3. The Annual Planning Survey
Shaun Andrews,
Head of Investor & Developer Planning
18 September 2012
glhearn.com
4. âPlanning refusal shows Authority
is âclosed for businessâ
âPoorly performing planning
teams face special measuresâ
âCameron to tackle planning again in
attempt to kick-start economyâ
âLabour: reforms take power out of hands of
local peopleâ
âHousing approvals fall by thirdâ
âGovernment push to reform planning laws could
backfire, warns senior planning officerâ
5. About the survey
⢠Survey of those closely involved in planning in public and private sector
⢠Applicants - 180 respondents - principals and professional advisors
⢠Local planning authorities â 40 senior managers, 11 London Boroughs
⢠Early indication of attitude following introduction of Localism Act and NPPF
⢠Annual survey to measure change
7. Key Findings
Investment Decisions
⢠Whether to invest in a project ⢠Perceptions of LPAsâ approach to
informed by: development not encouraging
Positive
â Traditional factors such as: 10%
⢠Market opportunity
⢠Fit with investment strategy
Negative
41%
â Increasingly influenced by:
⢠Previous experience of an LPA
⢠Reputation of an LPA
Neutral
49%
8. Key Findings
Top planning considerations when seeking permission
The political control Other
of the local authority
The cost of
submitting a planning
application
The likelihood of
securing permission
The local planning
authorityâs
performance
The cost of planning
obligations/Communi
ty Infrastructure Levy
(CIL)
The time it takes to A clear planning
get a decision policy position
9. Key Findings
Planning applications
⢠Length of time to determine ⢠Cost including fees and obligations
Very satisfied Satisfied Very satisfied Satisfied
1 8% 1% 2%
Very
Very dissatisfied
dissatisfied Neutral â itâs Neutral â itâs
fine 22%
25% fine
17% 29%
Dissatisfied
Dissatisfied 46%
50%
12. Key Findings
Greatest challenges
⢠Over the last three years: ⢠Over the next three years:
â Maintaining services with â Maintaining services with
reduced resources reduced resources
â Legislative change causing â Legislative change causing
uncertainty/complication uncertainty/complication
â Development viability â Getting plans / policy in place
â Delivering housing â Delivering housing
â Increased expectations in the
âpost-Localismâ world
15. Key Findings
Attitude to reform
⢠Thinking generally about the Governmentâs agenda, do you think it will
materially:
â Deliver more homes and economic growth?
⢠Yes: 32% applicants & 12% LPAs
â Produce a faster and leaner planning system?
⢠No: 79% applicants & 83% LPAs
â Overall, increase or decrease development activity?
⢠Neither increase nor decrease: 71% applicants & 88% LPAs
16. Key findings
What would make the biggest difference?
⢠Applicantsâ views on what would ⢠Local authoritiesâ priorities for
make the biggest difference to improvement
performance
â Processing applications faster â CIL
â Empowerment of officers / de-politicise â Production of policy documents /
the system
â Improvement to evidence base
â Investment in LPAs
â Pre-app consultation
â Increase accountability
â Training of members
â More commercial culture
â Size and budget of planning depts.
â Clear delivery frameworks
â Involving members in pre-apps
â Increase accessibility to officers
â Speeding up delivery of decisions
â Pro-growth agenda
â Improved policy documents
â Further training for officers & members
â Increased consistency
18. The Annual London Development Management Survey
⢠All 33 London Boroughs were surveyed
⢠Objective - review management of all major planning applications
⢠Major planning applications - 10 or more dwellings, residential sites over
0.5 ha, non-residential sites over 1 ha or creation/change of use of over
1,000 sq. m. gross
⢠Timeframe - 12 month period preceding publication of NPPF in April 2012
⢠Benchmark year from which post NPPF change can be measured
22. Approval Rate of Major Applications
100%
90%
Percentage of Major Applications Permitted
80%
70%
60%
50%
All London Boroughs
23.
