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5.2.2: Development Management Efficiency
Local Authorities
Aberdeen City Council: The planning hierarchy establishes a fundamentally different system of development control. A significant change, which reflects the necessary change in culture, is that development control will be referred to as development management. This is welcomed and is consistent with the Council's own approach in renaming development control as development standards.
Aberdeenshire Council: We generally welcome the changes that are proposed within the development management system, particularly the proposals for improved delegation, but with increased transparency and accountability and the appropriate checks and balances
Dundee City Council: In relation to development control, the White Paper proposes a new approach in which the underlying objective should be to promote sustainable and high quality new development and to manage the process with this in mind. In other words to foster the right development in the right places - development "management" rather than development "control". Dundee City Council has a track record of adopting precisely this positive and pro-active approach and therefore the general thrust of the White Paper is to be welcomed.
Fife Council: Agree to the change in emphasis from control to management which is all about a change in culture and operational style. These changes have already commenced in Fife with the recent change from Development Control to Development Promotion & Design.
Glasgow City Council: It should be noted that many of the new proposals, e.g. creating local review boards and direct neighbour notification of new proposals and application decisions, could involve substantial additional costs, which is unlikely to be fully absorbed by a fee increase and which would be difficult to quantify with any accuracy at this early stage. There should be an increase in application fees to cover the additional costs incurred by local authorities if neighbour notification procedures are transferred from the applicant to planning authorities. It is not known to what extent any increase in fees would help offset actual costs of delivering the development management service, given the scale and nature of the proposed additional responsibilities.
West Dunbartonshire Council: The change in name from Development Control to Development Management is seen as a positive move, similar to the change from Building Control to Building Standards. Public perception of the planning application process tends to be negative even although by far the majority of planning applications are granted. Development Control should be seen more as an enabling process and this change in name should help. The proposals on development management are relatively minor but all should contribute towards making the system work better, in particular clarifying to applicants, the objectors and appellants the constraints of the system.
Non Departmental Public Bodies
Defence Estates: Defence Estates is keen to reserve its position on the reduction of the appeal time period to three months and the reduction in the duration period of planning permissions from 5 years to 3 years. Post application development issues can often span lengthy time periods. Defence Estates is not convinced that reducing these timescales will have a net overall benefit to the drive toward efficiency so clearly promoted in the White Paper. Instead, Defence Estates believes efficiencies should focus on the 'front end' of the planning process prior to decision making, rather than changing the longer time period on these matters which is available post decision making.
Scottish Enterprise: Hopes that the declared move from development control to development management will allow for a planning system that is more supportive of the needs of economic development and the achievement of the aspirations of a 'Smart Successful Scotland'.
Scottish Enterprise Edinburgh and Lothian: The use of the term "Development Management" rather than "Development Control" is supported, particularly because it is important that the new approach to planning should have the underlying objective of promoting sustainable and high quality new development.
Scottish Environment Protection Agency: The proposals would appear to represent practical steps which may ease and speed up the process.
Scottish Water: Especially welcomes the proposals to improve the efficiency of the development control function and the shift to enforcement management for the small change/impact issues surrounding development control that can create unnecessary bureaucracy, uncertainty and delay. Wish to see new arrangements for the validation of planning applications as this is an area where there is much variation in performance between Councils.
Sportscotland: We would support an increase in the consultation period on planning applications for statutory consultees from 14 to 21 days, as already practiced by some councils. This would allow more time for submission of a considered response and obviate the need for frequent use of holding objections pending the receipt of further information.
Development Industry
James Barr Ltd (on behalf of various development industry businesses): The driving factor behind the majority of the proposed changes appears to be the Scottish Executive's fixation with ensuring increased community involvement in the process without full and proper regard for other users of the system.
The Buchanan Partnership: The Buchanan Partnership believes efficiencies should focus on the 'front end' of the planning process prior to decision making, rather than changing the longer time period which is available post decision making (for appeal and in relation to the duration of planning permission).
Walker Group (Scotland) Ltd: "The primary role of planning should not be to stop development happening - it should be to foster the right development in the right places." This sentiment is supported by the Walker Group. However, we would take issue with some of the measures which are suggested in order to bring about efficiency.
Other Businesses
Anonymous: Strongly endorses the consultation response submitted by the Scottish Renewables Forum ( SRF). In particular, echoes the SRF's concern surrounding the requirement for additional resources to be made available to allow timely planning decisions, whether through Local Planning Authorities or the Appeals system. Delays attributable to the planning system are, and could continue to, adversely affect the delivery of key Scottish targets in respect of renewable energy and the environment. For example, every month that a 50 MW wind farm project is delayed leads to: 9,425 tonnes of carbon dioxide emissions; and therefore £192,750 "climate change damage costs". Respondent looks forward to working under an improved and better resourced planning system in Scotland in the future, allowing the renewable energy sector to deliver its full potential in respect of environmental, industrial and socio-economic benefits.
