Our latest Spotlight is a guest post from Rachel Hearn, Design Principal at London Legacy Development Corporation. Drawing on research carried out for Public Practice during a year-long placement in LB Havering, Rachel reflects on the role pre-apps can play in securing good design, the challenges local authorities and applicants face when it comes to pre-apps, and how pre-app services could be improved.
What are the challenges to delivering pre-app services?
Although pre-application (pre-app) is a fundamental part of the planning process, there isn’t a standard approach to pre-apps. The service and fees vary dramatically across boroughs, leaving many applicants, officers and communities frustrated with the process. Nor is there much guidance on using pre-app to secure design quality.
The new National Planning Policy Framework and draft London Plan place increasing importance on achieving design quality through tools such as design review. However, design review is unlikely to achieve universal design quality alone, given its costs, limited coverage and external nature.
A design-led approach also needs to be integrated into the planning process, particularly at pre-app stage where many of the most fundamental aspects of design are shaped. But delivering good pre-app services can be challenging for local authorities, which can then limit their ability to secure good design outcomes.
Planning officers have heavy workloads and are under pressure to process applications quickly, which affects their capacity for scrutinising applications, negotiating with stakeholders or implementing new ways of working. High staff turnover makes it unlikely that applicants will deal with the same planning officer from pre-app through to application, and the advice they get from different officers is often inconsistent.
Confidentiality rules have led to a lack of transparency in the pre-app service, which risks generating a lack of trust between stakeholders. And the perceived lack of specialist skills within some boroughs, such as design expertise or commercial awareness, also increases uncertainty or risk for applicants.
Why should local authorities improve their pre-app services?
Despite these challenges, there are several ways in which local authorities can benefit if they improve their pre-app planning services. Faced with further government funding cuts, pre-apps is one area where local authorities can set their own fees and thus generate income. And a well-run pre-app process makes life more enjoyable for officers, which might improve staff retention – a key challenge for many local authorities.
With regards to design, placing more emphasis on design quality through pre-apps will boost in-house design expertise. Given that 72% of London’s boroughs are once again directly engaged in delivering their own homes, they now have an added incentive to ensure design quality.
How do pre-app services vary across London?
One of the issues that applicants face is that there’s significant variation in the service and costs of the pre-app across local authorities in London – and across the different stages of the pre-app process.
When applicants make initial contact with a local authority, the costs vary wildly between boroughs for seemingly the ‘same’ pre-app. For example, the cost of a first meeting on a 50-unit new build pre-app (which isn’t in a conservation area) ranges from £2,400 to £14,853. For the same meeting on a 150-unit scheme, there’s a difference of over £15,000 between the cheapest local authority and the most expensive.
The application process
When it comes to the application process itself, in over 75% of local authorities there’s no indication from their website of how long it will take from submitting an application to getting the first meeting. And of the local authorities which indicate how long it’ll take them to write a response after that first meeting, the shortest is five working days and the longest is 40 working days.
Although around 50% of boroughs have access to 3D modelling software like VU.CITY, the majority of them don’t have clearly defined ways of working with it. Only three keep mapped and/or geotagged records of the pre-app advice they’ve given.
The average number of major pre-apps local authorities processed between January 2016 and December 2017 was 40; but the minimum was 13 and the maximum was 87. A third of boroughs didn’t actually know how many major pre-apps they processed last year, and the majority of boroughs cannot easily tell if they have a 100% capture rate; i.e. whether or not all major applications started life as major pre-apps.
What can local authorities do to improve their pre-app services?
In response to these findings, Public Practice have created a Pre-Application Checklist. This provides guidance for integrating a design-led approach into the different stages of the pre-app service: before a pre-app process is received; during the pre-app process; and after the pre-app process has concluded. The Checklist and other resources including Pre-Application Information Benchmarking can be downloaded here.
The main recommendations in the Checklist are:
- Communicate clearly with applicants and communities. Set out the benefits and timescales of your pre-app service upfront, and explain how it works from the perspective of your stakeholders.
- Use new technologies intelligently. Consider integrating digital tools, such as 3D modelling or geo-tagged records, into your pre-app service to support officers.
- Record and review the pre-app service continuously.
- Track the pipeline of major pre-apps you process, and develop a feedback mechanism to help improve your service.
More research is needed to find out what kinds of additional training planning officers working with pre-app need, and to develop digital tools specifically to support the pre-app process – such as a user-centred pre-app interface, or internal project management and tracking. But as more local authorities improve their pre-app service, it will be possible to gather more evidence and put together a collection of case studies.