24. Number of major applications decided
vs. approval rate Westminster
Brent
No. of Major applications determined
Hammersmith &
Fulham
Redbridge
City of
London
Proportion of Major Applications Approved
25. Likelihood of Committee Overturning Recommendations
20%
18%
16%
14%
12%
10%
8%
6%
4%
No recommendations for major applications overturned
by committee in 19 out of the 33 London Boroughs
2%
0%
All London Boroughs
27. Time To Determine Major Applications
120
100
80
Weeks taken to determine
60
40
20
Validation to determination
0
All London Boroughs
28. Time To Determine Major Applications
120
100
80
Weeks taken to determine
60
40
35 week average determination
20
0
All London Boroughs
29. Time To Determine Major Applications
120
100
80
Weeks taken to determine
60
40
20
13 week target determination
0
All London Boroughs
30. Time To Determine Major Applications
120
100
80
Weeks taken to determine
60
1 year DCLG target
determination (inc. appeal)
40
20
0
All London Boroughs
31. Time To Determine Major Applications
120
100
31 week average inquiry
80
Weeks taken to determine
60
40
20
0
All London Boroughs
32. Time To Determine Major Applications
120
100
2 years
80
Weeks taken to determine
60
40
20
0
All London Boroughs
33. Time taken vs Approval rate
100
90
Redbridge
80
Weeks to determine applications
Hammersmith
Enfield & Fulham
70 Westminster
Croydon Bexley
60
50
40
30
Barking &
Dagenham
20
50% 55% 60% 65% 70% 75% 80% 85% 90% 95% 100%
Proportion of major applications approved
34. Appeals Decided (Average all Boroughs)
120 100%
90%
100
80%
70%
Number of appeals determined
Percentage of appeals allowed
80
60%
60 50% Number of appeals determined
Percentage of appeals allowed
40%
40
30%
20%
20
10%
0 0%
2008-9 2009-10 2010-11 2011-12
41. Creating a service culture
⢠Would applicants support an increase in application fees if, in return, a
âservice contractâ with the LPA was put in place?
⢠Could a new style PPA work if it had teeth and guaranteed a timetable and
standards and embodied principles such as:
â Urgency
â Transparency
â Accessibility
â Accountability
â Consistency
⢠Would it be right for applicants to be able to âOpt outâ and go straight to
inspectorate if authorities are placed in âspecial measuresâ ?
⢠Should central government funding relate to performance?
43. The Governmentâs objective
Steve Quartermain,
Chief Planner for England, Department of Communities and Local
Government
18 September 2012
glhearn.com
44. The Local Planning Authorityâs view
Sue Foster,
Executive Director Housing Regeneration & Environment,
London Borough of Lambeth
18 September 2012
glhearn.com
45. The applicantâs view
Adrian Penfold,
Head of Planning and Corporate Responsibility, British Land
18 September 2012
glhearn.com
46. The two cultures of planning?
Adrian Penfold www.britishland.com
Head of Planning and Corporate Responsibility
47. Outline
⢠The Hampton Review
⢠The Killian Pretty Review
⢠The Penfold Review
⢠Public and private sectors - differences and similarities
⢠Conclusions
47
48. The Hampton Review
Principles of better regulation
⢠Transparent
⢠Accountable
⢠Proportionate
⢠Consistent
⢠Targeted â only at cases where action is needed
Assessing our Regulatory System â The Hampton Review (2005)
48
49. The Killian Pretty Review
Reinforcing a service culture â the decision makerâs view:
⢠Applications not fit for purpose
⢠Relational nature of the process â trust and understanding
⢠Limits of frontline staff empowerment â political process
⢠Resourcing difficult
⢠Perverse incentives from targets
The Killian Pretty Review: Planning applications - A faster and more
responsive system: Final Report (2008) 49
50. The Penfold Review
Strengthening service culture
⢠Publish service standards
⢠Improve coordination of consenting bodies
⢠Improve accessibility of information and guidance
⢠Survey customer satisfaction
Resource pressure
⢠Joint working
⢠Charging
The Penfold Review of non-planning consents (2011)
50
51. In your experienceâŚ
* Local Planning Authority survey results, GL Hearn and British Property Federation (2012)
Ć Developer and applicants survey results, GL Hearn and British Property Federation (2012)
51
52. Public sector vs private sector
The Leadership Trust âLeadership in the public sector â is it different?â (2009)
Based on a survey by Ashridge 52
53. Public sector vs private sector
The Leadership Trust âLeadership in the public sector â is it different?â (2009)
