Planning Advice Note: PAN 48
PLANNING APPLICATION FORMS
1. This Planning Advice Note (PAN) identifies some key points about the content and layout of planning application forms, and makes suggestions for improvement. It also provides two good practice models of planning application forms; a general form, and a form for householder applications.
2. The statutory basis for the content of planning applications is contained in Part 2 of the Town and Country Planning (General Development Procedure)(Scotland) Order 1992. The legislation sets out the content of applications in general terms but planning authorities can ask for such information as may be required to enable them to determine an application. As a result, there is a wide disparity between planning authorities in the amount of information they seek, and in the design and layout of application forms. This PAN therefore provides an opportunity to rationalise and simplify planning application forms.
3. Responses to the Review of the Town and Country Planning System in Scotland highlighted the need for a more user-friendly, simplified, planning application form. It was argued by some respondents, local authorities and the private sector, that incomplete application forms were a major cause of delay and dissatisfaction. Clearer guidance and simpler forms would lead to greater accuracy of information supplied, and contribute to improvements in the efficiency and effectiveness of the development control service.
4. Applications for planning permission are made up of 5 main elements:
- the application form, plus up to 3 copies (as directed by the planning authority);
- a certificate of notification to owners or tenants of agricultural holdings;
- a certificate of neighbour notification, and a plan showing the location of neighbouring land;
- a plan which clearly identifies the location of the application site and such other plans and drawings necessary to describe the proposed development, plus up to 3 copies; and
- a fee.
5. Applying for planning permission, even where guidance is available, can be a daunting task, particularly for those who have had little experience or involvement with planning. Variations in the style and content of application forms can also be confusing for applicants such as architectural or surveying practices, and small builders who deal with several authorities.
6. As a matter of best practice, planning authorities should seek to hold pre-submission discussions wherever possible. This is useful for the authority and the applicant as potential problems can often be identified early on, and so prevent delays during processing.
7. This PAN only deals with the submission itself. Many of the suggestions for improvement contained in this advice are based on the good practice of planning authorities who have attempted to make their application forms easier to complete. The two model forms, included as annexes, illustrate good practice in the design and content of planning application forms. It is suggested that local authorities take these examples into account when reviewing their own forms, although local circumstances may require some changes to the detail. The two forms are :
a) a Householder Planning Application Form; and
b) a General Planning Application Form.
These have been prepared as two application packages, each of which also includes:
c) a land ownership certificate;
d) a neighbour notification certificate;
e) notice to owners/ tenants of agricultural holdings;
f) notice to neighbours; and
g) notes for guidance.
8. The PAN does not cover the very specialised requirements of mineral application forms, applications to display advertisements, or forms for listed building or hazardous substances consent. Nevertheless, the same general principles would also apply in relation to these subject areas.
9. General good practice advice on authorities' development control responsibilities can be found in Planning Advice Note 40: Development Control.
10. The planning application form and accompanying documents must describe the proposed development. The application needs to comply with Part 2 of the Town and Country Planning (General Development Procedure)(Scotland) Order 1992, and, in most cases, this should provide sufficient information for the planning authority to make a decision. However, the planning authority may direct the applicant to provide further information after the application has been received. Some planning authorities appear to seek information which is not necessary to determine the application. In devising an application form, only questions essential to the consideration of a development proposal should be included.
11. Householder applications are usually submitted by individuals with little experience of the planning system and generally do not raise policy issues of major significance. Many planning authorities have prepared a separate form specifically for householder applications which is simpler in terms of the information sought. It is recommended that all planning authorities should consider preparing a separate householder form.
12. The general planning application form should seek more detailed information and cover most other types of planning application.
13. Some authorities have combined the planning application form with that for listed building consent but some works which require listed building consent do not always need planning permission. A combined form may tend to confuse applicants unfamiliar with the planning system and who may not appreciate that the planning authority must give separate decisions on the application for planning permission and on the application for listed building consent. As a minimum, the form should make it clear to the applicant its dual purpose.
