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 Around 10% are withdrawn entirely.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