1. Understanding the problem


  • On average 50% of all Householder applications are invalid on receipt, and need to be resubmitted. This causes significant delays.

  • The system is incredibly confusing for applicants to navigate

  • Applicants need to visit and understand multiple websites and documents before submitting

  • The process is hugely costly - in terms of time and money – for both applicants and planning authorities

  • There are different local and national requirements that add further confusion

  • There is no indication at the point of submission that your application will be invalidated / refused for an obvious reason

Pain points for applicants

My application keeps getting sent back. A small, easy mistake can cause a big delay, and cost.
There is no clear, standard structure to tell you what information and documents are required
You don’t know what you don’t know. You need to already be an expert to use the service.
It’s so complicated. I’d need to hire a professional to even explore my options, so I’ll leave it.
I have to research across multiple websites and documents to find the information I need to use one service successfully.
It is inconsistent, the use, interpretation and prioritisation of policies seems to vary significantly

Pain points for officers

Every application has to be manually checked and validated. This typically takes 4-5 hours per application.
Every application has to be manually assessed against current legislation. There’s pressure on us to work quickly, but not to make mistakes.
Very little of my job involves actual planning A lot of my time is taken up doing data lookup and data entry.
Theres a lot of redundant information A lot of application reports are just our own policies regurgitated back at us. It’s hard to find the actual information we need.
A lot of time is spent dealing with applicants wanting more information or attacking the system in frustration, leading to complaints, twitter rants etc

Pain points for managers and the wider public

Resources are stretched, but we still need to process applications in time.
Costs are high The time it takes to process small applications is not covered by the fee.
Risk Ensuring consistency and quality of decisions is challenging, especially with high staff churn rate.
Resilience COVID19 has demonstrated that we need to be able to run all services remotely
Transparency & monitoring  Data about planning applications and analytics data is inaccessible or does not exist. 
Roadblocks The slowness and uncertainty of the process represents a cost and barrier to development, especially development by self-builders, small businesses and other small players
Democratic participation  It is incredibly hard for most people to engage constructively in public consultation because it takes so long to dig through folders of poorly name files to find the information that matters etc

How many planning submissions do councils receive?

Every year, councils receive thousands of planning submissions. This includes applications for planning permission (on average an 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?

Source: RIPA survey of UK councils, responses received

Currently the vast majority of planning applications are received indirectly via Planning Portal, which is now a private company. The remaining few 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?

Source: RIPA survey of UK councils, responses received

Source: Lambeth council (data to Jan 2021)

A significant number of planning applications received are ‘invalid’. This means checking whether some required documents are missing, incomplete or incorrectly formatted. 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 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