Transforming our Planning team

1. Context

1.1 A progress review is an integral part of the Planning Peer Challenge (PPC) process. The purpose of the review is to support the planning service in implementing their action plan following the PPC and offer a sounding board for discussion as the work is progressing.

1.2 The main aims of this progress review with North Northamptonshire Council (the Council) were to:

• Provide feedback to the Planning Service on the progress they have made against the PPC recommendations and action plan.
• Identify any early impacts or learning from the Planning Service's progress against their action plan to date.
• Identify any significant changes or challenges that have arisen since the peer team were 'on-site' and consider how best to navigate these in the future.

1.3 In addition to the core matters of consideration for a PPC progress review the Council requested that PAS undertake a desktop-based review of the Council's use of the Extension of Time on planning applications. The findings and recommendations from this element of the review have been reported as an addendum to this report.

1.4 The Planning Service in North Northamptonshire (the Council) has demonstrated that it is open to peer feedback, support, and challenge to help strengthen its ongoing work on improvement.

2. Scope of the Progress Review

2.1 The following officers and peers took part in this progress review:

• Rachael Ferry-Jones - Planning Advisory Service, Peer Challenge Manager
• Anna Rose - Head of Planning Advisory Service
• Tracy Darke - Lead Officer Peer (Shropshire Council)
• Councillor Philip Broadhead - Conservative Peer Member (Bournemouth, Christchurch and Poole Council)

2.2 Rachael Ferry-Jones, Tracy Darke and Councillor Philip Broadhead were all part of the original peer team that undertook the planning peer challenge in September 2022. 

2.3 The team initially completed a desk top review of the latest performance information provided by the Council, including the Council's own "RAG rated" progress report on the action plan, that has been reported to their Planning Transformation Board, and an updated "position statement" for the planning service. This was also supplemented by relevant publicly available information, including relevant governance reports and decision-making performance information.

2.4 Following the desk top review, the peer team spent a full day with the Planning Service on 15 May 2024 where they engaged with a range of different planning officers as well as senior elected Members, including the Leader of the Council and the Executive Member for Growth and Regeneration, and the Chief Executive.

2.5 We appreciated the opportunity to return to North Northamptonshire for this progress review. The peer team felt warmly welcomed and received excellent support throughout the day. The team would like to thank all the officers and members involved for their input. During the time since the review team were originally at the Council it is clear that the Council has responded to the recommendations from the peer challenge along with new challenges for the Council and the service. 

2.6 Our feedback in Section 3 is organised into five broad themes that emerged from our interviews.

Theme 1 provides some general reflections from the team whilst themes 2 to 5 reflect on the original recommendations from the peer challenge report as follows:

1. General reflections (High level overview of some key issues)
2. 2. Planning service and staff structure (Recommendations 1, 2, 5 and 7)
3. 3. Transformation and data (Recommendations 3, 4, 6 and 9) 
4. 4. Customers and stakeholders (Recommendations 10, 11 and 12) 
5. 5. Planning policy and developer contributions (Recommendations 13 and 14) 

2.7 For reference, the original recommendations are reproduced in Appendix 1.

2.8 Following the peer progress review, the team has developed a set of new recommendations to support the council, and these are detailed in Section 4.

3. Feedback

General reflections 

3.1 Progress and ongoing improvements: The Council has made significant progress in several key areas, reflecting its commitment to addressing the recommendations from the previous peer challenge. Notably, the move to two planning committees, alongside changes to the committee boundaries and the scheme of delegation, demonstrates a proactive approach to streamlining the decision-making process. The Council has also made strides in coordinating data for developer contributions and successfully publishing an infrastructure funding statement, ensuring greater transparency and accountability. Moreover, we recognise the ongoing efforts to implement a new IT system, which, once fully operational, will further enhance the efficiency of planning services. While challenges remain, the Council has taken meaningful steps towards improvement, and these achievements should be acknowledged as part of their continuing journey. 

3.2 Building a unified approach: While the Council is making efforts towards working effectively as a single entity, achieving a unified approach is challenging. Many staff refer to their legacy authorities when we would expect they would be using North Northamptonshire Council, and this is exacerbated by them working across different locations and feeling restricted in their use of legacy software. This can create the impression externally that the authority is not fully integrated and working as one council. It is crucial to reinforce the unified identity to ensure cohesive collaboration and support teams in streamlining their work and ensuring more consistency. This should include consideration of how resources are shared to support teams proportionately across all locations. We are aware of the actions being taken by the Council to address this issue, including the introduction of a new service structure, a single office base, a single IT system, and efforts to ensure consistency of approach. We welcome these actions.

