Pre-application good practice

Worthwhile Pre-application
Engagement
Phillipa Silcock
9th June 2014
www.pas.gov.uk

Housekeeping + Introductions
+ thanks to our hosts, Turley

What is Planning Advisory Service
for?
“The Planning Advisory Service (PAS) is
part of the Local Government Association.
The purpose of PAS is to support local
planning authorities to provide effective
and efficient planning services, to drive
improvement in those services and to
respond to and deliver changes in the
planning system”
(Grant offer letter for 2014/15)

Key Facts
• Started in 2004
• Funded by DCLG
• 11 staff. Supplier framework. Peer
community.
• Always subsidised. Mostly without charge.
• Non-judgemental. Not inspectors
• Respond to reform. Keep you current
• Support, promote, innovate

Pre-apps: the conundrum
• Here to talk about discussing
development proposals before they
enter the formal planning system
• Given: creating a chance to talk while
the proposal is still fluid is ‘good’
• But, it’s a discretionary part of the
planning process and
• The discussion has to be worthwhile
for people to be bothered doing it

Objectives for today
• To think about what makes a worthwhile pre-
application discussion
• To share some good practice from councils who
have been working on creating an attractive
offer for early discussions
• To look at the workbook
• To go away with some aims
for the improvement of your
offer to prospective applicants

Agenda – morning
• 10 commitments across the sector
• Michael Lowndes, a developer’s view of
worthwhile pre-app discussions
• Nicola Townsend, Croydon council’s pre-
application offer
• 11.30 Coffee and tea
• Frances Wheat, PPAs in Camden
• 12.40 Lunch

Agenda – afternoon
• Richard Crawley, Calculating the cost
• 14.40 Coffee break
• Cllr Mike Jones, Involving councillors and
communities in pre-app discussions
• Richard Crawley, PAS planning Quality
Framework
• 16.30 Finish

Not just listening…..
• Pre-applications Suite
• Discussions on your tables
– Your pre-apps offer
– Using PPAs
– Calculating the cost
– Involving members and the community
• A chance to explore the advice, recognise
where changes will strengthen your
planning offer

What pre-app should do
• Faster route to planning permission
• Chance to improve schemes
• More sustainable development
• Save abortive costs
• Build community acceptance
• Build in what the community wants
• Mitigate problems
• demonstrate political leadership

All the things that were wrong
• Developers not bothering/not listening
• Councils using charges as a cash
generator
• Just slows the system up
• Inconsistent procedures
• Still surprises - not everyone involved
• No commitment to the advice given
• And still too many conditions even if
permission is granted

10 Commitments
• A cross sector effort
- councils
- developer reps (HBF, BPF and FSB)
- statutory consultees ( big 5)
- community reps (Locality)
- RTPI and POS

10 Commitments
Goal
To get our own houses in order, so that
pre-application engagement will deliver……
“…high quality and appropriate development
schemes being granted planning permission
more quickly.”
“to shape better quality, more accepted
schemes and ensure improved outcomes for
the community.”

The commitments for LPAs
1. Quick, smooth process from proposal to
completion
2. Choice and range of options
3. Help the developer
to chose the most
appropriate option

4. Demonstrate the good value of your
service and meet the standards you
promise
5. Co-operate to get the right people at the
table
6. Promote an open exchange of
information
Pre-app brand
values
Trust Cost Time Reliable

7. Be collaborative – consider everyone’s
needs
8. Involve councillors in the discussion
9. Engage communities as early as possible
10.Record the information considered,
advice given and agreements reached

Mike Lowndes
What am I looking
for in a
pre-application service?

Our Pre-application offer at Croydon
How we manage to provide a comprehensive,
proportionate and good value service
Nicola Townsend
London Borough of Croydon

Pre-application process: historic
problems
– Silo working
– Inputs at the wrong stage – fixing problems rather than
designing success
– A mindset of identifying problems rather than working to find
solutions
– A tendency to only engage superficially with proposals in the
pre-application phase
– Limited engagement with Members/public
– First time Members see a strategic item is when determining

Aim
• Improve the quality of development in Croydon
Objectives
• Work with developers to align mutual objectives
• Fully harness the planning skills in our service
• Involve members constructively in the process
• Create the conditions for effective engagement of the local
community
• Get Croydon building
Pre-application process

Key ingredients
Get the organisation, processes & decision making right:
• The structure of the Development Management service
• The relationship between DM & Spatial Planning
• The pre-app process itself
• The use of project management
• The wording of your constitution
• Planning committee organisation
• Member training
• Member involvement
• Delegation scheme

Departmental structure & working
• Strategic Applications Team
– Virtual team
– Centre of excellence for dealing with big applications
• Having a project management mindset
– Clear responsibilities & expectations
• Spatial Planning working relationship with
Development Management
– Integrated process

