not sell out/agree to anything that could prejudice that, simply for recognition by an organisation or individual.
        One size does not fit all so hopefully you will be able to revise your scheme so that support can be unconditional. For instance a simple declaration of support and a commitment to best practice.

  10. I can categorically say that the Portal team support all users of our service, we do now and always have.
    We go out of our way to help companies migrate from paper to online and do not charge for assistance. We work with LPAs, Government agencies, businesses large and small, at all kinds of venues.
    From time to time we marshall our resources into campaigns such as “Smarter Planning” but we have never excluded any individual or busines from our activity.

    Our support has only 1 condition and that is a committment to operate electronically wherever possible. Where a business agrees to that aim and decides they would like to work with us to achieve it, I think it only right and proper we acknowledge it.

    • Keith Baker permalink

      On the basis of that, can we then expect that you will now revise “Smarter Planning” by removing the prescriptivee preconditions and altering the requirement to “a commitment to work electronically wherever possible”
      Working electronically wherever possible is exactly what we do and we congratulate and support the PP in improving and furthering that. As it stands currently however, we cannot sign up to Smarter Planning because of the existing pre-cvonditions.

      • I’m sorry Keith but we’re just not going to agree on this one.
        I have reviewed the checklist and there is nothing on it that I consider to be onerous or any less than I would expect an e-enabled business to be capable of doing.
        At the end of the day we are only offering a recognition of a mutualy agreed ambition to work in the most efficient way for all parties.
        Government is comitted to a digital future through its Digital by Default programme and I am paid to do all I can to promote it.
        We are not in any way suggesting that if you do not sign up then we’ll leave you by the wayside, but I have yet to come across any industry where supporting best practise is not a good thing.

        P.S Well over 100 agents have contacted us about joining the scheme since yesterday.

  11. Keith Baker permalink

    What do you think gives you the right to be prescriptive over how people work or be the judge of what others might or might not find onerous. I am in fact offended by the patronising tone of you last blog but not I have to say entirely surprised that you will not reconsider.
    I am happy to discuss/disect your “requirements” one by one if you are open to reconsider.For instance agreeing not to pay fees by cheque unless the LA have no other arrangement will mean either telling clients that LAs will not accept cheques (a lie) or, that although LAs will accept cheques we will not allow clients to pay that way (what right do we have to do that), or we will have to accept our clients cheque, bank it, wait for it to clear and then make an electronic transfer (how much delay will that cause)
    I do have better and more productive things to do than participate in a hollow PR excercise so unless you are genuinely prepared to listen and act on constructive criticism I will end my participation here.

  12. Ben Hunt permalink

    Once again, I largely agreee with the last respondent. I am quite happy to commit to electronic submissions wherever possible, and have used this facility on the Portal since its early days, when to say the least things were not as straightforward as they are now.

    But I have looked at the pre-conditions, and a number of them concern me – eg the requirement that all plans / drawings within the same document all have the same scale. There are often occasions where drawings are best included within a document; and where different scales are necessary on different drawings which show different things. This seems unnecessarily prescriptive, and should be left to the discretion of the applicant and agent.

    Fees – whilst I am happy to pay all fees electronically, occasionally the client wishes to pay the fee directly, and whilst I might encourage him/her to avod cheques, I have no control over how they choose to pay it.

    And what does that “application numbers” bit mean? Would I have to commit to submitting a certain number of applications in a set period? The number of applications I submit in a given period varies widely, and is beyond my control. Does this mean that I would not be able to be a “Smarter Planning Champion”, whilst a bigger (but not necessarily better) practice would be given this badge?

    There is a distinct risk that this sort of approach will be seen as something driven largely by the convenience and economies of public authorities – overlooking the fact that applicants are stakeholders in this as much as the rest of the public.

    • Ben, Keith and all,
      I will meet with the team on Monday to discuss all the feedback and post a fuller and considered response then
      In the meantime have a good weekend.

  13. Ben Hunt permalink

    “…. I have yet to come across any industry where supporting best practise is not a good thing.”

    I am a bit shocked by this statement, and not at all surprised that Keith has reacted so vehemently. The underlying assumptions are that you are the arbiters of good practice, that the criteria demanded by the scheme represent good practice in all respects, and that anyone who challenges those things is not supporting good practice.

    • Hi Ben,
      Just to be clear the good practise I am referring to is with regard to the process of electronic submission only.

      I am neither qualified nor would I ever comment on what constitutes a good planning application.