Based on a survey by Ashridge 53
56. Goals and objectives
To ensure that the Borough Council has a robust plan to ensure
planning decisions are in accordance with the strategic needs of the
town and that the plan is prepared in sufficient time to ensure that
it maximises developer contributions and avoids planning by
appeal
56
57. Conclusions
Areas for improvement
⢠Education/CPD
⢠Interchange
â Career change
â Secondments
⢠Status of planner in organisation
⢠Transparency
⢠Targets
⢠Escalation
⢠Resources
⢠Accreditation of experts
⢠Fees
57
61. London is differentâŚ.
⢠Democratically: Mayor, City & 32 London Boroughs
⢠Organisationally: London Plan and Local Plans =
Development Plan
⢠Demographics/economics: net contributor to national
recovery, plus tackling its own issues â with partnership
working/investment
⢠Growth: Only Region where house prices rising and
growth/jobs being delivered significantly. Census 2011
⢠Focus on delivering outcomes desired by national
policy â through London localism: at neighbourhood,
borough and London-wide levels
62. Governmentâs reformsâŚ.
⢠NPPF (what happens to the remaining guidance?)
⢠Secretary of State Statement 6 Sept.12
ď Growth Measures
ď Planning Reforms / Streamlining
⢠Mayorâs response: 13 Sept.12 Letter to Mr Pickles: -
ď Supports big investment in housing development and key infrastructure
ď Opportunities for Private Rented Sector and Empty Homes brought into use
ď Changes of Use (commercial) and PD relaxations
ď Public Sector Land & Property Holdings â innovative investment models
ď Prioritisation of Major Strategic Developments and Planning Applications
ď Stronger Collaboration and GLA / London Boroughs Partnerships
ď Take Over more high profile and cross-borough planning applications
ď Lead on S.106 reviews and development/housing viability âskills and effective solutions
ď GLA greater role, rather than PINS, on key strategic development decisions
63. Revised Early Minor Alterations to
London Plan
⢠Presumption in favour of sustainable development: in principle,
the Plan is the London expression of the NPPF
ď 87 policies consistent with NPPF, 33 policies consistent in substance
ď 1 policy inconsistent: affordable housing definition (EIP November)
⢠Affordable Housing and Affordable Rent: new policy position;
realism and responsibility in addressing housing need and funding
⢠Minor updates e.g.
ď Localism Act
ď Neighbourhood planning
ď Duty to cooperate
ď Community based initiatives for renewable and low carbon energy
ď S106 & CIL
ď Cycle parking
64. ImplementationâŚ.
⢠âBarriers to Housing Deliveryâ project: complementing Government
elsewhere in the country
⢠Real partnership working at area / site level â Boroughs/Developers
⢠OAPFs: focusing on delivery through partnership working
⢠The Olympic legacy: MDC in action: Queen Elizabeth Olympic Park
⢠New Delivery Vehicles: Dev Corporations/EZs: any further potential?
⢠Enhancing quality and streamlining housing standards: Housing SPG
⢠S.106 renegotiation: role for GLA in London
⢠Strategic support for Neighbourhood Planning: Shaping Places SPG
⢠Mayoral Funding Support: Outer London Fund / Regeneration Fund
65. Other new strategic challenges
⢠Population: latest ONS projections and Census: -
ď1 million extra people in London (a new Birmingham inside M25?)
ďPopulation increase could almost double relative to 2011 London Plan?
ďWhat does this mean for household growth?
ďDensities and household size gone up
⢠Employment: back to 2007/8 peak
ďWhat can planning do to sustain growth in current economic environment?
