Planning consultants understand better than most the pressures facing local planning authorities, particularly where those consultants have local authority experience.

Planning departments are under-resourced. Recruitment remains challenging. Applications are becoming increasingly complex, while planning legislation and policy continue to change at pace. while AI for example is making it easier for objectors to make lengthy submissions Officers are managing growing workloads with finite resources and growing public scrutiny.  All as to why a proposal should be refused.

This is not an article about blaming planning officers.

It is, however, an article about asking a difficult question on behalf of the clients we represent every day:

What level of service should applicants reasonably expect from the modern planning system?

Because while the cost of accessing the planning system continues to rise, many applicants would argue that meaningful engagement during the determination process appears to be declining.

Practice is not consistent across the country. Although some do not, and openly so, many officers and authorities continue to engage constructively, often in extremely difficult circumstances. The concern is, when it does happen, that positive engagement is increasingly treated as an optional extra rather than a core part of development management.

The Planning System Is Charging More Than Ever

Over the last decade, planning has become increasingly fee driven.

Applicants no longer simply pay an application fee and await a decision.

Many now pay for:

• Pre-application advice
• Planning Performance Agreements (PPAs)
• Discharge of condition applications
• Bespoke project management services
• Dedicated case officer arrangements
• Amendment submissions (the free-go has gone)
• Reconsultation exercises where revised plans need to be re-advertised or recirculated.

In some authorities, applicants can even pay specific fees to facilitate the submission and assessment of additional information during the determination process.

I don’t object to cost recovery. If additional work is undertaken by a local authority, it is entirely understandable that there should be a mechanism to recover the associated costs.

The interesting question is what applicants receive in return.

A More Transactional Relationship

For many years, local authorities were understandably reluctant to describe planning applicants as “customers”.

Planning decisions are not commercial transactions, and nobody is suggesting otherwise.

However, the relationship between applicants and local planning authorities has undeniably become more transactional.

A developer, business owner, homeowner or landowner can now spend thousands, and in some cases tens or hundreds of thousands, even millions of pounds navigating the planning process before a decision is even reached.

Against that backdrop, it is entirely reasonable to ask:

What level of engagement should the applicant expect?

Not approval. Not favourable treatment. Simply engagement.

The opportunity to discuss concerns, respond to issues and provide additional evidence where necessary.

The “You Can Withdraw and Resubmit” Problem

One of the most common frustrations we encounter as planning consultants happens when concerns are identified during determination and applicants seek to address them.

Historically, this was typically considered a normal part of development management.

• An issue emerged.
• Additional information was prepared.
• Officers considered that information.
• A planning judgement was reached.

Increasingly, however, the response is different.

• Applicants are not routinely informed of an issue
• Feedback is not freely given, and often must be chased
• If an applicant submits additional information (not necessarily any changes) they can be told the information is “unsolicited”.
• They are informed that the assessment of the proposal has already been completed.
• The information will not be considered.
• If they wish it to be considered, they are welcome to withdraw and resubmit.

This is, understandably, frustrating and illogical for clients.

After all, the information already exists. The issue has already been identified, and it might not have been possible to identify it prior to the application, even with the benefit of pre-app. The application is still live.

The only apparent obstacle is a procedural decision not to consider it.

At that point, many clients ask a perfectly reasonable question:

If the information is available now, why is a new application better than considering it within the current one?

The Resource Argument Doesn’t Always Explain Things

The usual explanation is resources. And resources undoubtedly matter.

But in many cases, the applicant is not asking for an enhanced service. They are simply asking the authority to consider material that may address an identified concern.

The question then becomes whether this is, in part, a cultural problem.

Has increasing pressure encouraged a culture where procedure is prioritised over constructive engagement? Is quality being sacrificed for speed?

When Process Becomes More Important than Outcome

At its best, development management is a collaborative, problem-solving exercise.

Identifying issues is only the first part of the process. The second part is exploring whether those issues can be addressed.

That principle is reflected in national planning policy. The National Planning Policy Framework states that local planning authorities should;

“work with the applicant in a positive and creative manner, where necessary seeking solutions to problems arising from initial proposals, to enable a timely decision”.

The language is clear and deliberate. Planning is intended to be collaborative, not merely administrative.

Yet many consultants will recognise situations where process increasingly appears to be prioritised over outcome.

One recent example, an email received by SF Planning from an officer stated:

“I will not be accepting or assessing this additional information.” And:

“The Council has already undertaken a full and thorough assessment, and I am not persuaded that the outcome would differ.”

The issue here is not the individual officer. Nor is it whether the officer’s planning judgement was correct.

The issue is what the statement represents.

A decision had effectively been reached. The discussion was closed. The opportunity to address concerns through further evidence had ended.

The process had become more important than the possibility of a different outcome.

A Perception of Declining Service

Perhaps the greatest frustration for applicants is the perception that engagement is becoming increasingly difficult despite the growing range of services for which they are expected to pay.

Many consultants report:

• Slower responses
• Reduced dialogue
• Greater reliance on rigid processes
• Reduced willingness to accept supplementary information
• Increasing advice to withdraw and resubmit

At the same time, planning services continue to expand their charging structures and offer increasingly sophisticated paid engagement mechanisms.

Again, there is nothing inherently wrong with charging for additional work.

But it does create a legitimate expectation that applicants will receive a proportionate level of service in return.

Many clients would argue that they are paying more than ever to access the planning system while receiving fewer opportunities than ever to influence an outcome once an application has been submitted.

Whether that perception is fair in every case or not, it is sufficiently widespread among applicants and consultants to warrant serious discussion across the profession.

An Important Conversation for the Profession

The planning profession should not be afraid to discuss these issues.

This is not about criticising local authorities. It is not about challenging the professionalism of planning officers.

And it is certainly not about suggesting applicants should receive a positive decision because they have paid a fee.

It is about whether the balance has shifted too far.

Whether development management is becoming increasingly focused on administering applications rather than managing development.

Whether a planning system that continues to promote positive engagement, proactive working and collaborative problem-solving is drifting towards a more procedural and transactional model.

Most importantly, it is about whether applicants are receiving the level of service they should reasonably expect from a system that asks them to invest more time, more money, more resources and more of themselves than ever before.

A constructive and responsive planning service should not be viewed as an unreasonable expectation.

And that is a conversation the profession needs to have.

We want to initiate and be part of that conversation. I firmly believe that there is a way in which all parties can collaborate to help deliver high-quality development in a timely manner.

Our consultants will continue to be proactive. We do, and will always try to:

• attend agent’s forums whenever they are held;
• respond to all relevant consultations; local, regional, and national;
• give honest feedback in a way that is constructive and respectful;
• request, and make ourselves available for, open conversations with planning officers, section heads and directors.

The latest NPPF empowers LPAs to process applications in open collaboration with applicants. We wait with interest to see how that translates to a timely and equitable process for everyone involved.

Get in Touch

SF Planning provides frank and responsible advice and assistance on a variety of planning matters. Get in touch to see how we can help with your project.

e: info@sfplanning.co.uk

t: Cheltenham: 01242 231575 | Gloucester: 01452 527997 | London: 020 3763 8005

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