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Streamlining the planning application process – have your say

by on January 22, 2013

Now I know you are a shy lot and like to keep your opinions to yourselves but I thought I would make you aware of an opportunity to have your say on the topic of application process simplification.

“Who cares!” I hear you all shout but just in case you want to influence the future of such things as: simplifying the requirements for design and access statements, improving the validation stage and requirements around local authority decisions notices, I have included the link to the consultation for you.

You have until March 4th, 2013 to opine, go on, don’t be shy!

  1. Simon Evans permalink

    Thanks for alerting everyone to this. I am sure those of us who feel deeply frustrated by the weight of bureaucracy that has accumulated around the whole business of making planning applications these days will welcome the opportunity to comment. This is particularly so in the case of DAS’s whose purpose looks great on paper but in practice seems to count for very little. I may be unique but of the countless number I have produced over the years, I have yet to have one referred to by anyone!

  2. Michael Carroll permalink

    I think I can speak for many agents in saying that the validation process for planning applications has become something of a nightmare over recent years. The process seems to have become a “tick box” exercise often given over to relatively inexperienced officers who have not been granted the luxury of using professional judgement in determining the validity of applications, and are somewhat reluctant (or unable) to listen to reasoned argument or pass the matter upward for determination by more senior officers. Mistakes in interpreting the information supplied are commonplace, all of which adds to the delays and frustration in trying to resolve any given issue.
    As I understand it, the official guidance for validation requires all requests for additional information to be relevant and proportionate. Unfortunately, in my experience, this guidance often seems to be ignored.

  3. Edward McGill RIBA permalink

    The new requirement in some areas to fill in a CIL local tax form before even a porch extension or an open fire escape application can be considered results in form filling with no current tax revenue. The planning office tell us that CIL local tax is to be gradually extended to even the smallest “domestic” projects and this is the reasoning behind the forms. Until it is there should not be a need to fill in these overly complex tax forms on projects of small size. Currently the CIL tax only applies to domestic extensions over 100 msq, in areas that it has been implemented, why fill in a complicated CIL tax form for 5 msq?

    Maybe a declaration on the householder application form to say simply that “the proposed work is under the current 100 msq tax level” would do the same job with less waste. As the CIL local tax base level is gradually reduced the form could be revised to keep track.

  4. Mark permalink

    As a local authority planning officer, I have to say that 90% of the invalid applications we receive are due to basic errors on the plans, i.e. drawings not corresponding with each other. I think both ‘sides’ need to take some responsibility here for speeding up the validation processes.

  5. William Cole permalink

    Please do not sweep away all the existing regulations before you have suitable replacements in place. Or you will alienate all parties as in the current implementation of new Core Strategies after the old Local plans have expired. Result the rape of conservation areas and a flood of “Garden Grabbing” proposals as at Stratford upon Avon

  6. Michael Carroll permalink

    I can only speak from my own experience, Mark.

    That happened to me a while back, where it was claimed, 12 days after submission, that a 1/1250 site plan didn’t match my 1/50 main drawing. The site plan had been prepared using an official OS issue, and was accurate. A protracted debate ensued. When I eventually had time to visit the planning department with hard copies, the 2 site plans were compared and it transpired that there was a 10% difference between what I had submitted and what the planners’ printer was producing. Hardly my fault, yet they refused to backdate the application to avoid any further delays. And no apology was given either.

    Another LPA asked me to submit existing and proposed rear elevations for a dwelling, because the rear wall was to be rendered. The property was not in a designated area, so I queried as to why it was necessary. No sensible explanation was forthcoming, so I simply had to do what was asked just to move things along. The 2 elevations were virtually identical – with a few ink dots to denote the render. This is notwithstanding the fact that rendering is PD in non-designated locations in any event.

    I’m sure your own LPA adopts a more sensible approach – but it’s this sort of thing I’m referring to; and it happens all too often – and with differing LPA’s and validation officers. It’s known as “nit picking”, and I’m afraid it’s becoming a disgrace.

    In order to balance my comments, I have to say in fairness that I deal with many planning officers who are sensible, helpful and an absolute credit to your profession. But I stand by my theory that the tendency to use junior inexperienced staff members for validation is causing many problems which would otherwise not occur if professional judgement was the accepted culture in relation to the validation of householder planning applications. That’s how things used to be, and there was nothing wrong with it.

