1. Understanding the problem


How many planning submissions do councils receive?


Every year, councils receive thousands of planning submissions. This includes applications for planning permission (the average authority in England receives 1400 of these per year), but it also includes other kinds of submission, such as applications for a Certificate of Lawful Development, Prior Approval requests or submission of details for approval.

So, for example, Lambeth Council receives 2100 applications for planning permission each year, but around 4900 submissions in total. However, data for the number of these other submissions is not collected, so the total number of them nationwide is not known.

How do they receive them?


Currently 90% of planning applications are received indirectly via Planning Portal; which is now a private company. The remaining 10% are received directly by email or post.

On average, each application takes 4-5 hours to validate. Applications are managed through back-office case management tools, with subsequent communications between the applicant and the case officer largely by email or phone. For onward reporting, case officers have to manually enter find and enter data themselves.

How many are invalid?


A significant number of planning applications received are ‘invalid’. This means checking that some required documents are missing, incomplete or incorrectly formatted. Our understanding – based on conversations with 40+ councils – is that typically 50% or more of all applications are ‘invalid’, so the application needs to be resubmitted. In some cases, applications go around this cycle as many as 9 times.

Applicants have to wait 11 days for their application to be validated (in the case of small projects). If an application is invalid, it causes an average delay of 34 days before it is resubmitted. Around 10% are withdrawn entirely.


How much does this cost applicants?


We do not have any precise data for this, however we can make some informed estimates.

If we conservatively estimate that ensuring validity typically costs 1 day of an agent’s labour, at a £400 cost, then for the 447,934 planning applications received in England alone last year, this project could drive savings of around £179m. This will especially benefit homeowners and SMEs.

There are also indirect costs that are impossible to estimate, such as the costs of those 34 day project delays, subsequent disputes and lost opportunity.


How much does this cost planning authorities?


The time to validate, report, return and revalidate submissions varies, but we estimate that validation takes, on average, 5 hours per submission (the Planning Advisory Service benchmark is 4 hours).

Assuming a typical hourly cost of £50 per hour (including overheads), that represents an annual cost of around £350,000 per year for the average planning authority.

Across the whole of England* this represents an annual cost of at least £111m. However, this only includes planning applications. Allowing for all submissions, the actual figure may even be double this.

There are also indirect costs that are hard to estimate, such as the cost of additional failure demand (emails, phone calls etc), the burden of manual data entry work, loss of trust and the additional cost of enforcement due to lack of data on starts and completions. Further general costs might include a high staff churn rate, training costs and the wider effects of reduced user satisfaction and trust.


What are the primary causes of invalidation?


Given the scale and cost of the problem, many people are surprised to learn how mundane and avoidable many of the reasons for invalid applications are. For example, missing a red line or a north point off the location plan, or not paying the correct fee.

The graph below shows a typical breakdown:



Data from Wycombe District Council

Mark

2. Approaches taken so far


Publishing validation checklists, guides and fee calculators on websites


Most councils provide these on their websites. They are reported to make some difference, but very little, since they themselves are often missed, and users are not sure which requirements apply to their project. They also put the burden onto users to be aware-of, find and wade-through even more documents, even though this was part of the problem in the first place.


Machine-learning software that automatically checks documents


For example, Milton Keynes Council have demonstrated the use of image-recognition software to identify and check drawings by type. Other similar approaches might include teaching algorithms to read the contents of reports. This is technically very impressive, and may be useful in some areas, but as a general approach to the whole problem it would be a very complex, laborious and expensive way to solve the problem ‘downstream’ (with limited reliability) instead of intervening upstream to avoid mistakes in the first place.


Web forms with field validation


In the world of digital services the standard approach to solving this problem is to use a web form with ‘field validations’. Almost every digital service we use in our day to day lives uses this approach. The most common example of this might be a text field in a form that is marked with an * , meaning that the field cannot be left blank.

This is hugely effective in that it communicates to the user what is required, and actively prevents the submission of an invalid form. However, most digital services require relatively little information, and the required information is the same for all users (‘one form fits all’).

This is not the case for planning. Planning requires large volumes of information, and what information is required will depend on many factors, such as project size, location and the nature of what is proposed. It is also subject to change from time to time and from local council to local council. Conventional, hard-coded linear forms are too limited in scope to deal with this, a flexible dynamic form structure is required.

The project that has so far advanced the furthest in developing such a service is ‘Submit My Planning Application’, developed by Hackney Council, working with Snook and Hacktar. This project showed extraordinary promise as a step towards the future, not least in being the first to achieve the milestone of allowing users to submit a digital site boundary instead of a site drawing.