3.3 Red, Amber, Green (RAG) review: Developing an action plan following the PPC is commendable and serves as a good practice model that PAS have shared with other councils. Whilst using a RAG rating is one means of noting progress it can be open to interpretation and usually requires an extra layer of detail for it to become effective in ensuring accountability.

3.4 During our evaluation of the Council's planning service progress against the original peer challenge recommendations, we noted that the Council has made full use of the RAG rating system as a tool to track progress, and, in several areas, has progressed as far as current circumstances allow. However, we identified some actions marked as "green" (indicating completion or no further action required) where outstanding issues remain that need addressing to fully meet the intent of the original  recommendations. We suggest considering the RAG ratings to ensure they accurately reflect the remaining work and propose new recommendations where necessary to build on the progress made. Providing more detail around completion criteria and any unresolved challenges will help maintain transparency and support further improvement. 

3.5 Public Challenges: Recent public complaints, including judicial reviews of council practices, have created challenges for the planning service. We recognise the pressure this has put on the service and the heightened scrutiny that accompanies such challenges. It is evident from the information shared with us that the Council is actively addressing these issues and implementing improvements, such as updating protocols and providing clear guidance for officers, as well as the establishment of a Planning Improvement Board. These efforts are acknowledged and will support staff moving forward. Care should also be taken to ensure that changes are proportionate and not excessively burdensome in addressing exceptional cases.

3.6 To further support the Council in their ambition that the planning service is reflecting best practice in the way that it operates we recommend that they consider commissioning PAS to deliver their on- site Development Management Toolkit training ensuring a particular focus on: • consultation and allocation; and • considering an application. This training would involve reviewing relevant information in advance, working with officers on-site on the two sections of the DM toolkit, and subsequently providing a short report with recommendations and conclusions that reflect best practice.  Planning service and staff structure (Recommendations 1, 2, 5 and 7)

3.7 Pay and grading system: We acknowledge that the Council has made significant progress in establishing a unified pay and grading system across the organisation. At the time of the original peer challenge, the Council had approval to streamline pay and grading for interim and new staff. It has since obtained approval to extend these changes to staff from the legacy authorities who have been transferred to the Council via the Transfer of Undertakings (Protection of Employment) Regulations (TUPE). This process is however contingent on mutual agreement, and we recognise that staff cannot be compelled to adopt the new terms and conditions. While the current RAG rating reflects the progress that has been made at a corporate level, we did hear from some staff that the variation of pay, and grading remains a justifiable cause for concern. We therefore commend the steps taken so far and recommend continuing to prioritise this area at a service level to facilitate the transition and address staff concerns fully.

3.8 Apprenticeships: The council has taken proactive steps to establish apprenticeship programs aimed at cultivating a sustainable pipeline of planners within the organisation. This initiative is pivotal not only for addressing current staffing needs but also for nurturing talent and ensuring the future continuity and expertise of the planning service. By investing in apprenticeships, the council demonstrates a commitment to long-term workforce development and the enhancement of planning services.

3.9 Backlog Funding: The council has successfully secured funding from the Department for Levelling Up, Housing and Communities (DLUHC) (now the Ministry of Housing Communities and Local Government (MHCLG) specifically to tackle the backlog of planning applications. This funding allocation reflects the Council's proactive approach to managing workload challenges and signifies their commitment to improving efficiency and service delivery within the planning service. It is important to communicate that, while addressing the backlog may temporarily affect performance statistics such as processing times and application turnaround rates, this short-term impact is a necessary step towards long-term improvements in service efficiency and effectiveness. 

3.10 Teamwork and leadership: The planning team exemplifies a robust culture of collaboration and mutual support, fostering a cohesive and supportive working environment. Colleagues actively engage in teamwork, readily assisting each other to navigate challenges. Despite the strong collegiality, there are notable concerns regarding morale, perceived lack of leadership support, and instances where staff feel unaware and unsupported. There is also a concern from their perspective that not all the original peer challenge recommendations have been adequately addressed.