  7. Jeff Rhodes permalink

    Yes, with a genuinely poor application which is invalidated the application/agent only has themselves to blame but I deal with LPAs across the UK and I’m afraid some do routinely invalidate applications on spurious grounds to buy time and some use validation/clerical officers who don’t always understand plans or planning regulations or who slavishly adhere to every point on a local list even where it is plainly irrelevant to the actual proposal. Most times there is absolutely nothing you can do about it other than grit your teeth and do what they say to get the application validated so its already got off to a bad start before the application has even been considered. That helps nobody and achieves nothing, it just creates tension between the parties. As regards this consultation, rarely for me I cannot actually find fault with the proposals, they all make sense! In fact I can’t really see how an LPA could argue against the proposed improvements either (and I’m also speaking as an ex LPA officer). Of course this is just validation though, the real fun starts post-validation.

  8. Michael Carroll permalink

    Thanks for the moral support, Jeff. I have to agree that it sometimes feels as if there is a hidden agenda. I often wonder whether validation officers have been instructed to nit pick so as to hold back the flow of applications being passed on to case officers.

    Most of my work involves domestic extensions, so planning approval is virtually guaranteed by using the published design guides. Because of this, it’s validation that has now become the “gamble” – not whether the proposal receives planning consent.

    For me, the anxious period for most jobs is between submission and validation – that’s the time I’m half expecting some “new” requirement to come out of nowhere. And, as you say, since there is no mechanism to achieve a quick solution when you feel you are being unfairly treated, you just have to do what is asked and spend extra time preparing and submitting trivial information to satisfy a validation officer – that’s time and effort which I for one don’t get paid for.

    It has now come to the point where I, and others I know, try to avoid taking jobs in certain areas – simply because of the disproportionate effort and expense required to achieve validation. And that cannot be right.

  9. Thank goodness something is to be done about the validation process. I get on well with the professional planing officers in my unitary authority, and they are pretty good at determining applications within the 8 week period, but the validation process is so slow…it regularly takes two weeks and upward…and I’m an “Accredited Agent” which is supposed to mean that my applications are validated quicker than others because I’ve a proven track record in submitting good quality applications. It’s definitely become a “tick box” exercise, handled by junior admin staff who are almost impervious to reason…if it’s on their list and you haven’t sent it in, the application doesn’t get validated, regardless of relevance or proportionality.

    Another gripe I have is that, despite having used the planning portal for some years now to lodge all my planning applications online, the LPA still on occasion send out letters in the post asking for any additional validation information, usually a fortnight later.

  10. As a manager of a validation team I can assure you we do not delay applications and there is no hidden agenda. We want to provide a good service, it would only create issues for us otherwise.

    My team validate the day the application comes in, most are invalid due to errors on the plan, such as the title relating to another site, a north point in the wrong direction, the wrong site outlined, the wrong scale quoted, the elevations not annotated correctly, not because the local requirements have not been adhered to. I cannot see why the local list creates a problem at all – The local list is published, it is clear for all to see what is required, prior to submitting the application, it just needs to be referred to. The list is not onerous, it is very basic for householder applications. If something minor is missing, a phone call puts it right and the application is registered immediately. We do all we can to get the application though as quickly as possible and it concerns me to read that this view of validation teams exists.

    Validation should be an adminitrative process, checking the relevant information is there and that it is accurate. Our other customers, the planning officers, are very happy with the service they receive from my team. They know the application is ready to determine on receipt from us.

  11. Michael Carroll permalink

    N – I’m sure you run your section very well. But I was not referring to applications which incorporate mistakes. That’s just bad work, and those applications deserve to be invalidated.

    But here are 2 other things that have happened to me recently.

    A dwelling due for extension had 2 detached ramshackle corrugated metal sheds in the garden, which I had shown on the block plan as scheduled for demolition. I wish I hadn’t done that because, 10 days after submission, I received a letter asking for elevations of the sheds. In line with Graham Bennett’s comments, there was no reasoning with the validation officer, so I had to travel 14 miles back to the site to take photos and measure up the 2 sheds, only to find on arrival that they had, quite legally, already been demolished and lay in a heap in the garden. On notifying the validation officer, he was having none of it. I was either to send in an amended block plan, or elevations of the sheds. I hastly drew up some elevations – freehand and from memory only. The scruffiest, most unprofessional piece of work I have ever done – prepared in anger, I have to confess. The application was then validated a few days later – about 2 weeks after submission. To this day, I cannot make any sense whatsoever of that incident.