⢠Further Alterations to London Plan policy:
ďPolicy and implementation responses to tackle key issues
ď e.g. new SHLAA, Borough housing targets revised
ď housing and commercial requirements/provision
ď ageing and younger population; increased student numbers
ď social / community infrastructure, i.e. schools/health
67. Other Mayoral planning documents
â˘Coming out this Autumn:
â˘London Planning Statement
â˘Housing SPG
â˘London Office Policy Review
â˘Industry & Transport SPG
â˘Note on duty to cooperate and the London Plan
â˘Draft SPG on Crossrail s106/CIL
â˘Later in 2012/13:
â˘Draft Sustainable Design and Construction SPG
â˘Draft guidance on hazardous substances
â˘Draft Town Centres SPG
68. Build your own home â the London
way
⢠Guidance published 28 July
⢠£3m resource funding to help community groups work up
designs, potentially culminating in a Community Right to
Build Order
⢠GLA keen to promote this through Neighbourhood
planning forums
⢠CRTB@london.gov.uk â for more information
⢠£5m development loan finance for custom build
- Design for London organising event 28 September
2012
- CBH@london.gov.uk â for more information
69. Other things to watch out for.....
⢠Mayor's "2020 Visionâ
ď Prioritising Implementation Delivery/Opportunity Areas
ď GLA Land Holdings â leverage and unlocking development
⢠Government: Taking forward the ministerial "housing
and planning" statement in London:
ď"failing" LPAs
ď unpicking s106s
ď changes to major infrastructure thresholds
ď design standards
⢠CIL & Funding Priorities - Potential changes
ď "technical" changes (s73) and wider changes: BPF Group
ď Boroughs / developers/ land owners prepared to fast-track
development will improve Mayoral funding potential
Thank you Alastair. Weâre very pleased to be able to share with you today the key findings of the research we have undertaken. We have actually undertaken two research projects. I will cover first the Annual Planning Survey undertaken with the BPF, and then a little later move on to our London focused development management data.
The debate around planning reform has become hugely polarised and these are just a selection of the headlines from over the last few weeks.So, what does the survey work tell us that might help cut through the rhetoric and help us gauge the real current âstate of planningâ?
Firstly, some background on the annual planning survey ⌠[read slide]
Firstly the applicantâs view âŚ
This first slides looks at investment considerations ⌠[read slide]The most popular themes or comments from those not responding positively were:Negative mentality or culture â a âpresumption against developmentâLack of consistency of approach or serviceToo much politicsLack of commercialityToo reactiveDelays
Next we look at what respondents listed as the top planning considerations when seeking permission:- Certainty â the likelihood of getting permission- Policy â having a clear position- Time â it takes to get a decision- Cost â of obligations/CIL- LPA performance- Political control â of the LA
Focusing now on planning applications, key concerns relate to:Time â 75% of respondents are dissatisfied with the length of time a typical planning application takes to be decidedCost â 68% weredissatisfied with the typical cost of a planning application (this includes fees, executive time, concessions and planning obligations)
But havenât Planning Performance Agreements or PPAs made a difference? - Only 25% of those that have entered into PPAs believed that they were positive- They are generally considered ineffective, time consuming and do not represent value for money
Turning now to the views of local authorities
We asked what are the greatest challenges faced by Local Planning Authorities?Over the last 3 years ⌠[read first colum]Over the next 3 year ⌠largely the same issues raised but with âgetting plans and policy in placeâ emerging. Probably a reference to the pressure being exerted by the NPPF for plans to be in place in 1 year and / or the Community Infrastructure LevyNotably not development viability in the next 3 years
When asked how do you think applicantsâ view their authorities approach to planning, 75% respondents said positive.There is clearly a general mismatch between this response and the Applicantsâ responses above.
Some of the questions were directly comparable between applicants and LPAs
There is a high degree of scepticism shared by both applicants and LPAs with respect to DCLGâs overall objectives for planning reform. We asked⌠[read bullets]
So what would make the biggest difference?We asked ⌠[read column headings]Although there are similarities between the items raised by both parties, the highest ranked are quite different. Applicantsâ are looking for speedier decisions and the greater certainty that they feel that some de-politicisation might bring. For LPAsâ CIL and policy activities rank highest.
In order to better understand the issues and concerns around how planning decisions are currently made, GL Hearn has undertaken more detailed research looking closely at each of the London Boroughs and the processing of major planning applications (using a combination of Local Authority and PINS data and our own). As we have already shown, the characteristics of individual LPAs is increasingly becoming an investment criteria in its own right. Therefore in the context of a planning system that can be inherently inefficient, a detailed understanding of individual boroughs is important.