3.11 Additionally, concerns were raised internally regarding prolonged absence of a member of the senior leadership team, impacting staff morale and operational stability. Issues that have led to successful legal challenges may also be linked to a lack of strong management within the service. We felt that officers are willing to follow, but that there was perhaps no clear leadership to guide them at the time we visited. It is crucial for the council to address these concerns transparently and ensure continuity in leadership support for the planning service moving forward. 

3.12 These challenges highlight the need for regular leadership engagement and support to bolster morale and ensure that staff feel adequately supported in their roles. We are aware that the senior leadership team (Executive and Interim Directors) have held forums with staff and would recommend that these continue on a regular basis and are well communicated amongst staff.

3.13 Change creates worry, fear and low morale. Maintaining and even increasing contact through 121s and team meetings is important and can help to encourage and support teams. Conversely, the loss of, or absence of, these core management tools can have the opposite effect. We heard that the approach to 121s with relevant team leaders is not consistent, and we would recommend that this is an area of focus for the Council.

3.14 Resource and Recruitment Issues: We heard that the planning service is grappling with persistent issues related to inadequate resources and recruitment difficulties, impacting its operational effectiveness. The service also continues to rely heavily on agency staff. Additionally, staff feedback indicates that many are working beyond their contracted hours to meet performance targets, highlighting the strain on staff caused by these challenges. Performance management should ensure that workloads are distributed equitably to avoid overburdening the willing, which is a key factor in staff retention. We recognise that these are shared challenges among councils across the country. However, it is crucial for the Council to prioritise improvements, such as addressing pay and grading issues, to alleviate these pressures.  Transformation and data (Recommendations 3, 4, 6 and 9)

3.15 Transformation plan and vision: The Council had rated progress on this initiative as green in the RAG assessment however, upon review, evidence supporting this rating was not clear. While progress had been made in establishing a Transformation Board, and now a Planning Improvement Board, the peer team felt that the Council has not yet fully articulated a clear vision and structure for the planning service. It is recommended that the Council revisits this aspect to ensure that the vision- setting process is robust and inclusive, reflecting a comprehensive understanding of the desired outcomes and objectives for how they would like the planning service to operate. This vision should serve as a guiding framework, informing all aspects of service delivery and any further transformation efforts.

3.16 In building this vision, the Council should celebrate and reflect on their successes. Notable achievements include attracting the business NIKE to locate in the area and successfully implementing pre-application fees for national strategic infrastructure projects. These accomplishments demonstrate the Council's capability and potential and should support the development of a comprehensive and aspirational vision for the planning service. By recognising and 
building on these successes, the Council can create a vision that is both ambitious and grounded in their proven strengths.

3.17 Transformation Board / Planning Improvement Board: The Council set up a Transformation Board that consisted of councillors who volunteered for the role. The Board were scheduled to meet monthly which demonstrates the level of commitment by the Council to drive transformation and improvement. The RAG-rated action plan has been reported to this board over time; however, councillors have expressed concerns about receiving papers late and frequent meeting cancellations. Given the level of frequency of meetings there were occasions where there were no available updates and as a result some meetings were justifiably cancelled. Notwithstanding, some Members felt they lacked the opportunity to drive the transformation as they had initially envisioned. There was also some uncertainty regarding the role of the new Planning Improvement Board. We understand that since we met on site the Leader of the Council has acknowledged the input and support provided by the Transformation Board and thanked Members for their service. The Transformation Board has now ceased and has been replaced by the Planning Improvement Board.

3.18 Planning Committee: We commend the Council for their substantial progress in implementing our earlier recommendation regarding the scheme of delegation and committee structure. Transitioning to two committees and adjusting their boundaries demonstrates a proactive approach towards creating a more efficient and cohesive planning service. By aligning committee boundaries with operational needs and amending the scheme of delegation, the Council has taken significant steps to streamline decision-making processes and enhance service delivery. This progress reflects a commitment to improving effectiveness and aligning with the vision of a unified planning service. Feedback from most stakeholders has been very positive, underscoring the successful impact of these changes.

3.19 Notwithstanding the above, it may be necessary to revisit the data to consider whether two committees are an efficient application of resources, as at least one of the committees has experienced recent cancellations. This could be due to various factors, including the timing of reports. We recommend reassessing the data periodically to ensure that the spatial boundaries of each committee are appropriate and that they proportionately reflect the number and type of applications being received. In light of the cancellations, it may also be appropriate as part of this periodic review to assess the data and consider whether one committee would be a more efficient and effective structure. This should be considered alongside any emerging proposals by Government to modernise planning committees given that this is one of the objectives of the proposed Planning and Infrastructure Bill as announced in the King's Speech.