Mark

3. Our approach



This project is based on a few key principles:

From documents to data

Instead of asking users to provide information by uploading documents (forms, reports, statements and drawings) that can only be read by humans, wherever possible, planning services should ask for information in the form of structured data that can be read by humans or machines.

Don’t check for mistakes, prevent them

This means that, instead of checking applications for errors after they have been submitted, we can prevent most errors occuring in the first place, before the user hits submit. If an application is not valid, users will not be able to submit it.

Don’t expect users to know what is required

Create a single point-of-access that guides the user through what information is required, based on their previous answers. Don’t expect them to research through multiple other websites and documents.

Only ask for what is required

Use dynamic forms to ensure that users are only asked for information that is relevant to their project, based on their previous answers.

Don’t ask something that is already known

Do not ask the user to tell us something they have already told us before, that planning officers already know, or can be worked out based on the information already provided (for example, the correct fee, or whether the property is in a conservation area).

APIs as a service

Allow the service to be used by third party software applications as well as humans, by receiving data via an API as well as via the main user interface. This will allow others to build complementary software applications on top the service. (Note need for appropriate security measures).

Modular, extendable and updateable

Break down the service pattern into modules, such that it can be edited using ‘low-code’ dynamic form editors, allowing it to be easily understood, maintained, improved and extended by domain experts (eg planning officers, internal consultees, service designers and content designers) without them knowing how to code. Also, separate national, regional and local policies and requirements, where suitable.

Standardise data

Pass on the planning application data as structured data, in such a way that back-office systems can use it, and the data can be passed on to registers automatically, without planners needing to do data entry.




Key design questions for this project:

1. How many planning documents can be replaced with planning data?

2. What are the data schemas that can capture most required information for planning applications?

3. Can we design a service pattern that captures the complex dependencies of required information involved in planning applications?

4. What dynamic form components are needed to cover most types of planning information?

5. How can we ensure that such a long, content-heavy digital service is legible and navigable for users?



Mark

4. Understanding users & stakeholders


This service pattern has to work for two main groups of people. Users (people applying for planning permission through a planning service) and also stakeholders (for example, planning officers, who receive these applications). Only these stakeholders can determine what information is needed to determine a planning application, and therefore whether it really is possible to achieve this transformation from documents to data.

Users



Applicants

People looking to apply for planning permission. This includes professional developers, businesses and private homeowners.

Agents

Professionals working for applicants, such as architects, design and build companies or planning consultants.

Customer service staff

Council helpline or helpdesk staff who may sometimes submit an application on an applicant’s behalf, either by telephone or in person. 



Stakeholders



Planning case officers

Planning professionals working within the planning department, receiving and processing planning enquiries and applications.

Planning consultees

Planning professionals working within the planning department or other areas of government with expertise in a particular area (eg heritage), who will input into the assessment of a planning application.

Managers

Senior managers running planning departments.


Data register maintainers

Teams maintaining and publishing national and local data registers such as GIS spatial policy maps, a National Planning Register, the Local Land Charges Database, the Local Land and Property Gazeteer and the London Development Database

Gov planning agencies

Parts of central government with responsibility for / oversight of planning and development control, such as the Planning Directorate and the Planning Advisory Service



User research


Some excellent discovery-stage user research for planning submissions services was carried out by Snook for Hackney Council, and can be found here.


User stories



As an applicant I want to clearly see what information is required so I can avoid my application being rejected

As an applicant I want to complete the whole process in one place so I can avoid hunting around multiple websites and documents

As an applicant I want to be able to leave and come back to my application so I can complete it over multiple sessions

As an applicant I want to be kept up to date about the progress of my application so I know it is being processed

As an applicant I want to be able to share the application with my agent  so they can do some of the work for me

As an applicant I want to be able to see anything my agent has filled in on my behalf so I can check that it’s correct

As an applicant I want to spend the least possible amount of time submitting an application so I can get on with my life

As an applicant I want to be able to do some or all of the work myself so I’m not paying my agent to do something I could do

As an applicant I want to use the same login I use for other council services  so I don’t have to remember multiple passwords

As an applicant I want to see where my proposal can better meet policy so I can avoid my application for planning permission being refused (not in alpha scope)

As an agent I want to manage multiple applications at once so I can see all my live applications for all my clients

As an agent I want to be able to share the application with my client so they can fill in the information that they know, instead of me having to ask them

As an agent I want to process any requests for further information as part of the same original application so I can keep track of applications more easily (not in alpha scope)

As an agent I want to the process and requirements to be as standardised as possible across all councils so I don’t have to relearn the process every time

As a customer service agent I want to be able to access and view a customer’s applications so I can complete an application if they have already started it

Process Map


A map of the planning process today, noting key tasks and pain points. 



