Supplementary Memorandum by The Royal
Institution of Chartered Surveyors (PI 10(a))
These are supplementary comments from the Royal
Institution of Chartered Surveyors to the Environment, Transport
and the Regions Select Committee's review of the Planning Inspectorate.
The RICS initial submission to the investigation centred on responding
to the questions set by the committee on the work of the Planning
Inspectorate. In that submission we stated that we do not perceive
any major problems with the Inspectorate and that the under-resourcing
of local authority planning departments is a much more serious
barrier to an effective planning process.
Following an informal discussion we have been
informed that the current investigation may be broad enough to
consider other elements of the planning system, including local
authorities. We are therefore pleased to submit an additional
paper, which we hope will be of use.
LOCAL AUTHORITY
PLANNING DEPARTMENTS
Delivering quality
The RICS is increasingly concerned that local authority
planning departments are heavily under-resourced and are finding
it difficult to ensure a high quality service. For example a range
of organisations, including the Local Government Association,
have called for the greater use of pre-applications stage discussions.
However as under-resourced planning departments are often driven
by the need to meet their targets for processing submitted applications,
they are unwilling to enter into such discussions. Perversely
of course preapplication discussions would lead to a faster processing
of submitted applications, and one would consider, a higher quality
final decision.
The workload of local authority planning departments
is growing, as it has to address an increasing complexity of issues.
For example planning departments are now having to review increasingly
detailed and complex environmental and transport impact assessments.
They are also entering into legal agreements over complex planning
obligations, covering areas as diverse as public transport provision,
infrastructure, urban design and even training provision.
In addition the government's Modernising Planning
Agenda is placing even greater burdens on planning departments.
For example due to the new planning policy guidance for housing,
local authorities will be expected to undertake a range of additional
projects such as urban capacity studies and developing methodologies
for a sequential approach to housing.
Local authorities are being frequently criticised
for the delays in updating their local plan. However the quality
of plan making is heavily reliant on the resources provided. It
would for example be interesting to compare local authorities
speed in plan making, with the budgets allocated for this process.
Specialist Advisors
There is increasing emphasis for, and commitment
to, high quality design, both of buildings and public spaces.
This is evidence in the formation of the Urban Design Alliance
and the forthcoming Government guidance on design. As a result
of these moves local authorities will have to call upon the services
of qualified conservation/design officers. This will be necessary
to enhance public acceptance of any design led criticism of schemes.
Clearly this will have an extra cost as far as staffing budgets
are concerned.
A reactive system
If local authorities are going to take a proactive
role, for example using their compulsory purchase powers to assemble
"brownfield" sites for development, this will require
extra resources, or removing resources from other areas.
If local authorities are going to be able to
work with developers (across the public, private and voluntary
sectors), to ensure the mixed-use, mixed tenure formats, incorporating
high urban design standards, needed for an "urban renaissance",
this will again require more resources.
The source of the problem
The Institution concern is that there may be
in certain cases a local political imperative behind under resourcing
planning departments. Slowing the planning process down can put
off politically unpopular decisions. Matters of regional and national
strategic importance may therefore fail to be properly addressed,
for example ensuring an adequate housing supply and the provision
of waste management and recycling sites.
There are also concerns that the best practice
indicators for planning may be too rigidly enforced and actually
act against a more effective planning system. We have set out
our concerns in Annex 1.
Recommendations
1. The ETRA Select Committee should hold
an inquiry specifically into the effectiveness of Local Authority
planning departments. Such an inquiry should consider:
— are planning departments properly
resourced,
— are the current best value indicators
resulting in a more effective planning system,
— do best value indicators hide more
than they tell,
— what is the level of planning costs
recovered via fees,
— are developers willing to pay higher
fees for a better planning system,
— what is the attitude of elected members
to the planning system, specifically development control.
Such an inquiry would we believe unearth a great
deal of useful information and throw a spotlight on an increasingly
worrying situation.
2. The DETR should sponsor research into
the effectiveness of local authority planning departments. We
would consider this would be both a quantitative and qualitative
survey.
Quantitative
The research would look at a range of planning
departments to compare indicators such as:
(1) The levels of work associated with Policy
(Regional Planning, Structure Planning, Local Planning), Development
Control and Environment and Conservation. Also additional workload
pressures now caused by "Process", eg Best Value and
Modernising Local Government and Modernising Planning initiatives,
must be considered.
(2) Levels of financial and human resources
deployed at present compared with the last five years and prospects
for the next five years in the light of revenue budget estimates.
(3) Number of cases per officers, broken
down into scale and type of proposal. These would be compared
with the time taken to approve an application.
(4) Number of pre-application stage discussions.
This would be compared with the number and stated reasons for
refusals.
(5) Number of refusals, which are subsequently
resubmitted and approved.
(6) Number of officers and budget involved
in the plan making process.
Qualitative
A survey of planning officers and "customers"
of planning services to determine if individuals believe:
(1) if a quality service is being delivered.
(2) if resources are a barrier to the effective
delivery of planning services.
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