      • Keith Baker permalink

        Plerase excuse me for intervening in your correspondence with Ben, who’s view comment I wholly endorse.

        I have just replied to Scott Alford whom emailed me in reply to my email to him on “Smarter Planning”, It says he is leading that.

        Here is the text from my reply email
        “I want to reiterate that I support your promoting e planning. I do fully endorse and in fact personally make all of my applications that way, including through Submit a Plan for Building Regulation applications and use email for Planning Appeals. You will see that I have contributed to the blog on whichever LA it is that has recently featured, pointing out that it is very simple to migrate from a paper system to all electronic but take care of backup and disaster recovery..
        My singular concern is that there are preconditions/strings attached to supporting “Smarter Planning” which are unnecessary and will prevent such as I from participating. The simple inclusion of “wherever possible/practical” will go some way to removing my objections but I think the scheme need more thought so as to remove the unnecessary, and some instances irrelevant, prescriptive terms from the “contract”. As I advised the director via his blog, I am happy to discuss in detail if that will be productive/constructive.”

        Strangely given your previous comment that you would be speaking to the team on Monday, Scott says (by auto reply) he is out of the office until 5th November.

  14. Jeff Rhodes permalink

    The advent of e-planning has been a revelation, I don’t think anyone would deny that. Aside from submitting planning applications on line (which ironically is perhaps the least useful aspect of e-planning, handy as it is), the ability to view and comment on planning applications and policy documents, local and national, from the comfort of your desk rather than trekking round the country to remote Council offices makes you wonder how we ever managed in “the old days”. BUT, when it gets to the stage that the e-process is actually dictating what and how things must be done, then the tail is starting to wag the dog. One of my pet hates, for example, is on-line consultation documents that try and force you to answer specific questions, attempting to confine your responses to certain things, rather than allowing your to make whatever comments you consider relevant. Likewise being forced to use certain scale drawings, rather than the most appropriate scale for whatever the drawing is of (so long as its a recognised and measurable scale). “Best practice” is not whatever makes it easiest for the regulator, it is what makes it easiest for the regulator AND the customer. In fact Better Regulation and Red Tape Challenge thinking would put the customer first .

  15. Ben Hunt permalink

    Just a couple more points.

    “Hi Ben,
    Just to be clear the good practise I am referring to is with regard to the process of electronic submission only.

    I am neither qualified nor would I ever comment on what constitutes a good planning application.”

    I, and others, have pointed out that there are signficant doubts that these schemes do indeed constitute good practice in terms of electronic submission. Secondly, as terms such as “Smarter Planning Champion” are used, this will signal to many that accredited agents will be “Smarter Planners” across the board, not just in terms of having planning applications validated first time. Understandably, people not in the profession will be unaware of limited scope of the validation process; as well as its flaws (see for instance Adam Roakes’ comments earlier in this blog). You cannot ignore this.

    Lastly, you mentioned that at least 100 agents had contacted you about joining the scheme. This apparent popularity should not be taken as a prima facie indication of its merits. This blog has raised concerns that these schemes provide a (unfair) commercial advantage. If so, their popularity with those who can obtain such an advantage is no surprise.

  16. Jeff Rhodes permalink

    On reflection I like the idea. Can we role it out to LPAs too please so that I can chose to appy to an LPA that is accredited and will deal with my applications quickest? A bit like you can using an accredited national building regulations service provider? Or am I stuck with whoever runs the show where I want to build something? Its ok, I already know the answer to that one.

    • Keith Baker permalink

      I have now heard from BCC with their attempt to justify the legality of their scheme. Text below.