 You can view and comment on the original live, working diagram here
Mark

5. Scope



Types of submission



Outline    Detail /full      Approval of details
Certificate of Lawfulnessn/a       not yet      not yet
Prior approvaln/anot yetnot yet
Pre-applicationn/anot yetnot yet
Listed building consentn/anot yetnot yet
Householder applicationsn/ayesnot yet
Minor applicationsnot yetnot yetnot yet
Major applications (medium)nonono
Major applications (large, strategic)nonono




Causes of invalidation


ReasonDescriptionCan it be designed-out?
1. Missing formsUsually CIL form or  Certificate of Ownership. Usually because applicants aren’t aware this is required. yes
2. Incomplete formsForms not signed and/or dated.yes
3. Incorrect feeApplicant has incorrectly worked out the correct planning feeyes
4. Missing feeApplicant has not paid fee.yes
5. Missing / mis-labelled location planLocation plan either missing, incorrectly labelled (eg no red line) or not to a visible scale.yes
6. Missing reports or statementsMissing reports such as Design and Access Statement, Wildlife and Ecology checklist, Heritage statement, Flood risk assessment, Trees report, Transport assessmentprobably
7. Missing / mis-labelled other drawings

Missing descriptive name, not to scale, or a whole drawing (eg elevation) missing.not yet 
8. Drawings don’t match each otherThe drawings show different versions of the schemeno 
9. Other reasons




Stages of the user journey




The current project scope includes preparing and submitting a planning application. It does not include earlier explorations (such as finding out if you need planning permission) or later stages following your application through consultation, decision, appeal etc.




Planning documents


What planning information will now be asked for as of data instead of documents, and why? 

Forms

Current status     How often is it required for householders?Does it require  a certified professional?
Application formdata always    no
Materials listdataoftenno
Ownership certificatesdataalwaysno
Feedataalwaysno
CIL formsdatasometimesno

Reports

Current status     How often is it required for householders?Does it require a certified professional?
Design & Access statementdata often    no, but sometimes useful
Heritage Assessmentdatasometimesno, but sometimes useful
Ecology & trees checklistdataoftennot always
Flood risk assessmentdatasometimesnot always
Drainage / SUDS statementdatasometimesnot always
Basement impact assessmentdocsometimessometimes
Structural surveydocsometimesyes
Townscape visual impact Assessmentdocsometimesno, but usually useful
Navigational Risk Assessmentdocrarelyyes
Air Quality Assessmentdocrarelyyes
Biodiversity Surveydocrarelyyes
Archaeological Surveydocrarelyyes
Tree survey  / Arboricultural Impact Assessment docsometimesyes
Landscape & visual impact Assessmentdocsometimesno, but usually useful
Sun & Daylight assessmentdocsometimesyes
Local views assessmentdocsometimesno, but usually useful
Parking surveydocsometimesno


Drawings

Current status     How often is it required for householders?Does it require a certified professional?
Location plandata always    no
Existing plansdocalmost alwaysno, but must be correctly drawn
Proposed plansdoc almost alwaysno, but must be correctly drawn
Existing elevationsdoc almost alwaysno, but must be correctly drawn
Existing sections docalmost alwaysno, but must be correctly drawn
Proposed sectionsdocalmost alwaysno, but must be correctly drawn
Existing roof plandocalmost alwaysno, but must be correctly drawn
Proposed roof plandocalmost always
no, but must be correctly drawn
Site plan docsometimesno, but must be correctly drawn
Site photographsdocalmost alwaysno
Existing detailsdocsometimes
no, but must be correctly drawn
Proposed detailsdocsometimesno, but must be correctly drawn
3D massing modeldocneveryes


See the full working schema here



Users with specific accessibility needs


Non-English-speaking usersnot yet
Users with dyslexiaconsider
Users with autismconsider
Deaf or hard of hearingconsider
Visually impaired usersconsider
Blind usersyes (screen readers) 
Users with physical or motor disabilitiesconsider
Users suffering from anxietyconsider
Elderly usersconsider
Non-web usersconsider
Users with outdated devicesyes (as far as possible)


Mark