Planning applications have become significantly more complex, in terms of documentation required and matters considered during determination, over the last 30 years. Within this time period it is estimated, by varying industry reports, that the cost of preparing reports required for applications is around five times more than it was, without even taking into account planning application fees themselves. In addition to this, the requirements, from Council to Council, are inconsistent, which can sometimes make submitting applications feel a little like playing roulette, depending on which Council your application lands within.
Application requirements evidently depend on what you are applying for and where. Despite this, there is definitely a list of most commonly required documents which include, in no particular order, the application form, ownership certificate, agricultural holdings certificate, design and access statement, location plan, site plan, existing and proposed floor plans and elevations (where applicable) ecology surveys, noise surveys, flood risk assessments, heritage assessments, planning statements, structural surveys, tree surveys, visual impact assessments, landscaping plans and highway surveys.
Even the simplest application can require a large number of the above application requirements and it is not surprising that when applicants come to seek planning permission for their proposed project, it can be quite a surprise as to the volume of information which is need and which we advise clients they will require to get through validation (and ultimately secure a permission). As part of this we are, however, often asked why you need certain documents and whether they are truly necessary.
We have, therefore, taken five examples of common documents which are required as part of a planning application in order to explain why such documentation is required as part of the determination of your proposals.
Planning/Design and Access Statement – the purpose of these statements is to demonstrate how the design of a proposal relates to its site, how design has evolved (where appropriate) and how it responds to the local context and location. The document generally addresses specific policy at both local plan and national levels against which the proposal would be assessed against, and is overall a valuable document in providing support for proposals in order to seek approval.
Ecological Surveys – Circular 06/05: Biodiversity and Geological Conservation – Statutory Obligations and Their Impact Within The Planning System (August 2005) specifically mandated that material ecological impacts need to be fully considered at the planning stage and cannot, therefore, be dealt with via condition following approval of a development. At the very least, a preliminary ecological appraisal (PEA) is needed on most sites to ensure there are no ecological impacts, or protected species, which need to be taken into account and mitigated as a result of the proposal. Aside from planning, any damage towards protected species would also be a breach of legislation such as, but not limited to, The Conservation of Habitats and Species Regulations 2010 and the Wildlife and Countryside Act 1981. Non-compliance with ecological legislation can carry consequences outside of the planning system.
Highways Surveys – Even if you are utilising an existing access, there is a requirement, as part of any development proposals, for access being utilised to be brought up to the relevant standards which most commonly concern visibility splays. Visibility splays are calculated off the speed at which the road is used, and this can either be calculated utilising the speed limit enforced but, more commonly, is calculated utilising speed survey data to specifically work out the length of visibility which is required. If appropriate, and safe, access for all users cannot be demonstrated, it is very likely that your proposal would be refused on highway safety grounds.
Structural Surveys – structural surveys are more commonly required on applications for conversion of existing buildings. This is of particular importance for both full and prior approval applications where, for example, barn conversions are required to be able to be converted without the need for new structural elements and must be able to take the loading of a conversion. Without such structural reports, it cannot be determined that the proposal is a true conversion, which is important taking into account Case Law such as Hibbett and, in the case of something such as a Class Q prior approval, if it is not a true conversion, the proposal cannot progress under that permitted development right and any works could be considered as having been commenced without planning permission.
Heritage Assessments – If your proposal is a listed building, or in or impacts upon a conservation area, there is a legal obligation upon the determining body (the Council) to take such matters into account. Indeed, the National Planning Policy Framework is specific in its requirement for taking into account impacts to designated heritage assets (and non-designated heritage assets) and there is a requirement to preserve and enhance heritage assets as a result of any development proposals. Any harm is required to be quantified and assessed against any public benefits arising from the proposal.
Whilst we, as consultants, try to keep submission documents to a minimum in order to keep applications as cost effective as possible relative to what is being proposed, there are often a list of non-negotiable reports and surveys which are required with input from relevant, qualified, professionals in their field. Without the appropriate submission documents, it is not uncommon for Councils to refuse to validate applications until such information is available (for example bat surveys to be undertaken in the relevant survey season) or, if validated, lack of information can then lead to a refusal as a result of a lack of appropriate information.
We will always only advise you as to the documentation which is required to support your proposal and to assist you in gaining a positive outcome even though we do understand that, sometimes, the cost of an application can be significantly more than perhaps first anticipated at the point of initial enquiry. If reports are needed, we are always able to explain why, such as with the examples above, as well as explain the implications of any specific reports upon your intended plans.
We certainly don’t instruct reports for the sake of it, nor are we on any commission basis from those who we regularly obtain from across varying professional disciplines.