Thursday, 15 November 2012
The False Economy Of Scrapping Pre-Apps
It is not uncommon now, indeed it is perhaps more common than not, for LPAs to charge for pre-planning application discussions (pre-apps). The justification being, perfectly legitimate, that pre-apps divert valuable officer time from the determination of planning applications and that that time needs to be compensated for.
For the first time recently though I have heard that one Greater Manchester authority has actually scrapped pre-apps altogether, forbidding officers to engage in discussions about any site that is not the subject of an application. Whilst this authority has seen it's number of officers dwindle and no doubt views this approach as making best use of it's resources, I cannot help but wonder whether this does actually represent a false economy.
There are perhaps two implications of a LPA not engaging with prospective developers or promoters at the pre-application stage. Firstly, developers or promoters that are risk-averse (and they are certainly more common than not) may err on the side of caution if critical policy information (planning gain contributions, for example) cannot be gathered or if, more fundamentally, the reluctance on the part of the LPA is interpreted as a sign that the LPA is resistant to development. The risk of this is that that developer or promoter invests their time and money in another opportunity in another borough.
If the developer or promoter does though seek to bring a scheme forward without a framework for pre-application discussions then the only avenue available to engage with the LPA is to put an application in.
The same principles, of course, apply as much to householder development as they do to commercial development.
A planning application that has not been the subject of constructive pre-apps is extremely likely to raise issues that cannot be determined within the target date and then, as a result, it is extremely likely that a LPA will invite the applicant to withdraw that application for fear of it going beyond it's target date.
I would suggest that were such a scenario to be the result of a deliberate attempt to save time by abandoning pre-apps then that would represent a false economy because a proposal that could have been dealt with by a single planning application will end up being dealt with by two.