The Planning Officers' Society welcomes the consultation paper and the opportunity given to comment on the governments' proposals.

In summary, the Society supports the proposals to introduce BVPI's for:

• The percentage of appeals allowed against the authority's decision to refuse
• The quality of service checklist

And for the deletion of BVPI 107 'planning cost per head of population.'

The Society does not support the deletion of BVPI 188 'the number of decisions delegated to officers as a percentage of all decisions.'

However, the Society expresses grave reservations with the proposal to introduce the new BVPI's from 1 April 2004 given the ambiguity and lack of clarity in the current guidance.

The Society would suggest that the introduction of the new BVPI's be delayed until the following issues have been addresses and clear guidance issued, to ensure consistency of application and the implementation of measures to provide a clear audit trail for capturing the required information within individual local planning authorities.

BV(x1)  Percentage of appeals allowed against the authority's decision to refuse

1. To what type of applications does this apply? i.e. planning applications, advertisement consents, listed building consents and conservation area consents, enforcement cases, certificate of lawfulness.
   
   
2. Would appeals that have been withdrawn be included in the measure of performance? If counted this could weigh against the local planning authority, yet it could be viewed as a successful outcome.
   
   
3. How are partially allowed appeals to be counted? Often the element of the appeal that is allowed is satisfactory to the local planning authority and only that element which is dismissed the subject of objection.
   
   
4. Is the percentage of appeals allowed expressed against the total number of refusals issued, or of those refusals which were the subject of an appeal? If the latter is the case consideration should be given to the Planning Inspectorate collecting this data.
   
   
5. Unclear as to why this will provide a measure to determine consistency of adhering to policy. All refusals should be founded on policy grounds, if they are subsequently allowed on appeal, this will be as a consequence of the Planning Inspectorate/ODPM interpreting policy differently to that of the original decision-maker, assessing the impact in a different way, or by affording different weight to material considerations, than that afforded by the local planning authority.