14. The best practice examples provide the application questions and the certificates in one form. This allows for one signature to suffice for the application form and certificates, and helps reduce confusion incurred by having to complete numerous forms.
15. Some authorities use coloured paper or corner flashes to distinguish between forms and/or certificates. The greatest degree of clarity in presentation was found to be through simple white forms using black print. For highlighting, white print on a dark or toned background can be effective but care should be taken not to "overkill" on black. The use of screen tints, such as 70% black should be considered. This is particularly effective for the purposes of photocopying the form. The sample forms use this style of presentation. Whatever presentational style is adopted, it is important to maintain consistency of presentation. It is also helpful to include all relevant forms and certificates in one package.
16. There are a number of other presentational points which can help readability and user understanding:
- use plain English;
- ensure a clear distinction between questions and instructions;
- use an uncomplicated numbering system for questions;
- avoid long lines of type, particularly in capital letters;
- clearly distinguish between headings/ titles, questions and instructions/references. Consider the use of block capitals, lower case, emboldening and italics; and
- avoid the use of small type (do not go below point size 9).
the application form
17. All application forms should comprise the following:-
- panel (for Official Use Only);
- instructions for completing the form; and
- space for answers.
18. Most planning application forms bear the name of the authority, their logo or coat of arms, an indication of its purpose and its statutory basis. However, for those authorities whose forms do not carry these features, there is scope for improvement by incorporating them into the heading.
19. The "For Official Use Only" panel usually appears towards the top right hand corner of forms but in some instances, is not clearly separate from the rest of the form. The items contained within the panel vary between authorities but there appears to be growing trend towards incorporating lengthy panels down the right hand side of the form, which serve as a computer input. While it is recognised that computer input is becoming increasingly important, in some cases this panel tends to impair readability and can cause confusion for applicants. It is therefore recommended that a separate computer input sheet is used on receipt of the application and that the panel is limited to contain a reference number and registration date. The aim should be to present a tidy, uncluttered form.
Instructions On Completing The Form
20. Some forms have instructions mixed up with headings or questions. This tends to distract, rather than focus, the applicantís attention. Many authorities have adopted a clear distinction between general background information on making a planning application, which are contained in separate Notes for Guidance, and minor instructions associated with questions on the form. This approach is recommended.
21. It is also recommended that a single, highly visible instruction referring the applicants to the "Notes for Guidance", should immediately precede the questions on the form. Minor instructions on the form, relating to individual questions, should be in a distinctive type face and may be of three sorts:
- those referring the applicant to "Notes for Guidance";
- those specifying how the question should be answered eg "USE BLOCK CAPITALS", "tick one box"; or
- those indicating a choice of action eg " if you answered "Yes" to question 5, do not answer question 6, but go straight to question 7".
Space For Answers
22. The space for answers on forms varies from free space, to lined space, to boxes for ticking. One method which should be avoided is the "YES/NO" option where the correct answer could be ticked or the incorrect answer deleted; this can be confusing. Ticking marked boxes is an easier and clearer option, and reduces the volume of information which the applicant has to write. The instructions must clearly state whether one or more boxes should be ticked.
23. Where written answers are requested, it is important to make sure that sufficient space is given for the reply.
householder application form
24. Householder applications form a significant proportion (approximately 40%) of all planning applications. A lengthy application form can seem rather daunting to most householders who have usually had little or no experience of the planning system. The major objective for the householder form is to limit the information to what is required by the planning authority to reach a sound decision; a single side of questions plus certificates should be sufficient, set out in such a way that the form can be completed with ease. While these principles apply to all planning application forms, they are particularly important in the case of householder applications.
general application form
25. Given the range and diversity of development proposals, it is difficult to design a general planning application form which covers every situation and satisfies the interests of all consultees. Despite this, authorities should not attempt to design their forms in the hope that all the details of every development will be covered: this would lead to a very unwieldy form which would almost certainly confuse potential applicants. Many authorities devote large amounts of space on the form to obtaining information on residential, commercial and industrial developments. The best practice form, found in the annex, demonstrates how this can be kept to a minimum.
