Too much information?
5 February 2010
There has been a significant increase in the supporting information required by planning authorities, with a corresponding increase in costs. RICS supported research into the implications, as Stephen Brown reports
The process in England and Wales by which house builders seek planning permission for new housing development involves them providing local authorities with a significant amount of supporting information, which represents a cost to the house builder. With funding from the RICS Education Trust, Phil Allmendinger of the University of Cambridge has explored the trends in the amount and nature of information that is required, using Cambridge as the case study area.
Concern has been mounting recently over the increase in the amount of information required and, while the Barker and Killian-Pretty reviews highlighted many issues, the actual costs and impacts of this increase remain largely unknown. This research has tried to estimate the changing requirements, their costs, the reasons for the increase in information required and the implications.
The increase in supporting information required from 2005 onwards related mainly to environmental matters, including sustainability statements and biodiversity checklists
By sampling planning applications over the period 1997-2007, the research identified how requirements had changed. Then, using two hypothetical sites, a panel of consultants estimated the costs of supplying the required supporting information at 2009 prices, providing a further, updated estimate of changing costs. Interviews with key actors in local planning authorities and the private sector then explored a range of issues around the use of such information and the wider implications for planning and development.
The research results highlight a significant increase in information requirements for planning applications during the sample period. While estimates of the increase are complicated by the merging of some requirements, the extra information required since 2005 relates mainly to environmental matters, including sustainability statements and biodiversity checklists.
The costs of providing such information have also increased significantly, particularly since 2005. The research estimates that a non-sensitive development of 20 dwellings within development limits would incur average supporting information costs of £93,000. For more sensitive sites, the cost would be £122,500. If the costs of commissioning and collating such requirements are added, the figures rise to £140,000 and £180,750 respectively, representing between £4,650 and £9,000 per house built (with all estimates at 2009 prices).
Few could point to specific examples of supporting information leading to an improvement in a scheme other than at a general level
By delving deeper, the research found that the most significant cause of this growth in information requirements was the increasing complexity of the objectives of planning, particularly around the notion of sustainable development, and the need for an applicant to demonstrate that a proposal met multiple, sometimes competing, requirements.
There were conflicting views on the use of such information. While some argued that the information added value to developments, others claimed that its main value was to ensure that local authorities would not be subject to successful judicial reviews.
Other than increasing the cost of securing planning permission, the main impact of the more demanding information requirements was upon market entry. Smaller developers and builders were less likely to be able to compete, due to high upfront costs.
Findings
Have information requirements increased?
It will come as no surprise to anyone involved in development and planning that there was a significant increase in required supporting information over the period 1997-2007. Figure 1 shows the growth in information requirements for the sites analysed. The high number of documents in 2002 is related to two particularly sensitive sites that required specific information.
Figure 1. Note: excludes planning statements
From 2005 onwards, additional information related mainly to environmental matters. Since 2006, 'design and access statements' have been a national requirement, largely replacing what were sometimes termed 'supporting statements' or 'planning statements'.
How have costs changed?
The costs of supplying the required supporting information have also increased. Based on the figures provided by consultants for this study, an estimate of the costs for non-sensitive and sensitive sites can be made based on the supporting information requirements from the sample (Figures 2 and 3).
Figure 2. Note: Supporting documentation costs at 2009 prices
Figure 3. Note: Supporting documentation costs at 2009 prices. Assumes all aspects of supporting information as sensitive
The costs in Figures 2 and 3 were derived as follows: for non-sensitive sites, the supporting information submitted with the application was noted and then an estimated cost allocated to it from the information provided by consultants. For the sensitive sites, it was assumed that each element of the supporting information addressed a sensitive element of the development - e.g. a full archaeological appraisal might be required, rather than simply a desk-based assessment. In other words, the costs in Figure 3 are for a worst-case scenario.