    An application involved a timber detached garage with roof space storage. It was a marketed building product. No plans were available from the manufacturer – only a photograph of an identical building which had been erected before at a different site. I prepared proper scaled drawings of the building, and submitted the application together with the photograph, the purpose of which was clearly explained in the application. A few days later, a very puzzling message was left on my answerphone saying that the the description on the application was wrong. On telephoning back, at 4.15 the same day (a Friday), I found that the validation officer had left for home and would be on holiday for the next 2 weeks. But someone else would ring back. The following Wednesday, I got the call. Turns out the reason for the delay was that the validation officer wanted to agree a revised description saying that the application was for “retrospective consent”. The officer had looked at the photo and, without reading the accompanying information, had come to the conclusion that the building had already been erected. Obviously, the matter was resolved there and then and, in fairness, the application was backdated to the day it was submitted. So this little problem had arisen simply from a lack of attention on the part of the validation officer. Not a major issue I would concede – but still somewhat annoying, and, regretfully not untypical of the sort of mistakes that seem to arise on a regular basis, irrespective of my attempts to present high quality submissions.

    So you see, N, it’s not the process that is the real issue here. It’s more about the attitude and inexperience of the staff employed in that process. Too often they get it wrong in my view, and it is we agents, often in the face of spectacular intransigence, that have to spend valuable time putting it right. But with regard to your own office, it sounds as though you’re doing a great job, and you can no doubt be rest assured that these sort of things never arise in your own area. Obviously, it is the behaviour others that has brought about this poor view of validation officials. I hope a way can be found to eliminate that view.

  12. Gabriel Pallaris permalink

    Regular invalidations occur with my planning applications , the last two I submitted were refused primarily on the grounds that I had not filled in the correct Planning Application forms, both projects were in Conservation Areas and the works involved quite substantial demolition and reconstruction. I was told ” you don’t have to fill in the above form, but should use a Householders Application”, the explanation from the council, was that the substantial demolition needed to occur and applied for buildings detached from the main house. ( over 150 cubic metres )
    Secondly more why is it now practise that if applications are made for planning consent that are within permitted development they are not returned for an application to be made for a Certificate Of Lawfulness, instead they are allowed to go through the process and are often refused planning.
    I seems that Councils do not observe normal courtesy but take take money in order to make more by default.

  13. As a sole practitioner mainly working in the field of residential extensions and new-builds, I am ambivalent regarding validation.
    My LPA validation team are generally excellent in that, where there is a query, I get a phone call or email and can usually clear up any issues within 24 hours.
    However, the validation letters are issued by post, often two weeks after the validation date and, despite representations, there seems no mechanism in place which allows email validation letters when both my, and my Clients’, email addresses are included in the application.
    Welcome to the age of steam!!

  14. j2013 permalink

    Personally, I am concerned that this Government will remove an essential asset of planning applications. As a resident, I have objected to two planning applications, both based on the D&A Statement, which is a great reflection of how much thought and consideration went into a developer’s plans. I noticed mention of the use of render further up this thread. I have to say that render in particular is a cheap and cheerful option, and can be used to spoil the look of entire neighbourhoods, particularly when combined with ultra-modern windows and doors, and roof tiles which stick out like a sore thumb. Just because I don’t live in a Conservation Area does not mean I don’t deserve a reasonable townscape! In my experience, developers have little concern for the look and feel of existing neighbourhoods. I have thus far been able to refer to the D&A Statement for my ammunition against the development proposal. Where will I look now?

    I truly feel that it is poor developers holding up planning application processes, not the process itself!

  15. Jeff Rhodes permalink

    With all due respect to the likes of “N” who try to make a bad system work ok, I was pleased to read the other day that some Councils are now also so fed up with it they are ditching validation and validation teams/officers. Wolverhampton for example now just pass applications direct to the planning officer, who straight away starts dealing with the application and if he/she needs any more info just asks for it in the course of dealing with the application. I think Coventry may have done similar, possibly others. Hallelujah! By the way “N”, I would not really class your planning officers as your “customers” – well not unless they are paying for your services – they are just another part of the Council so far as your real customers outside the Council are concerned. Perhaps thats part of the problem, systems being designed with the wrong “customers” in mind.

