In the United Kingdom, 23 March 2020 will now and forever be a day etched on the memory. The Prime Minister announcing that we would be entering a period of lockdown, requiring the closure of all but essential retailers, asking households to stay indoors, preventing non-essential travel and moving millions of the UK workforce into their studies, spare rooms, kitchens, hallways and cupboards under the stairs (in some cases communal ones…) – severely testing home wifi capabilities and video conference etiquette (is muting oneself whilst not speaking rude or simply good practice?!).
Six weeks later and we have just completed our first full month, April 2020, under a way of life that has required resilience, adaptability, patience and cooperation. We have noticed, amongst colleagues, clients and Councils a broad desire to make the very best of exceptionally challenging circumstances. And now, as we move into May, the first glimpses of planning performance are available to review to see just how we are all managing.
In this blog, we have explored the performance of Local Planning Authorities in the South West of England and Wales, as a test case, offering a review of planning determinations, validations and receipts across these two wide ranging regions.
The base line
When we entered lockdown, there was no doubt that all of us faced difficult decisions about how we might continue to work. With some having the resources and strategies in place to cope and adapt quicker than others. For LPAs, strictly administered as they are by legislation and regulations, in all of their public facing processes, the challenge was to navigate their daily business in respect of Development Management processes whilst ensuring transparency, proper consultation and due processes were all adhered to. The response was extremely varied - as Lichfields Business as (un)usual mapping resource demonstrates – but on the whole, LPAs expressed a desire to keep things moving as much as they possibly could.
There were some exceptions to this general rule, particularly in Wales, where the decision was taken in a few LPAs to cease services almost entirely whilst they awaited further guidance from the Government. This guidance has now come and things are moving again in these LPAs, and whilst their performance (i.e. near zero determinations and validations) in this period should not be dismissed, for the purpose of this piece, given that they are the minority and unfairly skew the data, they have been omitted from the general performance results.
Our research took performance on determination, validation and applications received (where this data was easily available from LPA websites) in April 2020 and compared it to averaged data from three months in the 12 months prior as a comparison of performance.
In April 2020 Wiltshire determination rate was up 135% on the previous year.
Whilst there has (quite rightly) been a significant level of interest procedurally in making decisions at planning committee little has been said about the general performance of LPAs in determining applications, often in the many hundreds a month. After all, in many Authorities, decisions made at Committee account for less than 5% of all decisions made (sometimes a little as 1 or 2%). In terms of keeping things going, it is the 95%+ where the real ‘action‘ is!
And here, the results were striking. Across the West of England the 28 LPAs for which data was available, managed to determine an average of 94% of the applications when compared to previous performance. Some clearly using the time where other services might not have been functioning to make real head way.
Despite the lockdown Caerphilly’s validation level was as high as 80% when compared to its previous year average
In Wales, LPA performed similarly well. Discounting the outliers who stopped making decisions during April, the remaining LPAs (15 in total) determined an average of 90% of the applications they usually would.
Despite a great deal of concern in the industry about how LPAs would manage to process decisions – the data suggests it is very much business as usual.
A number of Local Authorities across the UK reported potential issues with validation procedures (See Lichfields Business as (un)unusal). No longer able to accept paper copies and not being able to post site notices/concerns as to whether site notices would be seen (allowing for proper consultation) being two core concerns. It’s possible then that validation levels may take a significant dip.
Whilst the research showed that they were indeed reduced, it was not as significant as it might have been. Welsh Authorities recorded validation levels at an average of 63% of past performance and the South West at an average of 70%.
West Somerset barely missed a beat, with a validation level of 91% when compared to previous performance.
Given the uncertainty and having to move towards a new way of practicing these figures represent a steady response to ensuring new applications continue to enter the system – figures made more impressive when the below is factored in…
Finally, where Authority website allowed, we collected data on applications received/registered. This data demonstrates the most striking returns, with applications received by Authorities falling dramatically (and almost certainly impacting on the number of validations that month).
Torfaen saw a dramatic reduction in application submissions, with the April 2020 level just 32% of last year’s average.
In the South West of England, LPAs received, on average, just 55% of the application they would normally expect to receive and in Wales, that figure was down to 47%.
Anecdotally, One officer I spoke to suggested the biggest fall has been in householder and minor applications – perhaps reflecting the economic uncertainty facing many of us and resulting in small scale projects being put on hold.
The results here, whilst only a high level snap shot, demonstrate a clear and immediate trend. LPAs have, despite concerns, continued to determine applications at a rate almost identical to previous months in the last year. For this they should be applauded. Validation levels are lower, but surely impacted by the significant drop in applications received – perhaps pointing to what is likely to be (and might have been expected) a lag in the true impact of the lockdown on the planning and development industry in respect of the delivery of new planning permissions in the coming months.
All highlighting the importance for applicants to keep on submitting, as initial responses show that LPAs are more than capable of processing them.
 Data, where available, was taken from April 2019, November 2019 and February 2020 and averaged to give a baseline performance level against which April 2020 was compared.