It must be borne in mind that the costs in Figures 2 and 3 are for supporting information and not for other costs involved in submitting an application. Fees for completing the application forms, obtaining ownership certificates, co-ordinating the production of the application drawings and illustrative layouts, etc, are all additional to the supporting information costs. If an additional 50% is added for management, the estimated cost of supporting information requirements rises to around £140,000 in 2007 for non-sensitive sites and £183,750 for sensitive sites (£294,000 for 2006). Management costs for sensitive sites are also likely to be higher given the increased complexity of the information required.
What has driven the increase?
The participants in the research pointed to four possible drivers of the increase in required supporting information:
- The growth in the complexity of planning objectives has widened the scope of considerations against which proposals are assessed. Some of the objectives are vague and are largely determined at local level within national and regional guidance (e.g. sustainable development), while others are technical in nature (e.g. retail assessments).
- The introduction of the national and local lists of information requirements from 2005 onwards helped to introduce some consistency between authorities, which had previously taken very varied approaches. A common view among those interviewed was that authorities took the nationally suggested local lists and simply adopted them wholesale. One consequence of this was that, in some cases, supporting information was required to 'tick the box', rather than because it reflected the needs of the application.
- Those in local authorities pointed to a watershed around 2004-2005 when the UK government issued a wide range of new national policy guidance, including new objectives for planning around the notions of sustainable communities and sustainable development. These changes call for a range of new assessments and information.
- There is an assumption that supporting information requirements are largely demand driven - in other words, that local planning authorities require the information. The other view, which found some support in the Killian-Pretty Review, is that consultancies and those charged with acting for applicants have an incentive to produce supporting information in order to increase fees.
How has the information been used?
Discussions with agents and local authorities elicited two distinct views on this issue. On one hand, there was some consensus that elements of supporting information did help to create better developments. Having a structured approach to assessing the evolution of a scheme via design and access statements was broadly felt to be positive. However, some elements of supporting information were felt to be formulaic and lacking in relevance. This caused some resentment among applicants and agents. There was a strong feeling that the current approach needed to be more proportionate to the scheme. Questions also arose over the duplication of information between the plan and permission stages.
The other view was that supporting information was used by risk-averse authorities attempting to avoid judicial reviews. Used this way, supporting information had little or no value other than to provide evidence that a particular issue had been assessed.
Have processes or developments improved?
The general view was that supporting information, if used correctly, did improve proposals, though other factors, such as pre-application discussions and flexible local authorities, were just as important to 'good development' and the delivery of a scheme. Few could point to specific examples of supporting information leading to an improvement in a scheme other than at a general level. There was an acceptance among local authorities that some of the information did not lead to any improvements and simply noted the existence of certain conditions or issues.
What is the impact?
Apart from adding to the cost of applications and providing some general improvements to development, supporting information was perceived as having little impact on the development process. However, one issue emerged concerning 'market entry'. While the introduction of national and local lists had provided some certainty about the information required in support of an application, by increasing upfront costs, the new requirements had made it more difficult for smaller developers and builders to compete. This, in turn, favoured those with resources and/or know-how.
Implications
There has been an understandable attempt by government to use the planning system to achieve wider aims related to such issues as climate change and social inclusion. In the process, however, the objectives of planning have become diffuse and complex.
At the same time, there has been increasing development pressure and severe shortages of planning staff at a time of major legislative change. While the increase in supporting information requirements may be an understandable consequence, the implications are serious. First, the complexity of planning objectives, and their vagueness, has made delivery and the achievement of objectives less, not more, likely. Second, it has raised expectations about what can be achieved through development and planning. The danger is that planning becomes overly focused on process, instead of outcome.
Further information |
 The full report, Transaction costs, building and housing supply, can be downloaded from www.rics.org/research |
 See also Pre-application preparation and validation in isurv planning. |
Related competencies include: Stephen Brown is Head of Research at RICS, Phil Allmendinger is Professor of Land Economy at the University of Cambridge