SP & DM integration: how not to do it
Urban Design phase → Detailed application preparation phase
Development ManagementSpatial Planning

SP & DM integration: how we now do it
Spatial Planning
Development Management
Urban Design phase → Detailed application preparation phase

Pre-application: What we offer at Croydon
1. Duty planning officer service
15 minute appointment to discuss householder and business extensions
2. Correspondence service
Appropriate for domestic extensions or shop fronts, signs and alterations to
small business premises
3. Pre-application meeting service
It is not suitable for complex, major developments, but it is ideal for other
types of planning application
4. Development team service (DTS)
The DTS is a new enhanced service designed for development proposals that
are more complex and likely to raise a number of issues

DTS approach
• Strategic schemes are complex projects – recognise that and use
the right tools to manage them properly
• Preparing a major application costs a lot of money – efficiency
saves time & money
• Developers want as much certainty as possible – they are willing
to pay for and engage in an enhanced service if they have
confidence in it
• There are two approaches to pre-apps:
– “Show & tell”
– Joint design team approach
• Co-ordinated, collaborative & constructive

What is the DTS?
The stages What we expect from the
developer
What happens What is the expected outcome
Initiation
meeting
• OS map and description of
development
• Meeting with more senior
officers to look at strategic
issues
• Consider the process
needed
• Planning statement covering:
– Strategic policy issues
– Project plan
– Draft Planning Performance
Agreement
Urban
design /
Stage 1
• Draft Design Statement
including an urban design
analysis
• One or more design
workshops to understand
the site, it’s surroundings
and the nature of the
development and how it can
be accommodated
• Design Statement and concept
scheme
• PRESENTATION TO STRATEGIC
PLANNING COMMITTEE
Communit
y
engageme
nt
• Illustrative material of proposed
scheme, preferably including
options
• Meaningful engagement
with the community affected
• An explicit feedback
session
• Consultation response report and
amendments to concept scheme
Application
preparatio
n
• Draft planning application
• Draft Impact Assessment
• Draft heads of terms of S106
legal agreement
• One or more workshops to
understand the details of
the development, its
impacts on immediate
neighbours and the
surrounding area generally
• Completed planning application
• Planning Performance Agreement
• Agreed S106 heads of terms
• PRESENTATION TO STRATEGIC
PLANNING COMMITTEE
Closedown
phase
• Final amendments to planning
application
• Address any final
comments from members
• A valid planning application ready
for submission

How does the DTS work?
• Start with a red line around a site
• The scheme evolves through collaborative working
• Requires commitment from both sides
• Project focus
• Deal with all issues prior to application submission
• Planning application stage not place for negotiation
• Clean and good application = determine in time
Cost
Payable in stages and varies depending on the scale and
complexity of the development. Assuming one main
meeting at each stage:
• £1,800 (plus VAT) for minor applications
• £3,600 (plus VAT) for major applications

Can it work?
• Scheme: 100,000 ft2 spec offices
• Location: close East Croydon Station
• First Contact with LPA: January 2012
• Application submitted: February 2012
• Planning permission issued: March 2012
• Construction starts on site: July 2012

Other schemes to have been through
DTS
• Westfield/Hammerson
• Cane Hill
• Lion Green Road
• Taberner House
• Quest House
• Tesco Purley Way
• Schools applications

DTS conclusions
• A culture change for members, most officers and many
developers
• Took time to fully introduce all elements of the process
• Members are involved constructively in the process
• Fully harnessing the skills in our service in an integrated way
• Mind shift to pro-development
• Developers are gaining confidence in Croydon
• Most importantly better schemes are emerging
• Croydon is open for business!

“ The integration of our pre-application process into the council’s
committee process has meant that strategic planning committee
members now play a greater role in the design process and input
into the scheme’s development before it is submitted as a planning
application. Our aim is to encourage high quality developments that
enhance Croydon and this is enabling us to do that.”
Cllr David Osland, Former Chair of Strategic Planning
Committee & Cllr Paul Scott RIBA, Current Chair of Strategic
Planning Committee , London Borough of Croydon

Turn to Section 2 of the
Pre-applications Suite
Workbook
• How does your service
measure up?
• What are the challenges
that you face in
improving the range of
services you currently
provide?
• What would be the first
thing you’d change?
Workshop 1: Running a
positive and business like pre-
application service

Planning Performance Agreements in Camden
PAS Pre- Application Services Workshop - 10 June 2014
Frances Wheat
Head of Development Management

Structure of presentation
• Why Camden encourages PPAs
• When we encourage PPAs
• Camden’s service offer
• Success so far
• Examples
• How Camden benefits