    • I am planning to commission a deeper look into the work of Wolverhapmton and others who have taken this approach.

    • Hi Jeff

      Believe it or not I am not totally against this stance! – If the latest proposal out for consultation is adopted, then validation will involve considering material considerations or the scale of a proposal when deciding on what information to request, and it may sit better with a qualified planner. However I also know the planners view of this is having worked with one who previously experienced this arrangement. The admin team were disbanded, the planner ended up doing all the administrative tasks, not just validation. I do feel therefore that the admin team have a place in the process (but that is my personal view only!).

      I still insist the planners are our customers – We provide a service to them but we do consider all our customers and I hate to think that we are not providing a good service to all.

  16. Jeff Rhodes permalink

    Hi N, I don’t know your local authority, and for all I know you may well be an exemplar of best practice, but as you can see from other comments, unfortunately the garden isn’t so rosy elswehere. I’m certainly not advocating disbanding admin teams – there is a lot of admin to do in addition to validation (eg consultations, e-planning maintenance, committee reports admin, decision notice admin etc), and this may well include validation. I think people are just highlighting that the validation part of the process has run away with itself after Local Lists were “invented”. It sounds to me like all Wolverhampton (for example) have done is go back to how it used to work – as I remember it when I was on the LPA side of the fence. I worked in Development Control for 4 different planning authorities in different parts of the country and validation was very simple back then, as per the national regs: plan identifying the site, application forms and certificate, and that was it. Technically even the fee wasn’t required for validation, although it was invariably required. The case officer – me – just asked for anything else whilst dealing with the application. My admin colleagues provided very helpful support, but they had enough to do without complex validation checklists and frustrated applicants to worry about.

  17. Michael Carroll permalink

    With regard to location plans, in my view, these are often unnecessary for householder applications. Whereas they may be useful in identifying isolated countryside properties, in normal town locations, a 1/500 block plan is sufficient information to enable the case officer to assess the proposal and its effect on neighbouring properties.
    However, many LPA’s refuse to validate unless a further 1/1250 plan is submitted indicating at least 2 streets, and this can sometimes prove difficult where a property occupies a central location in a very long road.
    Since these days most people have access to satnavs and google maps, I often wonder as to the actual purpose of location plans for typical home extensions.
    Perhaps this is another matter where professional judgement should be exercised.

    • I do agree to your comment as to the necessity of the 1/2500 Location Plan. It is nothing but a sales income. Apart from maps, a street view of the Building is also available at no cost.

  18. I was recently asked for an Energy Statement for a car port ??? The person who contacted me obvioulsy had no idea of a car port and was merely ticking boxes. She said that she couldn’t valid as there wasn’t an energy statemnt. So I sent one saying that the building was not heated nor did it have any lighting. Result – application validated !!!!

  19. I agree with a lot of the previous comments with delays resulting from basis errors with submission and over zealous planning support staff. However, even with the proposal to streamline the system with many authorities having reduced staff down to a dangerous level, I can still see delays occurring as staff may take the easy option and just invalidate to give them time to deal with the applications and enqueries coming through.

  20. Doug Fisher permalink

    Some of these validation delays may be down to incompetence and staff shortages but what is really hard to accept is when they only seem to be caused by the desire to meet 8 week targets.

    Case officers also seem to do this, presumably being under pressure from their seniors. One such ploy appears to be to impose a ‘reserved matters’ condition on the consent in order to get the application processed before the target decision date. This is despite procedure manuals requiring minor outstanding details to be obtained on the site visit in order not to have to impose such conditions.

    I have had this happen on three occasions – the most blatant being a ‘materials and finishes’ reserved matter on a garden building consent (not in a conservation area and almost PD) when full details were already on the original plans/ application form. The case officer would not be specific about what further details were needed. I had no choice but to submit a ‘reserved matters’ application that merely repeated exactly the same information.
    It may have helped them meet their targets but it meant a 2 month delay for me. I could have appealed the condition instead but that would have delayed things even further.

    No doubt others have had similar experiences that are worse than a couple of weeks validation delay.

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