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 Would appeals that have been withdrawn be included in the measure of performance?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.
   

BV(x2)  Quality of Service Checklist

1. The introduction of the service checklist is supported, however the proposed scoring mechanism provides little incentive to secure improvements against the checklist as an authority which can answer 'yes' to all but one criteria under each 'quality question' will be scored the same as an authority that cannot answer 'yes' to any. However many criteria you score for each of the 'quality questions' unless you can tick them all you would score 0. As a consequence you wont know how any other local planning authorities are performing until they get full scores for each 'quality question' .Performance against the checklist would be better expressed as a percentage of meeting all the criteria, not just the 'quality question.'
   
   
2. 'Quality Question 2' - what does 'all aspects of design' mean?
   
   
3. 'Quality Question 5' -what is the definition of 'major' applications in this context? Not all 'major' applications within the current definition set out on the PS2 form require a development team approach.
   
   
4. What project management tools are deemed to be appropriate in order for this criteria to be met?

BVPI 107 Planning cost per head of population

The Society fully supports the deletion of this indicator

BVPI 188 the number of decisions delegated to officers as a percentage of all decisions

1. The Society supports the retention of this indicator and does not agree with the proposal to delete it.
   
   
2. The indicator and target are seen as helpful tools to secure effective delegation arrangements within local planning authorities and to delete the indicator and target at this time is considered to be premature in advance of the publication of the National Planning Forum's updated Guide to Schemes of Delegation, and a period following to enable those authorities who have yet to review their schemes the opportunity to do so, and make any necessary changes in light of the new guidance. The introduction of the indicator and target is acknowledged by the Society as a measure which has re-focussed members attention on the importance of having effective delegation arrangements which in turn has contributed to improvements in the performance of the speed of determination of planning applications and provides for an effective and efficient use of scarce planning staff resources. The indicator should be retained.

Planning Standards

There would appear to be no justification for the performance standard set for the poorly performing local planning authorities as defined by government, other than setting an arbitrary target.

The Society would like to take this opportunity to raise the potential for BVPI's to be included for the enforcement service, in future reviews of the indicators and performance standards. The Society would express a willingness to assist in devising appropriate measures if this is considered to be appropriate.

Download Document (160.768Kb) - DOWNLOAD