3.20 We heard that the current workflow protocol sometimes results in schemes being put forward for delegation before discussion with the Chair of the Planning Committee. We suggest revisiting the workflow process to ensure that Officers and Members are clear on how it should operate and that relevant schemes are duly considered by the Chair of the Planning Committee prior to determination.

3.21 Data and information technology systems: The Council informed us that they have implemented Power BI to integrate data from the different legacy authority systems; however, we did not receive any evidence of this integration, as the data provided to the peer team was still broken down by legacy authorities. This highlights ongoing challenges in presenting data as a unified council and reinforces the tendency of officers to relate to their legacy authorities. While the Council has made progress in commissioning an IT system to unify legacy information onto a consistent platform, we understand that such implementations take time. Notwithstanding, the phased approach to this software's rollout, with each legacy team starting at different times, further reinforces disparate working patterns and delays the streamlining of the service.

3.22 We recommend that the Council consider rolling out the new IT system to all teams simultaneously, starting with inputting new applications into a unified system, while phasing the transfer of historical data. This approach was supported by the officers we spoke to, who did not view operating multiple systems during a transitional period as a significant constraint. Officers do however have some concerns that they have not been included, nor necessarily had the capacity, to fully engage in how the new software will operate and determine whether it is fit for purpose. We recommend that key staff be included in the development and phasing of the approach and implementation.

3.23 It is also crucial to ensure that all service needs are adequately serviced and to identify where the chosen platform may not meet those needs. For example, in monitoring developer contributions, there are other widely used software packages, such as Exacom, that integrate with core planning services software. We suggest consulting with peers who use different software packages for specialised matters, including the management and monitoring of developer contributions, to ensure the best solutions are implemented.

3.24 Additionally, we recognise that Power BI can be a powerful tool for managing the service, and in the interim, staff should be trained on how to integrate data and present it in a unified way. This training will help ensure that the Council can effectively utilise its resources and present a cohesive and integrated planning service.  Customers and stakeholders (Recommendations 10, 11 and 12)

3.25 We received 19 responses from the external stakeholders who were invited by the Council to make any comments on progress against the PPC recommendations. This included responses from Parish and Town Councils and developers. Many acknowledged positive improvements including the new committee structure and some referenced improved communications regarding planning changes. However, concerns persist over inconsistent email responses and access to officers, as well as delays and suggested inconsistencies in planning decisions. There is a unanimous call for clearer communication channels, streamlined policy application, and enhanced enforcement measures to address breaches promptly. Planning enforcement was cited as a particular concern for many of the Parish and Town Councils.

3.26 Stakeholders, including Parish Councils, have highlighted the importance of access to training and improved engagement in planning matters, particularly regarding developer contributions to maximise local benefits. It is commendable that the Council has been providing training sessions for Parish Councils, and these efforts should be recognised. To build on this, periodic reminders and enhanced communication would ensure that all local councils are fully informed of and able to take advantage of these opportunities, further strengthening collaboration and engagement in the planning process.

3.27 At least one response noted effective service provision by the planning teams, highlighting regular dialogue with officers and senior officials, and successful collaboration with other consultee colleagues through Planning Performance Agreements (PPAs). However, significant issues persist, including delays in consultation responses from other key stakeholders which remains a source of frustration and delay for both the Council and applicants, impacting project timelines. Feedback from developers also included frustrations about a perceived lack of improvement. One response commented that whilst there is political leadership, they cannot see this carried through to operational areas with the same confidence. Whilst relationships with senior management and officers at a project level are good there is a lack of engagement and consistency across the Council. They would like to see greater integration and alignment of the planning service in light of the overall corporate ambitions of the Council. Planning policy and developer contributions (Recommendations 13 and 14)

3.28 Planning policy and the Local Plan: The previous peer challenge report acknowledged the effective history of collaboration within planning policy and the imminent adoption of core local plan documents. Whilst it did raise some concerns about project management and ensuring the Council has a realistic timeline for producing a new local plan, generally the feedback was very positive. Our progress review however highlighted several issues including resource constraints within the planning policy service with unfilled vacancies in the Local Plan team which are challenged by the restructuring of the service. It is crucial to address these challenges proactively, as challenges in planning policy can escalate into more complex crises.