CBI Scotland: There are a number of very welcome proposals in this area but we have concerns about the proposal to reduce the duration of planning consents from 5 years to 3 years and the plan to reduce the time allowed for appeals from 6 months to 3 months. Three years sounds like a long time, but the experiences of many of our members has highlighted just how much time it can take to negotiate and clear planning conditions and agreements. With regard to the time allowed for appeals, the reduction planned may produce the opposite effect than intended and could lead to a logjam as applicants may lodge on appeal as a matter of course to protect their position. It is our understanding that this is what happened in England and Wales. On the wider issue of planning agreements and obligations, we are pleased that the framework governing such agreements will be improved. 'Planning Gain' has reached unprecedented levels and there is a strong case for a major 'reform', not just 'refinement'.
Edinburgh Chamber of Commerce: The suggestion for increasing planning fees is noted, along with the justification that this will be to aid speeding up the planning process. Most developers would accept this suggestion. What guarantee will there be that increased fees will in fact deliver faster applications? What come back will there be for applicants if local authority planning departments do not deliver quicker? What guarantees of service quality/speed will there be in general?
Institute of Directors: The potential substantial rise in fees is a major worry and would be most unwelcome - again a disincentive to invest in Scotland.
Orange PCS Ltd: We welcome proposals to increase the efficiency of the planning system. Our business requires a large number of applications to be submitted and these need to be dealt with speedily if consumer demands and expectations are to be met.
Scottish Financial Enterprise ( SFE): Welcomes the new emphasis on development management rather than development control - providing that a genuine change in approach and measurable improvements are achieved.
Scottish Power: We would recommend that some form of Performance Management would have a place in the proposed Development Management system The main principle behind the proposed reform is to make the system more efficient. However, we have concerns that the reform may not achieve the desired end result of incentivising the consenting authority ( CA). What will incentivise the CA to 'expedite' decisions? Fees are proposed to increase, but will the additional funds be used to incentivise fast decisions? Perhaps higher fees could be charged for more complex proposals to reflect the additional work in processing? Consideration could also be given to introducing 'Standards of Performance' where penalties would be associated with failure to meet timely progress. We support the principle of standardisation in specific elements of the Development Management system. We welcome the proposal to standardise policy models and planning agreements where possible. Perhaps consideration should also be given to standardising committee cycles?
Wm Morrison Supermarkets PLC: Welcomes proposals to improve efficiency in the planning process, including the proposed rationalisation of the framework for governing planning agreements and allowing applicants to submit unilateral obligations. More consultation is also required to define the scope of planning agreements and when these are applied in practice.
Professional Organisations
Institute of Civil Engineers Scotland: The various efficiency proposals on e-planning; standard application forms; determination of notification of applications, improvements to the Planning Agreement framework and new power to decline applications are welcomed
RTPI Scotland: We support the use of the term " development management", which was promoted by the Institute in its manifesto for the UK election earlier this year
Planning Consultants, Architects and Lawyers
Collar, Neil: The changes to the development plan process promise significant efficiency gains; the changes to the development management system are disappointing in comparison. The use of e-planning and standard application forms is welcome, but not a significant gain. How does reducing the time limit for appeals, giving local authorities the power to decline to determine applications, and amending the duration of planning permissions make the system more efficient?. Overall, the proposals seem to make development management procedures more, rather than less, complicated.
Humberts Leisure Consulting: Reduced period for appeals to 3 months is a concern but changes to speed and improve system welcomed along with balanced approach to encouraging public/interested party involvement.
MBM Planning & Development: Changing terminology such as Development Control to Development Management is a positive step forward and will help to remove the negative image that many planning authorities currently have when it comes to assessing planning applications. The common culture of rejecting proposals unless there are good reasons to approve, needs to be addressed and this change in emphasis will help. However without an up to date development plan system the negative culture is likely to continue.
Academic Bodies and Individuals
Macaulay Land Use Research Institute: The concept of development management is a subtle but crucial switch in vocabulary to describe the planning application and decision process. We wholeheartedly support this change. We also support the primacy of the development plan although we have a fundamental concern that the twin desires to have a quicker process threatens the legitimacy and equity of public involvement strategies.
Community Councils
Fortrose & Rosemarkie Community Council: The Community Council supports the idea that the term Development Management be adopted since its aim will be to foster the right development in the right places. Monitoring of a development by the Community Council is suggested in the White Paper and community representation must also have an input to a development brief. The system should preclude late submissions for inclusion in a development plan once the Consultation Draft plan has been published.
Helensburgh Community Council: We are doubtful about the White Paper's proposal for a change of description from Development Control to Development Management. If this is not just playing with words, it would seem to herald more, not fewer, departures from the LDP. That contradicts the assertion of greater certainty in the LDP. If management is to mean anything, local groups must be involved both in the preparation of the local development plan and in the resolution of planning applications. Development Control is essential in ensuring implementation of the LDP.