      ” You say that the scheme is unlawful, but not which law it contravenes. If you can provide more detail on this, I am happy to investigate further, but you will not be surprised to hear that we do not consider the scheme to be unlawful. The scheme we have in Bristol is not something new, and you can see reference to such schemes in the PARSOL ‘Fast Track Agent Accreditation Scheme and in the government commissioned Killian Pretty Review. In the later document it is covered in the November 2008 Final Report and Recommendation 13 says “Local planning authorities and other bodies should provide greater encouragement and recognition to those agents who prepare good quality applications on behalf of their clients, in order to drive up the standard of applications submitted”. You will also know that a number of other councils have similar schemes to ours in operation.
      You say that it gives preference to planning applications on the basis of who submits them. In some ways I agree that it does give preference, in that we do not carry out the full validation procedure on applications from Accredited Agents. This is simply on the basis that they have proved that they can make applications that are valid, so we feel we can bypass this process with little risk of having incomplete applications registered. To be clear, no preference is given when it comes to determining the application, and I can assure you that all applications are determined without ‘favour or partiality’.
      You say that there are restrictions on who can qualify, and this is correct, and this is set out on our website, and we do not feel that these are onerous requirements. Again, the threshold we have set is not something unique to Bristol, and evidence from our own records is that around 35% of applications received are made invalid on receipt. This means that we spend significant amounts of time requesting further information (to make the application valid), and part of our thinking was that it was unfair on the agents who do get it right first time in terms of meeting the validation requirements, to have their application delayed whilst resources were put into securing the right information for validation to take place.
      You say that we impose additional obligations on those that join the scheme. Again, this is correct, but agents do not have to join the scheme, and the feedback we have from those who have become accredited is positive.
      You say that we promote only Accredited Agents, and that this is unfair to those who do not participate ‘but are equally expert’. I would not agree that we ‘promote’ accredited agents, and are web pages are clear in saying “The following is a list of planning agents who are on our Accredited Agent scheme. These agents have shown they fully understand how to submit a properly prepared planning application. We cannot guarantee however that the content of the planning application would be acceptable in planning terms when it is considered.”. It is correct that we don’t publish other lists of agents, nor do we recommend agents to potential applicants.”

      I will leave it for you to draw your own conclusions on the above except to say I am sure the “Procedure Order” must bear on this. I am not familiar of anything within it that enables anyone to set any party apart from anyother.

      I will progress and update again in due course.

      • Keith Baker permalink

        Text of My response to BCC explanation above, below.

        “1.
        You appear to defend the Lawfulness of your scheme by reference to Guidance /Proposal and Recommendation. None of which is Law. In fact I recall that the Parsol scheme did identify and raise several areas where it thought it was close to or beyond the Law at the time of its inception. In most instances those have been eliminated by subsequent Acts and SIs but as far as I know none of those revisions have legislated to permit any discrimination between applicants. As I see it General/Common Law, The Procedure Order and your councils Constitution dictates Impartial, Equitable and non Discriminatory conduct of your council

        2
        Giving preference to applications on the basis of who submits them is not in accord with the Procedure Order or your councils Equalities Policy or Constitution.

        3
        Ditto As 2.

        4.I concede that it is the agents free choice to sign up. However there is the point that if agents do not sign up they cannot appear on your “promotional” list, thus they may well feel obliged and coerced for commercial reasons to sign up.

        5.
        Publishing a selective or any other list is “promotion”, it cannot be anything other.

        The overriding point is that the scheme is contrived purely to enable you to “Accredit” and thus favour certain agents. It is false and bogus in the benefits to agents you suggest are accrued or intended. The Procedure Order dictates that properly compiled and submitted applications will in any case be validated more or less immediately, whereas those that are incomplete or lacking will be invalidated awaiting further information. The only benefit to agents in reality is to attain inclusion on your exclusive promotional list.

        It is not that I do not support speeding up administration of applications, I do, but the opportunities for taking advantage of that must be available to all, including members of the public whom want to make their own applications. Especially if they have taken the time and trouble to engage with you in pre application discussion.

        Additionally it is not clear Prima Facie that the accreditation is only in respect of Householder applications nor could I see anywhere that you disclaim recommending those that are accredited or refer to others whom may not be accredited but are equally or more expert.”

        I will value others thoughts/comments

      • I have published this comment with Bristol’s agreement, although I think it sails close to contravening the terms of use of my blog.

        In general terms I try and keep to conversations about the principles and practices of planning and do not usually publish the text of conversations between named individuals or bodies.

        In this case because we were clearly supporting Bristol’s scheme I decided it was appropriate (with their permission to publish).

        I am deeply committed to working with everyone across our industry to promote e-planning and I am therefore naturally biased towards any schemes that further that ambition. It is also Government’s ambition – made very clear in the Government Digital Strategy published yesterday.

        As I have said before we are not selective in who we work with or support, whether it be a citizen wishing to self-serve or any agent wishing to improve their processes. The fact that we support schemes such as Bristol’s should not be seen in any way as reducing my committment to better electronic services for everyone else.

  17. What a lot of hot air this has generated, some of it sounds like sour grapes. I agree that the term Accredited Agent might not be the best terminology for the process, but this is a pilot scheme for household applications only and so far has worked well in my experience over a number of applications.