Why Camden encourages PPAs
1: Improves quality of planning process
• Shared vision and policy objectives identified
• Effective stakeholder involvement
• Collaborative working
• Fosters strong and productive
partnerships
• An improved customer service
• Better value in long term
• Removal of 13/16-week time constraint

2: Facilitates well informed, robust decision making
• Effective transparent community engagement
• Community empowerment and ownership
• Building trust
• Less objection, more support
• Certainty through Member involvement
• Avoidance of refusal and lengthy appeals
• More sustainable and higher quality developments

3: Facilitates workload planning
• Core and ‘flexible workpool’ model
• Discretionary pre-application advice paid for by those
who benefit
• Service can respond to development pressures
• Fixed term contracts for additional staff

What sort of PPAs do Camden offer?
• Pre-application
• Application stage
• Post decision
• Significant clients who submit a number
of applications and enquiries each year

When do we encourage a PPA
planning proposals that:
• are strategic
• require Environmental Impact Assessment
• on larger sites that include a variety of land uses
• have impact on strategic areas of environmental sensitivity
• on sites with many constraints to be resolved
• involve significant non-standard planning obligations
• referable to GLA or Secretary of State;
• significant impact on existing communities which require wide
consultation/ involvement with stakeholders
• unique to a local authority’s experience.

Camden’s charges
For a flat rate of £6,000 (exclusive of meeting costs), 2 types of PPA are offered:
Type 1: Pre-application through to decision PPA
Type 2: Post decision PPA to consider Approval of Details and s106 discharge of
obligations
E.g. of meeting costs
Large major £4,000 for full pre-app meeting, £2,000 for breakout meeting/workshop
Development Management Forum £1,500 + cost of venue
Developers Briefing £1,000

Success so far
Steady increase in use of PPA
• 2010: 4
• 2011: 5
• 2012: 12
• 2013: 18
Some examples :
• Kings Cross Central masterplan site
• Housing Service’s Community Investment Programme
• Francis Crick Centre (UKCRMI) - Kings Cross
• Hawley Wharf - Camden Town
• West End Lane development - West Hampstead
• Kings College London Campus – Finchley Road
• North East Quadrant – Regents Estate
• 79 Camden Rd
• SAATCHI site - Fitzrovia

Case Study: Hawley Wharf
• Mixed use scheme comprising 180 flats, school, commercial and
town centre uses. EIA development and referable to the GLA.
• This was a re-submission after a committee overturn
• Screening: PPA was necessary
• Scoping: Timetable of meetings agreed - including 2 x Member
Briefings, a Development Management Forum for local community.
• Vision and objectives, key stakeholders, policy position, procedural
arrangements and committee date all agreed.
• Implementation: First of 25 agreed meetings held in May 2012,
with application presented at agreed Committee in November.
• Key benefits: Community engagement resulted in only 30
objections (previously 170), Member involvement allowed more
certainty and understanding of a very complex proposal.
• Decision was to unanimously approve

So for Camden a PPA is not just about
removing the time constraints…
a PPA will:
•limit bureaucratic approach
•promote shared objectives , visions, goals
•allows flexibility
•build trust and strong partnerships
•give genuine voice to local communities
•establish transparency and more certainty
•result in well informed and robust decision
•Ensures staff resource is available for discretionary service

Workbook
• How does your service
measure up?
• Take a look at the
templates for PPAs on
your tables
• Are you able to
demonstrate that PPAs
are worthwhile for
developers?
Workshop 2: Using PPAs more
effectively

Lunch
Please be back by 13.30 at the
latest

Richard Crawley
Calculating the cost

Costing / charging for pre-app
How hard can this
be …

Before we begin
• This is not a precise science, and there are
several important stakeholders
– Finance director
– Staff providing the service
– Investors / Developers
– Place shapers
• Don’t treat this just as a technical exercise
– Needs to be done right, for the right reasons, with
political support
– And followed-through

Before we begin
• The world is a confusing place, and people
keep changing their minds
• Expect questions, challenge and negotiations

Applicatio
n
Post-
App
The application process

Pre-App
Applicatio
n
Post-
App
Pre-application advice
Fee
Fee

Pre-App
Applicatio
n
Post-
App
PPA
Pre-application and PPA

Pre-App
Applicatio
n
Post-
App
PPA
Pre-application and PPA ?

Pre-App
Applicatio
n
Post-
App
PPA
Yellow bits = enhanced service ?

Pre-App
Applicatio
n
Post-
App
PPA
Policy positions …

(i) Understanding councils costs
• Even if you’re not going to charge,
discretionary services need to be designed
with cost in mind
• Services are (mostly) provided by people
– Who,
– How long
– How much per unit
– ……….. Does it add value ?