3.29 Development Management often takes the focus of Councils, as national performance measures provide a quicker indication of challenges within the service. In contrast, issues within the Local Plan can take longer to become apparent as they arise over time. Officers would like the senior leadership team to acknowledge this distinction and support them in prioritising this area of the planning service, ensuring adequate support, resource, and corporate attention to foster cohesive and effective local plan development. This should include showcasing the role of the local plan corporately to unify planning policy in line with the Council's strategic spatial ambitions and the sustainable development of the Council's area.  

3.30 Developer contributions: The council has made notable improvements in coordinating developer contributions data to prepare an infrastructure funding statement. In response to a recent local audit, they have developed a comprehensive protocol manual that references PAS guidance, and which enhances transparency and consistency in their processes. To further optimise the management of developer contributions and streamline this service, it is advisable for the Council to explore adopting a software package that is fit for purpose and which communicates with the planning software that the Council has commissioned. Consulting with other authorities that use similar software will provide valuable insights into effective and efficient solutions tailored to the Council's needs, ensuring robust management of developer contributions and infrastructure funding moving forward. 

4. Recommendations 

4.1 The following summarises the recommendations from the peer review team following the progress review:

1. Reinforce the unified identity of North Northamptonshire to ensure cohesive collaboration and support teams in streamlining their work and ensuring more consistency. Officers should identify working for North Northamptonshire to external parties and refrain from referencing legacy authorities. To support officers and the streamlining of the planning service consideration should also be given to how resources are best utilised, for example design advice, to support teams proportionately across all locations.
2. Building on the progress made corporately, prioritise at service level the implementation of streamlined pay and grading for staff transferred under TUPE regulations. While acknowledging that this will require mutual agreement, we recommend that the Council prioritise this at the earliest opportunity to facilitate the transition and comprehensively address staff concerns.
3. Consider the Red Amber Green (RAG) ratings in the action plan to ensure that they accurately reflect progress. This should include verifying that actions marked as green fully meet the original recommendations and address any outstanding issues. To enhance transparency, it would be helpful to provide a more detailed explanation for each RAG rating to clarify completion criteria.
4. To support the Council in their ambition that the planning service is reflecting best practice in the way that it operates consider commissioning PAS to deliver our on-site Development Management Toolkit training ensuring a particular focus on:
   • consultation and allocation
     and
   • considering an application
5. Prioritise regular leadership engagement, 121's and support to address officer's concerns and communicate on important matters. Continued forums with staff by the senior leadership team, including the Assistant and Executive Directors, are recommended to maintain transparency and foster a supportive work environment. 
6. Define a cohesive vision that outlines how the Council would like their planning service to operate. This vision should serve as a guiding framework, informing all aspects of service delivery and any further transformation efforts.
7. Periodically reassess planning application data and the workflow process to ensure that the spatial boundaries of each planning committee are appropriate, that they proportionately reflect the number and type of applications being received and that schemes appropriate for determination by the planning committee are duly considered. As part of this periodic review consideration should be given to whether one committee would be a more efficient and effective structure.
8. Consider rolling out the new IT system to all teams simultaneously, starting with inputting new applications into a unified system, while phasing the transfer of historical data. Key staff should be included in the development and phasing of the approach and implementation to ensure the software is fit for purpose. Additionally, ensure that all service needs are adequately serviced and consult with peers who use other software packages to deal with specialised areas of planning for example, the management and monitoring of developer contributions. As a priority in the interim period, officers should be trained on using Power BI to integrate data and present it in a unified way, ensuring the Council can effectively utilise its resources and present a cohesive planning service.
9. Periodic reminders to ensure all local councils are aware of and can participate in training opportunities.
10. Prioritise addressing resource constraints and filling vacancies within the planning policy service. Senior leadership team should enhance focus on the local plan, aligning it with the Council's corporate spatial ambitions and sustainable development goals.
11. Explore effective software solutions for managing developer contributions to enhance efficiency and effectiveness. Consult with other authorities using similar systems to identify best practices and work towards ensuring that the Council implements an optimal management solution for the management and monitoring of developer contributions (Linked to recommendation 8). 

5. Conclusions and next steps

5.1 It is clear to the peer team that the recommendations of the original Planning Peer Challenge in the Council have been taken seriously. A comprehensive action plan was developed by the Council and progress has been made across many of the recommendations. 