    Bristol is a core area for my business so I need to get the best & most efficient service that I can, If I was to put in a couple of applications or so a year say in Manchester or Plymouth I wouldn’t expect special treatment, why should I. Anyone starting out in the Bristol can apply to be an AC, they just have to show that they can put a few well presented applications together. I really don’t see what is wrong with offering ‘regular’ professionals a fast track service. Why should we be treated the same as DIY householders who often submit poor applications which tie up the time of registration departments in sending out letters and emails in an attempt to secure the correct information at the required standard.

    For punters who may use the accredited agents listings to select an Architect or architectural designer, all they have to do is to use the excellent facility on the BCC website which shows all the applications that those agents have submitted, they can then review and make judgements based on what they see. This is the page- http://www.bristol.gov.uk/page/planning-and-building-regulations/planning-agents-accreditation-scheme.

    I sincerely hope that the pilot scheme is taken up as a permanent arrangement.

    • Ben Hunt permalink

      Hot air and sour grapes? I think not. These are genuine concerns.

      I do not think that because your core business area is Bristol that you should get special treatment. Planning is a public service, and I would expect to be treated on a fair and equal basis in Bristol, Plymouth, Manchester …….. or anywhere else for that matter. And if I was a DIY householder who submitted a valid application in Bristol, I would question the fairness (and perhaps legality?) of a paid professional getting preferential treatment from the local planning authority whose council tax I was paying.

      Surely if you are submitting valid applications first time you already have an advantage – those applications submitted by others not containing the correct information do not get validated and registered first time, and are therefore delayed?

    • Michael Hayes permalink

      By quoting the link to a list of accredited agents published on an LPA website you are highlighting the point that those of us with misgivings about Agent Accreditation Schemes have been trying to make. Any potential client using a search engine to find an Agent will be presented with this page in the top few hits. They are unlikely to look any further, thus excluding new Agents trying to enter the market and those Agents who choose not to be associated with the scheme.

      Furthermore despite the disclaimers, potential clients are obviously going to be swayed by the official sounding phraseology of “Accredited Agent”. They are going to be seriously misled into believing that it is the quality of design that is being accredited, when in fact all that is being accredited is the “bureaucratic-ness” of the agent’s bureaucratic procedures.

  18. Keith Baker permalink

    Free exchange of opinions/views is it seems only with the Directors reluctant permission (see the directors and my thread above) I posted my reply several days ago and it seems only to have been published now because of BCCs intervention requesting it.

    I can not see that the Bristol Scheme has anything to do with furthing e-planning, it is about speeding up validation. There is no e-planning requirement.

  19. I’ve had enough of this debate. The issue is how can LPAs validate applications more efficiently. The obvious answer is for LPAs to improve their validation process. If a valid application is made, it should be quickly validated by the LPA regardless of who has made the application; planner, architect, builder or whoever. LPAs need to properly resource their validation service to do the work properly and efficiently; that is their public duty after all. Accreditation schemes are simply a devisive smoke screen and Keith is quite right, they have nothing to do with e-planning.

  20. Jen permalink

    I work at a LPA and if we are asked to recommended an agent we direct people to Public Access where there are various search options which will show how many applications a particular agent has submitted, the types of applications submitted and the decision. If people look closely enough they can also get an idea of how long the application took to be validated. It can be time consuming but worth it before they part with their money.
    There is a lot of LPA bashing going on here and the issue isn’t just about how LPAs can improve their processes. Whilst there may be many LPAs which need to get their act together to improve processes and resource the validation function adequately there are probably just as many agents who repeatedly fail to submit a valid application. From experience most of the reasons are to do with the basic national requirements (fee, D&A statement, block plan) and not the local ones.

    • Ben Hunt permalink

      Fair comment by Jen. Your points about the evidence being there in the Public Access system is one that might be developed further?

      But to be clear, I don’t want to engage in LPA bashing – practice is variable, and the validation process is far from perfect. Just like agents. Overall, good agents will tend to get their applications validated without undue delay; and good planning authorities will register valid applications without undue delay. However, we have to recognise that in some instances there are problems with the process on both sides, and that (especially for more complex and unusual situations) sometimes a one-size-fits-all approach does not work well – ref one scheme I mentioned above which requires that all drawings are to the same scale within a document.

      I am all for e-planning, and all for good standards of application submission. What I am concerned about are schemes which give a potential commercial advantage, along with a jump to the head of the validation queue, via a spurious badge of “quality” given to “smarter planners”.

