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The pre-application process is being milked for cash by some councils

Peter czerwinski york aerial view
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While the draft NPPF recommends early engagement with planners, most architects find the process unreliable and expensive, writes Brian Waters of the Association of Consultant Architects 

The government’s new draft National Planning Policy Framework (NPPF) emphasises the benefits of pre-application consultation. ‘Early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties,’ it rightly claims.

In 2014 the Local Government Association (LGA) published a paper endorsing this approach, with 10 commitments. These include:

  • Pre-application engagement should enable sustainable development to proceed quickly and smoothly to completion. This is a co-operative process that requires a positive, proactive commitment from participants.
  • Those providing pre-application services should offer a range of timely, effective services proportionate to the scale and complexity of proposed development. The process, timescales, costs and outputs should all be clearly set out.
  • Pre-application services should be delivered in a timely manner and demonstrate good value for money, irrespective of whether the provider makes a charge for them.
  • Pre-application discussions should bring together the right people to address all of the development issues.

Local planning authorities have been offering pre-app consultation services with different levels and charges for some years. Feedback from ACA members has been mixed, so we did a survey.

Architects used to have a trusting relationship with planners but the pre-app process has formalised this almost out of existence

It turns out that pre-application planning services offered by local authorities are so unreliable and expensive that some architects have stopped using them altogether. Many architects say they would rather submit a full planning application and use that as the ‘sounding board’. 

Many said the guidance they received was nothing more than a regurgitation of the council’s policies or was given by a junior officer, whose advice was later overruled by a manager. 

Two-thirds said the advice given did not cover all relevant issues and more than half said they had experienced cases where an entirely new issue which could, or did, lead to refusal had emerged after the pre-app process. 

More than 85 per cent said they were not happy with the system. And 80 per cent said councils failed to provide their advice within the agreed timeframe – sometimes taking as much as a year. None had ever received a refund for a missed deadline despite the service involving a contractual agreement. Two-thirds said planning authorities no longer offer a free informal preliminary discussion with a duty planning officer. 

The pre-app process has gone badly wrong in some local planning authorities and is increasingly used as a way of generating income for under-funded departments. Given the stretched resources of these departments, there is room for some sympathy. However, milking the pre-app process for disproportionate income, as is increasingly the case, should be prevented. ‘Pre-application services should be delivered in a timely manner and demonstrate good value for money,’ says the LGA. It goes further than the draft NPPF, which should make this recommendation a requirement.

In authorities where the pre-app report or advice consists mainly of trotting out a précis of related policies, which a competent agent can do perfectly well, it makes perfect sense for the applicant not to bother, knowing that on an appeal the authority will say to the inspector ‘We told them so’. Avoiding this kind of pre-application trap does not always solve the problem, however, because among the reasons for refusal there will often be the statement that the applicant had ‘failed to seek out pre-application advice’. Many architects used to have a trusting relationship with planning officers and could sound them out informally on proposals but the pre-app process has formalised this almost out of existence.

Before endorsing the system further, the government should examine how it is working and come up with some safeguards to ensure it does what it says on the tin. Readers who share this poor experience of the system should respond to the consultation on the NPPF before tomorrow’s deadline.

Brian Waters is president of the Association of Consultant Architects, the national professional body representing architects in private practice in the UK. Membership for eligible practices is free.

Image by Peter Czerwinski

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