5.2 Like any local planning service, there are always areas for ongoing improvement, along with new challenges and opportunities to consider. This report outlines these areas and identifies where the peer team believes the Planning Service should now focus on its improvement journey. PAS is committed to continuing to work alongside the Council to support the ongoing development of the planning service. 

5.3 For any questions about the original Planning Peer Challenge or this progress review please contact: Rachael Ferry-Jones Principal Consultant Planning Advisory Service [email protected]   Local Government Association 18 Smith Square Westminster London SW1P 3HZ 

Appendix 1: Original PPC recommendations (October 2022)   

2022 Recommendations and progress

1. Continue work to establish a consistent corporate pay and grading system as a matter of priority as this is currently a barrier to transforming the planning service.
2. Build on the work done so far on the staffing structure to produce a detailed staffing structure for the entire planning service (beneath tier 4 and 5 posts) to provide clarity and start to build one team.
3. Develop a comprehensive transformation plan for the development management service to bring the five existing systems, teams and services into one:
   • Start with a vision for the planning service, including what 'good' looks like
   • Allocate appropriate resources and programme management expertise to deliver the plan and recognise that there will need to be some temporary working arrangements during the transformation process including working across existing teams and systems
   • Involve people from across the service in developing the plan and supporting workstreams to build a shared sense of purpose.
   • Consider setting up a board to oversee the work with senior level councillor and officer sponsors
4. Consider how to resource the transformation necessary, with some potential fixed term posts to kick start the process funded from vacancies.
5. Review the current agency arrangements including considering a different procurement route to let a contract for services with an overarching organisation.
6. Implement a robust performance management framework to:
   • provide the data and information necessary to understand how the service is performing and inform what resources are needed
     and
   • carry out an early risk assessment of out-of-date planning applications.
7. Implement appropriate management and support for employees to include a consistent approach to one-to-one meetings, team meetings, and some clarity about hybrid working expectations such as when people are required to attend meetings in person.
8. Further review the scheme of delegation and the number of committees:
   • Ensure that householder and minor applications only go to committee in exceptional circumstances
   • Trial a significantly reduced number of committees with a proportionate geographical spread (based on an analysis of applications needed to go to committee after the changes to the scheme of delegation)
   • To encourage the move to a new joined up planning service, it would be better if the new committee boundaries were not aligned to the predecessor council boundaries
   • Ensure the new scheme of delegation and other adopted policies are consistently applied
9. Consider some messaging for customers about current issues and plans to address them, once these are clear.
10. Consider opportunities for more planning training and development for town and parish councils, in conjunction with North Northamptonshire members and officers.
11. Consider how best to involve internal and external stakeholders early enough to maximise the gains from planning applications, particularly on larger applications and to avoid unnecessary consultation requests on some applications. 
    2022 Recommendation and progress
12. Engage with PAS to benefit from their current support offer on improving the governance of developer contributions.
13. Consider working with PAS to establish realistic project management arrangements for progressing the Council's planning policy framework.    

1. Context

1.1 This is an addendum report to the planning peer challenge (PPC) progress review report that was issued to North Northamptonshire Council (the Council) in October 2024.

1.2 In addition to the core matters of consideration in the PPC progress review the Council requested that the Planning Advisory Service (PAS) undertake a desktop-based review of the Council's use of the Extension of Time (EOT) on planning applications. The findings and recommendations from this element of the review are the subject of this addendum report.

2. Scope of the Progress Review 

2.1 In undertaking this review we have had regard to the following documents and data provided by the Council:

• Workflow Process 2023
• EOT Protocol -v1 Jan 2024
• Site Visit protocol
• Note on use of Extensions of Time within Planning
• EOT info - 01.06.22 - 31.05.24

2.2 In addition to the above we have also considered planning applications data that is published and publicly available on the Government's website.

3. Feedback and recommendations

Workflow Process 2023 

3.1 Categorisation and validation efficiency - The implementation of three distinct categories is helpful and provides a clear framework for processing applications.

The aspiration to achieve validation within 3 days is very good and achieving this goal would indicate efficient processes, considering the national benchmark for validation completion is an average of 5 days.

3.2 Processing targets - Setting a target of 28 days for straightforward applications is very good, aligning with best practices and ensuring timely decision-making.