  21. bryan cadman permalink

    PP Directors Blog – Comments and responses

    An interesting and sometimes ‘heated’ debate. Back in the middle of the posts Keith Baker has said that he has made a formal complaint to BCC, and the BCC response has now been published along with Keith’s response to the BCC response.

    This hasn’t picked up all the various points made re AA schemes and about validation generally, so although I’m not sure that I have a role of defending Accredited Agent schemes across the country (and we are a late starter in this as some schemes have been running for years and they have been recommended in published reports eg the Killian Pretty report), I am happy to offer my views on other issues. On specific points of detail, I can only comment as far as Bristol’s scheme is involved. For the sake of brevity, I have put the questions into groups and with my response below.

    1. Q: Its illegal/unlawful/discriminatory as it gives preference to planning applications on the basis of who submits them and discriminates against those who aren’t accredited agents.
    A: I don’t agree that it is illegal, and whilst there have been some references to the Procedure Order and general planning acts and SIs, no one has said which law it breaks. I also can’t see that it is discriminatory, as that phrase in equalities policies is used in connection with discrimination on the grounds of age, race, religion etc. On the preferential treatment point, this needs to be put in context, as this is only bypassing the validation process and does not mean that AA applications get any different treatment in terms of assessment.

    2. Q: Clients will be seriously mislead into choosing Agents with accreditation in the false belief that they are ‘officially endorsed’/’commercially promoted’ by the LPA, and so making the AA schemes anti-competitive.
    A: This is not the intention and our website is clear on what an accredited agent is. It says:
    “The following is a list of planning agents who are on our Accredited Agent scheme. These agents have shown they fully understand how to submit a properly prepared planning application.
    We cannot guarantee however that the content of the planning application would be acceptable in planning terms when it is considered.”
    I think that if you are a client looking for an agent, and if you don’t have a ‘trip advisor’ type recommendation, I can see the Accredited Agents badge as a starting point, but then you would want to find out what it means – which you can find out on the website. You are then only a few clicks away from looking at Planning Online and then reviewing the recent applications made by that agent. I genuinely can’t see that prospective clients won’t look beyond the AA badge, especially as it is easy to get further information.

    3. Q: The term ‘accredited’ implies a quality standard for the application submitted and it does not establish the quality of the submission.
    A: Whilst I can see that it could be perceived as misleading, I don’t agree our scheme does this, and (see above) we are clear on why we are accrediting agents. Accepted it is possible that applications by accredited agents (or any agents for that matter) may ‘have a poor design and access statement’, but if that is an issue with our accredited agents we can use the briefing sessions to address this.

    4. Q: AA schemes are a barrier to new agents/anti competitive, ie meeting the 3 right first time criteria.
    A: Agreed that a new agent will need time to meet the criteria, but I can’t see that this is really anti competitive, and in reality is submitting a valid application such a high hurdle?.

    5. Q: Its impractical for agents who deal with many LPAS to be accredited with all of them, especially if the 3 previous ‘right first time’ applications are a perquisite to entry.
    A: Our scheme is currently limited to Householder applications only, and the agents who make this type of application tend to be locally based. I agree that if you operate on a regional/national scale, it would be impractical to join all such schemes, so maybe there is an argument for regional/national schemes (See Chris Kendal’s blog response to Adam Roake). We do have some agents who operate in this area who are recognised by Bristol and the adj council.

    6. Q: it ties up the system in red tape, ie applying for accreditation and complying with the rules is bureaucratic.
    A: Can’t agree with this as our process for applying is very straightforward, and complying with the rules is primarily around agents submitting valid applications. The other ‘rules’ include ‘acting in a professional manner and not bringing the council into disrepute, and attending a meeting at least once a year. I can’t see this is ‘tied up in red tape’.

    7. Q: it is an admission that the standard service by LPAs is not good enough eg professional agents being tripped up with validation criteria. Those who do not sign up will get a ‘second class service’.
    A: I can’t agree that this shows the service supplied by BCC is not good enough, or that those who don’t sign up get a second class service. I don’t see how the validation criteria ‘trips up professional agents’ and in any event, taking up the option of pre app advice can remove this uncertainty. Our experience is that invalid applications are often invalid because the fee is wrong, required documents ( eg D & A statements) are missing, wrong certificates and inadequate plans. There is a need I think to increase the standard of applications as submitted, and I do believe such schemes can help with this.