• To derive a “productive hourly rate” you need
to wrangle three things:
• Productive time
– How many hours are available for work ? (after
holiday, supervision, training)
• Cost of employment
– Salary, NIC
• Overheads
– Light, heat, payroll, corporate, ICT

• Productive hourly rate = cost / hours *
overheads
• [worked example]
• [Note wrinkle of consultation ripples]

ii) Recovering costs
• Recovery = recovery (only)
• Method
– Standard charges
– Standard charges +/-
– Phased
• Make life easy for yourself – standardise,
average, communicate

iii) Estimating standard charges
• Understand your building blocks
– Eg hourly rate = £50
– Job = 4 hours
– Price = £200
• Scaling
– [use example]

iii) Estimating standard charges
• What if they want another hour ?

iv) Introducing a schedule
• Think about monitoring
• Talk to your neighbours
• Be ready to learn

Your turn
• For a few minutes each, consider these
extracts from charging schedules [all
downloaded on 5th June 2014]
• Assume the role of buyer. What do you
like / not like

The Planner [Dec/Jan 2014 p. 43]
“The RTPI’s experience is that most
complaints about consultant’s fees occur
when no agreement has been formalised
between consultant and client. There should
be no ambiguity. It is advisable to cover the
following items”
Summary table of estimated costs; detailed
tables of time costs; reimbursable expenses;
subsistence and daily allowances; terms and
schedule of payment.

Closing
• Support your staff
– This is not for everyone
• Negotiate the freedom
– Beware corporate policies on headcount / savings
– More income = more resource requirement
– Don’t break your service promises
• Corporate decision
– Approach to fees
• Fail without a win-win
• Great opportunity to project positivity !

Cllr Mike Jones,
Leader Cheshire West
and Chester Council and
Chair LGA Environment
and Housing Board

Workbook
Workshop 4: Involving
Councillors and the
community • What guidance do you
provide to encourage
active, early
engagement with the
community?
• How do you facilitate a
situation where your
councillors can more
effectively act as civic
leaders and work for
their communities in
relation to proposals?

Richard Crawley
The Planning Quality Framework

‘The research suggests that government planning performance
targets may be driving perverse behaviour,’ he said.
‘This is especially worrying as the research also finds that a focus
on good practice in local planning authorities is required if the
NPPF is to be fully effective.
‘A number of local authorities are exemplary according to the
performance data but described as ‘horrendous’ by those with
first-hand experience of working with them.’
Under this regime, efficient authorities that focus on customer
service and enabling good development could be placed in
special measures because they miss their targets, while others
could be lauded for gaming the system.
‘The evidence from the research suggests that government
proposals to increase the threshold for designating authorities as
underperforming may only make matters worse,’ Betts added.
• Clive Betts, Chair of all-party select committee
[4th April 2014]

Why PAS can help
• Benchmarking since 2009. Trusted. Expert.
• Bring together all the components (now)
– Leadership
– Positive planning
– Good practise
– Peer working
• Working towards integrating
– Plan-led system
– Quality and focus on development (not consents)

Why PAS can help
• Benchmarking since 2009. Trusted. Expert.
• Bring together all the components (now)
– Leadership [councillors; AMR; standards]
– Positive planning [pre-app; PPA; evaluation]
– Good practise [s106; cttee;]
– Peer working [design; cohorts]
• Working towards integrating
– Plan-led system [policy ?]
– Quality and focus on development (not consents)

A framework based on three things
• Application data (inc quantitative ‘quality’)
• Survey data
• Feedback on quality
• Powerful as three separate things
• We’re going to bring them together
• We’ve never done this before

PAS Benchmark Quality Framework
You have to do it all The more chunks you do the
better the value
Once per year, and if you
miss the boat – tough.
Just begin.
Snapshot in time Trend over quarters
Industrial strength cost
accounting
Low hassle and easy. Means
to end.
Internal management tool External badge of quality
• Both free, sector-led (designed through pilot
group) and based on “understand to improve”

What’s the commitment ?
• You need to provide
– A chief data wrangler to set up, maintain
– Annual survey of councillors, staff, amenity groups
• What do you get ?
– Detailed understanding of what’s happening
– Survey feedback on peoples’ opinions
– Data on quality of work and outcomes
• Together = balanced, holistic framework

What next?
• The Planning Quality Framework will be
launched in September
• Preparing more Good practice sharing
materials:
- committee structures
- project management of major schemes
- s106 processes
• What else?

Follow-up evaluation
• We employ a company to follow-up on our
work
– On reflection, was today actually useful ?
– 10 mins of feedback in return for £100’s of
support
• Our board use this to decide what we do
with our grant. If we don’t get positive
feedback we are unlikely to continue
• We do note those who don’t have time to
put a little back…..

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Phillipa Silcock
Phillipa.silcock@local.gov.uk
Twitter @phillipaPAS
PAS email pas@local.gov.uk
web www.pas.gov.uk
phone 020 7664 3000

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