3.3 Differentiation of Application Types - It could be beneficial to further differentiate between householder applications and other minor applications. Establishing more ambitious targets for householder applications could drive even greater efficiency in processing times.

EOT Protocol

3.4 Overview - It is beneficial to have a protocol of this nature, serving as a useful model for others. The requirement for officers to obtain managerial approval for EOTs demonstrates strong discipline and helps to ensure that EOTs are granted only by exception.

3.5 EOTs and refusals - The policy that EOTs cannot be used for refusals is a good idea, provided it does not adversely impact performance. This approach will be effective as long as there is strong discipline to ensure refusals are determined within statutory timeframes.

3.6 Appropriate and inappropriate use of EOTs - While the protocol outlines when EOTs are appropriate, it would also be helpful to specify when they are not appropriate. For example, EOTs should not be used if a case officer realises that the application has gone over 8 weeks without prior communication with the applicant.

3.7 Recording and limiting EOTs - The policy on recording EOTs is sound but it would also be beneficial to include the reason for each EOT in the records. Having a policy to limit EOTs to one per application is considered good practice and is an approach that DLUHC is considering introducing at a national level.

3.8 Recommendation - To amend the EOT protocol to specify when EOTs are not acceptable. This should include a stipulation that EOTs will not be permitted for any householder applications (see planning applications data analysis below and possible future government policy).

Site visit protocol

3.9 Overview - Having a site visits protocol is beneficial and reflects good practice, providing clear guidelines for the process.

3.10 Criteria for site visits - It would be beneficial to include topographic factors in the criteria for determining the need for a site visit. For example, sites with steep slopes are much harder to assess using only photos. Additionally, the need for site visits should consider the level of objections and the officer's recommendation. A common complaint to the Local Government Ombudsman (LGO) is that objectors feel their concerns have not been properly considered. Complaints have been upheld when there is no evidence of a site visit, particularly regarding issues such as overlooking.

3.11 Recommendation - Amend the site visits protocol to include topographic issues, the level of objections, and officer recommendations as criteria for site visits. Ensure officers provide a written note explaining their decision not to conduct a site visit.

Planning applications data analysis

3.12 It is important to note that we have considered the planning applications data as a whole for North Northamptonshire, and not by a breakdown of legacy authorities.

3.13 Quality - The current appeal outcomes are generally satisfactory, with only one major appeal lost and a low percentage (1%) of non-major appeals lost. However, the fact that 32% of non-major appeals were upheld is concerning, as it exceeds the generally acceptable threshold of 25%. This indicates a potential need to improve the robustness of the process for defending appeals.

3.14 Speed - Presently, the council's performance on speed metrics, as measured by the Department for Levelling Up, Housing, and Communities (DLUHC), is satisfactory and not at risk of designation. Nonetheless, there has been a slight decline in the performance of major applications in the last measured quarter. As with many councils, this performance is largely maintained through the use of extension of time agreements.

3.15 If DLUHC implements the new measures proposed in the Accelerated Planning System consultation, the council will fall below the minimum thresholds. Currently, major applications have a 16% determination rate within 13/16 weeks against a proposed 50% minimum threshold, and non-major applications have a 48% determination rate within 8 weeks against a proposed 60% minimum threshold.

3.16 North Northamptonshire's performance mirrors the national picture, where the national average for determining major applications within 13/16 weeks is 19% and for non-major applications within 8 weeks is 49%. Therefore, significant changes will be necessary for most councils to meet the proposed new DLUHC targets.

3.17 A further breakdown reveals that 46% of householder applications required an extension of time between June 2022 and May 2024. The DLUHC consultation suggests that councils will not be allowed to use extensions of time for householder applications, necessitating a significant shift in the council's approach.

3.18 Recommendation - It is recommended that the council begins monitoring the speed of decision-making without extensions of time against the proposed new DLUHC targets. This will help staff acclimatise to more challenging targets. Additionally, staff should be informed that extensions of time should not be used for householder applications.  3.19 Recommendation - Consider creating a Development Management (DM) manual that consolidates all protocols in one place. This would provide a comprehensive resource for DM officers, helping ensure consistency in practices. We can connect you with councils that have successfully implemented such manuals if desired.

4. Conclusions and next steps

4.1 For any questions regarding this addendum report please contact: 

Rachael Ferry-Jones - Principal Consultant, Planning Advisory Service 

[email protected]

Local Government Association
18 Smith Square
Westminster
London
SW1P 3HZ