Some background on this survey which was a quantitative review rather than an attitudinal survey⌠[read slide]
This background slide shows all major applications dealt with in London by Borough It ranges from 89 applications in Westminster to 10 in Barking & Dagenham and Kingston upon Thames. These numbers exclude those seeking to vary previous permissions e.g. Section 73 applications.
The Annual Planning Survey has shown use that Certainty, Time & Cost are three of the most important factors from an applicantsâ perspective and we have grouped our analysis accordingly
Firstly, certainty âŚ
This slide shows us the approval rate of major applications across all London boroughsThe average approval rate ranges from 57% to 100%The average approval rate across all London boroughs is 85% and therefore reasonably high
This is the same information shown spatiallyThis represents a fairly random picture and reinforces the need to understand each Borough in detail and separately
This slides brings together data on the number of major applications each Borough dealt with during the year and its average approval rateAs you can seen there is a very wide spread and in the top right hand corner we have highlighted the 5 boroughs who dealt with the highest quantity of major applications and have the highest approval ratesCity of London, Hammersmith & Fulham, Redbridge, Brent and Westminster
This slide indicates that likelihood of Planning Committee overturning recommendations19 boroughs had no major applications overturned at planning committee during the year preceding NPPFOf the 14 others, rates range from 2%-19% (or almost 1 in 5)
Moving on now to time
This slide illustrates the time each Borough took to determine its major applications
Onaverage 38 weeks Fastest borough from validation to determination averages 18 weeks and slowest around 87 weeks. A quite massive variance.
None average the 13 week government target
This is the 12 month âplanning guaranteeâ that the coalition has promised to introduce and, on this basis, that looks pretty achievable, however, there exists a small problem in that âŚ
The 12 month guarantee includes any appeal that might be requiredA public inquiry appeal is currently averaging 31 weeks for these sorts of applications in London and therefore putting this timeframe out of reach for most LAsIt is also important to remember that this slide shows averages and that a great number of applications currently massively exceed the timeframes shownThere is no doubt therefore that this is a huge challenge
And to put all this in context - this indicates the two year line
Another scatter diagram this time showing time taken vs. approval rate Just as an indication - Barking & Dagenham, Hammersmith & Fulham, Redbridge, Enfield, Bexley, Westminster and Croydon approved 90%+ of its applications within 40 weeks
Looking now briefly at appeals, this shows the number of appeals decided and the proportion of appeals allowed between 2008-2012 Overall the number of appeals have dropped but those allowed has remained fairly consistent and ranged from 29-33%. Actually lower than we had expected.
Moving finally to cost
As you can see Planning application fees have increased only marginally over the period 2007-2013 This is based on an average 50 resi unit scheme 2013 includes the 15% increase duePre-app fees have however grown and represent a significant additional cost
This slide aims to highlight the total indirect cost to project of planning application fees and S106/CILFirst we have application costs as per previous slideNext average S106 costs for major applications in London (excluding affordable housing)Finally we need to add on affordable housing and CIL. We have no hard figures on this but there is no doubt that this is significant and ranges from borough to boroughThe main point Iâd like to make here is that application costs are relatively small in relative terms although I am not playing down their significance in a very difficult market
CIL as you know has arrived although the take up so far has been lowThese slides are taken from our CIL monitoring service and illustrates that by next year many more boroughs will have its CIL in place as shown in greenThe deadline as you know for those boroughs who wish to take it up is 2014
So, finally, some thoughts for discussion this morning from me
Dipping back again into the Annual Planning SurveyWhen LPAs were asked what will the planned 15% increase in application fee next year enable them to do. - Only 3% thought that it might allow them to deliver an improved planning service. - 82% thought that it could only maintain the status quoThis poses some real issues in the context of further public sector funding not being made available. Must fees rise further? What is the right balance between planningâs traditional regulatory origins and a modernised customer / service provider relationship?
In this context, how might we create an improved service that both LPAs and applicantsâ might be proud of?⌠[read slides]Thank you