    8. Q: It cannot be fair to skip normal ‘statutory’ validation because of the agent applying or to give preference to applications on the basis of who submits them. LPAs should just improve their validation processes and validate applications ‘more efficiently’
    A: We don’t skip the statutory validation requirements, but skip checks we would usually make, for example to ensure that plans match the description of development, and that different plans match. On validation, this activity takes up significant amounts of LPA time, and even with our record of 35% of applications being invalid on receipt (which is quite low compared to some other councils) means we get around 1600 invalid applications a year. Resources LPAs can put into validating applications are finite and in many cases being reduced. Two questions stand out, first is why are so many invalid applications submitted, and second should LPAs look to adopting more draconian measures, eg simply sending invalid applications back stamped ‘invalid’ or impose a separate charge for sorting out invalid applications ?

    9. Q: Accredited applications do not take up less of an officer’s time
    A: the hope is that with Householder applications it might, as the agents who know and understand the validation process and will know and understand the relevant policies that apply to their applications. Although we don’t know if this is the case yet, but we are time recording (started Sept 2012) on an individual application basis, and will have some data over the coming months

    10. Q: a valid application ought to contain sufficient information to determine it, yet most applications end up with a request for further information.
    A: On the first point agreed. But I’m not sure that there is evidence that most valid applications result in a request for further information. No doubt a significant number will need further amended plans.

    11. Q: The point of AA schemes are to exclude not include, and agents who ‘leave no stone unturned for their clients’ or ‘disagree with their LA’ will be excluded.
    A: I would say that the intention of such schemes is to include agents and develop relationships. In BCC’s case, many of the agents are those who often have not got involved with our Planning User Group (which tends to be a forum for larger practices including planning consultancies and focus on larger developments), and the scheme is providing that opportunity for engagement. Although I accept that those who don’t meet the criteria or choose not to join won’t be an accredited agent. Not sure I understand the point that agents who work in their clients interests will be excluded, as the main criteria to meet is around submitting valid planning applications, which must be in the clients interest.

    12. Q: Bristol’s scheme has nothing to do with furthering e-planning.
    A: Whilst our scheme does not currently have ‘e’ working as a requirement, other schemes do. However, it is something we are looking at (see notes from our first scheme meeting) which included a presentation from the Planning Portal, and talks about an additional commitment for Accredited Agents to ‘submit and pay online’

    In summary, I agree that such schemes do need to be carefully considered, and understand some (although not all) of the concerns raised in the discussion. That said, I would argue that the benefits of reducing the time spent on validation, along with joint working with agents (in a positive and pro-active way) make it worth pursuing.

  22. This is a very interesting discussion that airs a wide range of views.

    At the risk of stirring things up again, its possibly interesting to consider things from the customers point of view (and its possibly relevant that there is almost nothing in the above that mentions the word ‘customer’ or applicant!).

    As a recent applicant (customer) I would totally, 100% welcome something that helped me in the selection of a agent who would be likely to be successful and helpful in what can be a stressful and difficult process for many. I would absolutely want to know that an agent works closely with the authority involved, and to see information about their contribution to a successful outcome. I would say such transparency is almost essential to an effective market so that consumers can make informed choices about the selection of their agent.

    Secondly, from the authority point of view it is interesting to note that in analytical work we’ve done with some authorities, some agents routinely submit valid applications (95%+ validity) and have consistently high rates of approvals. Others, with a very similar mix of applications are achieving less than 40% validity and sub 70% approvals! This generates significant costs to local tax payers as well as applicants and it seems its just poor practice.

    Authorities are criticised in the above comments.for poor quality, delay and inconsistency It seems that the same case could be made throughout the ‘supply chain’. Surely the best approach is for agents and authorities to work very closely in the interests of their (shared) customers and high quality development. Setting out clearly the standards that are expected must aid everyone involved and surely the good agents would want to be doing everything they can to support authorities in driving up the quality of applications.

    Furthermore, agents have a business to run and life’s tough enough especially for the small ones. Hence the ‘we only submit a handful of applications’ issue above sounds like a very good reason why the portal should be involved so that all applications are considered even if they are spread thinly over many different authorities. This can only help small, good agents get more business.

    How all this can be balanced is another matter and may or may not involve some form of accreditation, published figures on agent performance or something quite different. But it should be the customer who is at the heart of whatever emerges from the discussion, while supporting the good agents and reducing authority costs and promoting good quality development.

    In my opinion the portal are absolutely right to raise this and be at the heart of this.

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