Hillhead Community Council: It should be a requirement of the Planning Bill that environmental assessments, transport assessments etc, are made by an independent body. Currently they are too narrow in focus and are carried out by employees of the applicant, often by the engineers who will carry out the development. Conversely, environmental assessments should not be restricted to the large scale developments. They should not be restricted to the natural environment (We can elaborate on this). Amenity within the curtilage of a building should receive more attention. Cumulative change is not addressed. We are pleased to note that this is of importance, but it is often far too narrowly considered. Buildings are considered only in relation to immediate neighbours, if at all. Of particular concern is the limited context of road traffic assessments. These are carried out for the developer rather than the city council, often by the firm employed as contractor. They should be carried out by independent firms and take account of a much wider area if their impact is to be evaluated.
Kennoway Community Council: We support the term "Development Management" and would suggest it become mandatory for Local Authorities to use this term also mandatory that all Authorities operate their Planning System in the same way.
Knightswood North Templar Community Council: Proposals to require authorities to make planning agreements and obligations on the public register are a positive step, however more consideration, we believe, should be given to involving local communities and neighbours in the preparation and negotiation of such agreements. In addition, this community council fully supports proposals to reduce the time period for appeals, reduce the duration of planning permissions, enhance the effectiveness of tree preservation orders and give powers to authorities to decline to determine applications where they have determined more than one similar application in the 2 years previous.
Voluntary Organisations
Avondale Civic Society: The crucial need in any revised planning system is for transparency in the development control process. This will not be achieved simply by rebranding! Councils must be required to implement the policies in their development plans as well as make them comprehensible and relevant. Their performance should be audited.
Brethren Gospel Trusts: We welcome the proposed new terminology and the positive approach to development implied thereby.
Colinton Amenity Association: We strongly support the aim of increased efficiency in the operation of the planning system coupled with better quality of decisions and outcomes on the ground. However, we reiterate that the aims of fairness and balance to all parties in development management will not be seen to be achieved, unless there is an equitable appeal mechanism.
Hensburgh Study Group: Replacement of the term "Development Control" by "Development Management" - we are unconvinced. The White Paper asserts "The primary role of planning should not be to stop development happening - it should be to foster the right development in the right places." Correct, but good planning control does just that. Amending or stopping bad development from happening is also a primary role of planning. Our fear is that the revised wording would be quoted by developers to justify anything. We think it is an unnecessary change of wording.
Quarry Traffic Monitoring Group: Development Control or Development Management? We consider this to be little more than a play on words, perhaps with the intention of giving a softer, more 'user friendly' image to the planning system. A much more radical approach is needed if the confidence of the public to be gained. Our experience is that local views are not taken into account and as a consequence our environment has been seriously compromised. Public confidence in the planning system and its practitioners could not be lower than at the present time.
Rambler's Association: The renaming of "Development Control" to "Development Management" does nothing to improve the system and indeed gives an impression that there are no limits to development and any problems can be "managed" in such a way as to counter objections. The role of the planning authority is to control how proposals are developed, and it is the developers themselves who actually manage developments. We would suggest that the title "Development Control" remains as such.
Rural Scotland: Rural Scotland favours the term development control. Development management is what developers do, not determining authorities. The logic for use of the term 'management' appears confused. It is argued that planning should 'foster the right development' but a broad term such as management hardly reflects that aim. Given that 'management' can be so loosely interpreted and that the planning system will continue to determine whether applications are granted or refused, the known and understood term 'control' remains valid. Irrespective of the term used it is important for planning to achieve quality built environment. Rural Scotland also notes that the Section on Development "Management" gives considerable attention to development that is "not constituting a significant departure from the development plan" and how it may be dealt with. Clear explanation of the nature of the word "significant" is critical as a proposal may or may not go through a particular decision making process depending on a determination of whether something is significant or not. This may mean the difference between a decision being taken by officers or elected members as well as influencing the degree of public involvement in the process.
Scottish Council for National Parks: Anyone who has had contact with the planning system over the years knows what Development Control means. To change it to Development Management will merely confuse the lay public and add not a jot to the quality of the process. It will, however, incur significant costs in a cash strapped service, as Personnel Departments (sorry, Human Resources) rewrite job descriptions, ask everyone to re-apply for their jobs, new notepaper, business cards, compliments slips, etc are printed and reception areas, office doors etc., get new signs. Surely, we are too busy for this kind of window dressing!
Private Individuals
Anonymous: This is a mere word change in the exercise of politically correct descriptions. Political correctness is an out of-date, archaic and negative fad which makes no positive contribution to concise and clear legislation.
Armstrong, Pam: Two issues regarding current development control practice need to be addressed. First, the impact on neighbours of the construction phase of development needs to be properly considered and noise limits attached as a standard condition. Second, there is an issue about the definition of the height of new buildings - this needs to take into account the height of the ground on which such buildings are situated.
Barham, Paul: Many improvements in efficiency could be addressed under the present system, such as the move towards a standard application form. This could apply beyond planning to building control and other areas of development control covered by national legislation.
Hopgood J A & Uprichard P: We consider that 'Development Control' remains a better description of the process of determining applications than 'Development Management'.
Milligan, James: The Development Control divisions of Local Authorities should become Local Plan Implementation agencies, promoting as well as controlling developments in accordance with Local plan proposal.
Wolff, Sula Dr: I like the emphasis on pre-application consultations and on listed building regulations (especially to tighten controls on demolition).
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