After a bit of a scramble, and with some help from our friends, we published our work and thoughts on local planning fees last week. By and large I’m very pleased with it, and it seems to have done its job working alongside the more political lobbying position of the LGA. As is the way, everyone’s thoughts now turn to what next ? Given that October isn’t really that far away, what practical things should we begin now to prepare for locally set fees ?
I have detected a very strong sense that people can hardly wait. It really is the case that corporate subsidy is drastically reduced and without the ability to increase revenues more people will be laid off. The impact on quality of service will be horrific and especially galling for those of us who can remember ‘standards’ authorities and backlogs of normal, straightforward, applications. But what, given that we don’t know what the result of the consultation will be, is worth doing at this stage ? I reckon there are two things:
1. Engaging leadership
I reckon the result of the consultation will be some new freedoms. Take, for example, the free go. It feels unlikely that the new regs will entirely abolish the principle of free go, but might instead say it is for the LPA to decide whether or not to offer one.
Well, what does your place want to do ? For many places these decisions will be straightforward: “Our position is that everything that can be recovered from applicants should be.“. For others, it may be more nuanced: “For applications in regeneration areas we will minimise, where possible, the costs of the process including offering a free go.“.
These are not decisions for planners in isolation. Why not start with the ‘principles’ section in our paper and use them to understand how your own authority wants to proceed. All these decisions will have cost & budget implications, and you may have to iterate round these things several times.
2. Thinking through the practicals
I’ve heard some strange things about the consultation requirements for local fee setting. I think CLG have said that they believe a 6-week consultation is appropriate. Assuming that the principles of cost recovery are clear and articulated locally – what is there left to consult on ? Suppose you publish your schedule which says the charge for application type X is £100. You might get a response that says this is too much – it should be £80. It can’t be. The costs are the costs*.
Consultation is an unhelpful word. We’re actually talking about notification. What you need to organise is who, how and when these sorts of decisions are made in your place. It may well be worth you investigating a change to your scheme of delegation, allowing your department to set fees in consultation with your portfolio holder if certain conditions are met. Don’t try and organise this in July. Do it now. Use building control (or land charges) as a model.
What not to do
At this stage, if you’re not already thinking through the results of your benchmark I wouldn’t bother trying to capture costs. There are too many unknowns, and it would be irritating to go through 100% of the work but not capture costs in a way that allowed you to model the rechargable component. But it is worth thinking through the diaries – and for what it’s worth we’ve earmarked two 4-week blocks:-
7th February – a slightly optimistic “early adopters” session that relies on getting an early peek at the new regs
9th May (the week after the royal wedding 4-day bender) – a high volume national benchmark to capture and model costs / fees
Then, as discussed above, you need to set out a mini project plan to get you to through your local democratic process to a public fee schedule before october. The alternative – processing applications for free – don’t bear thinking about…
* Yes of course there will be downward pressure on costs. But this will not be brought about by local consultation, but by peer benchmarking.