This was submitted by Harald Tobermann, LCCC Vice Char and spokesman on planning, in April 2017.
- There is widespread dissatisfaction about appeal decisions made by DPEA. Likely reasons are
- lack of DPEA visibility (perceived as ‘remote’);
- inadequate space for third parties during appeals. In addition, planning councillors are sometimes shying away from “political” decision because of exaggerated fear of an appeal.
This can be remedied by better resourcing of the DPEA (for publicity and education) and under certain circumstances for third party participation in appeals.
- Planning fees are far too low to cover real costs of processing (incl defending appeals and enforcement). Fee caps for large applications are absurd: if there are demonstrably planning efficiencies of scale (where is the research?), fees could be tapered. But not capped. Arguments that this hinders development can be easily set aside: as long the fees go into resources, applications will also be processed at a speed more likely to encourage development. We would also suggest that fees should be set locally, not nationally.
- Much higher emphasis needs to be placed on design quality and build quality, as well as a systematic assessment of the infrastructure requirements associated with the development: each development – however small – should make a proportional contribution to education, health, transport and green infrastructure. The present system of hoping for rateable value increases is not delivering the required infrastructure. In addition, there needs to be a requirement to deliver most infrastructure up front or at least in parallel for all large developments.
- Planning authorities need to have statutory rules regarding the quality and robustness of their planning IT (recently very poor in Edinburgh); there also needs to be a statutory enforcement regime with teeth. The current system is not fit for purpose. Funding has to come from increased fees.
- Planning authorities should be required to reflect on and report annually on the quality of their decisions: not how many went to appeal, but by visiting completed developments shortly after completion and 2 years later.
- Planning permissions need to have to come with keener timelines: expiry between 18 months and 3 years (in exceptional and transparent circumstances); extensions only in the form of another application with full fees; abolition of ridiculous definitions of site start (recently, a dropped kerb qualified as site start).
- Planning authorities should be required to make annual/biannual capacity assessments of existing infrastructure (and in the immediate pipeline) for each neighbourhood.