GIA RESPONSE TO PLANNING CONSULTATION
Ambitions for the Planning System
In September 2023 Craig McLaren,
Scotland’s first National Planning Improvement Champion, called for ideas
on what a high-performing planning system looks like and what impact it has.
Response from The Glasgow Institute of Architects. 28th November 2023
1. What are the outcomes we need the Planning system to deliver to have impact?
A responsive service, where the determination takes 2 months, or a very short extended
period beyond that (3 months maximum), so that applicants have certainty on project
programming.
Planning Officers able to accept and return phone calls timeously, so there can be
meaningful conversations to short-circuit protracted email trails.
Responsiveness to email enquiries rather than these simply generating an out-of-office
response, and an untimely response many days later.
Where consultation responses are not received, the assumption should be that the consultee
has no objection and the determination should proceed on that basis, rather than waiting
weeks for slow consultees to respond.
Planners and committee members to understand the financial imperatives of applicants.
Delays result in investment being cancelled, which is not good for the local economy.
Avoid pre-commencement conditions, as these only delay development and are in many
instances simply unnecessary.
Remove payments for submitting applications for discharge of conditions, as this has not
improved responsiveness.
Set clear deadlines on Planning approving applications for discharge of conditions (2 weeks
would be appropriate). If no response within 6 weeks then a deemed approval.
Consistency in all aspects of the Planning Process across Local Authorities including the
pre-application process & fees, methodology for discharging conditions and means of
communication.
2. What makes a high performing Planning Authority?
An Authority which understands the importance of development.
An Authority which has Officers who can take phone calls and discuss applications
meaningfully with a view to timeous determination.
An Authority which avoids irrelevant conditions (e.g. Inverclyde Council only apply conditions
where these are absolutely relevant, rather than the scattergun lists which many other
Authorities impose) which reflects that Council’s understanding of the need to reduce
unnecessary bureaucracy and delay.
An Authority which responds to a pre-application request within 2-3 weeks, rather than this
being treated as having no importance despite a pre-app fee having been paid by the
applicant.
Primarily an Authority which starts from the premise that development should be approved,
unless there are particular reasons why an application is inappropriate.
Planning Officers who are driven and recognise the need to positively engage with the
process, working in cooperation with the applicant.
An Authority that is flexible and able to deal with peaks in demand across each area. For
example, wind farm applications can take up too much resource leading to localised
backlogs.
Clear and swift advice, particularly in the early stages when the principles of development
are being considered. An improved pre-app process would assist, with a dedicated team.
3. How can we measure this?
A live feed showing the date applications were submitted via ePlanning, the date they were
eventually registered, the date for determination, the extent to which that has been
exceeded, and the actual determination date and decision.
A summary of the number of Conditions imposed on each Consent, and whether these
relate to relevant matters such as flood risk, contamination and invasive species, or whether
they are spurious matters such as final selection of external finishes.
An overall snapshot of each Local Authority every quarter to help identify where issues and
backlogs are, to allow resources to be allocated appropriately.
Feedback reporting on abandoned projects where the Planning timescales have taken so
long that the project is no longer viable, and quantifying the subsequent loss of investment
so that Local Authorities and Government understand the implications for the local area and
the nation.
R Jonathan Potter
President
The Glasgow Institute of Architects
A chapter of the Royal Incorporation of Architects in Scotland
The Improvement Champion summarized their findings here in Feburary 2024.