26. Authorities should think about what information is essential in determining a planning application and try to keep this to a minimum. In more complex or unusual applications, planning authorities should seek to obtain a supporting statement from the applicant: many applicants already provide this as normal practice. In addition, authorities should stress the value of pre-application discussions.
Notification to owners or agricultural tenants and neighbour notification
27. Applicants are required by statute to notify neighbours, other owners and any agricultural tenants that they are applying for planning permission. They must include certificates stating that they have complied with those requirements with their planning application.
28. The content of these certificates is set out in Articles 8 and 9 of the Town and Country Planning (General Development Procedure)(Scotland) Order 1992 (as amended). A number of planning authorities have put the wording of the Order into plain English for their certificates. This approach is recommended but authorities must ensure that the revised wording has exactly the same meaning as the legislation intended. Certificates should be presented in the same style as the planning application form.
29. Some authorities provide the applicant with the notice which must be served on owners, tenants of agricultural holdings, or neighbours as appropriate. The applicant completes the notice by filling in the relevant details. It is recommended that planning authorities adopt this practice, but they should avoid using their name or logo as a heading as this gives the impression that it is the authority which is serving notice. A best practice example of each of these notices can be found in the Annex. The reverse side of the notice provides guidance to the recipient on what action they should take following the service of such notices. This is seen to be of great benefit in helping third parties to understand their rights in the planning process.
planning application fees
30. Most planning applications must be accompanied by a planning application fee, without which the application cannot be validated. The fee payable is dependent on the type and scale of the proposed development and is governed by the Town & Country Planning (Fees for Applications and Deemed Applications)(Scotland) Regulations 1990 (as amended). Since the fee scales vary from time to time, it is advisable not to print specific fees applicable on the form.
guidance for applicants
31. Many authorities have compiled Planning Handbooks which deal with the process of plan making and development control. While this is useful, planning authorities should also prepare guidance notes specifically focused on completing the application form and certificates. It is important that the notes for guidance relate easily to the application questions and certificates. Some authorities have incorporated notes for guidance as a folder for the whole application package, ie the application form, land ownership and neighbour notification certificates, and the notice to owners and neighbours. This approach is recommended and the best practice forms follow this example.
32. Authorities may wish to provide further information such as how long a decision is likely to take, or, how to appeal against a decision to refuse consent or a failure to determine the application within the statutory period. The aim should be to improve the level of information and guidance available to the applicant. Such information has been incorporated in the application form, in the case of the Householder example, and in the Notes for Guidance accompanying the general planning application form, in the annex. Guidance notes could also be incorporated into the notices to neighbours, owners, and tenants of agricultural holdings, as demonstrated in the annex. This would inform the relevant party of how to make representations as well as improve their general awareness and understanding of the planning system.
33. Obtaining planning permission can be a complicated process, particularly for those who have had little experience with the planning system. This Planning Advice Note is intended to provide the stimulus for planning authorities to improve the content and layout of their planning application forms, which should help create:
- a user-friendly, simplified, planning application form;
- a planning system which is more accessible and easier to use;
- a reduction in the delays arising from incomplete applications; and
- improvements in the efficiency and effectiveness of the development control system.
34. Enquiries about the content of this advice note should be addressed to
Roger Kelly, Tel: 0131 244 7526.
Further copies and a list of SPPs; NPPGs and PANs may be obtained from
John Stuksis, Tel: 0131 244 7543
Planning Application Form: Notes for Guidance
Before completing this form it is advisable to discuss your proposal with the Planning Department
Householder Planning Application Form: Notes for Guidance
Before completing this form it is advisable to discuss your proposal with the Planning Department as you may not require planning permision
This form should be used for applications for extensions to single dwelling flats/houses; domestic garages; driveways/access; boundary fences/walls; satellite antennae; replacement windows; but excluding erection of new houses.