The Importance of Pre-Application Communication in the Planning Process
Planners by nature are fond of abbreviations. “PAN”, “PAD”, “PACC” are examples of abbreviations which have become synonymous in the last few years with the early stages in the planning application process. Long before an application is submitted for most development projects, the applicant and their agent will follow these three steps.
So what do they mean?
PAN (Proposal of Application Notice) is the notice served on the relevant Council by the applicant to let the Council know that the applicant intends to submit an application for a major development proposal. Submission of the PAN kick-starts a 12 week period during which the planning application cannot be submitted. The applicant should use this time to carry out PAD (Pre-application Discussion) with the Council and its statutory consultees and PACC (Pre-application Community Consultation) with the local community and relevant stakeholders.
These procedures are defined through planning legislation and guidance and are designed to ensure that the planning application process is “front loaded”. The theory is, spending more time up front, engaging early with the right people and preparing an application that responds to the feedback will help deliver an approval in a timely fashion. Our experience tells us that by and large this works for most projects. There is no doubt that failing to get people on board before submitting your project for planning will at best put you on the back foot and at worst secure you a quick refusal.
PAD is nothing new and applicants have been engaging with Councils/ DoE prior to submitting applications for many years now. More recently however, Belfast City Council has introduced a charging system for pre-application meetings which has formalised the process further. Applicants should submit detailed information about the project to allow the Council and its consultees to fully understand what is being proposed and help them form an opinion as to the issues and how to resolve them. In return the applicant can expect a detailed and robust response from the Council as to the merits or otherwise of the project, its chances of success and what needs to be fixed in order to ensure that success.
Once PAD is closed out and assuming agreement is reached, the applicant can expect a positive and timely decision on their application following submission. That’s the theory anyway, but it is early days for this new system and it remains to be seen if paying for PAD is any more effective than the less formal system.
Time spent up front can often feel like wasted time for an applicant who is keen to get their application submitted, but trust me, a PAD process where the applicant and the authorities are willing to engage and compromise helps yield a quick decision on the other side.
While speaking to the authorities pre-application has always been a good idea, speaking to the public and key stakeholders is arguably becoming even more important. The introduction of PACC into planning legislation in April 2015 has changed the approach to the planning process beyond recognition. At Strategic Planning we have been carrying out pre-application community consultation on major projects for years and always found it invaluable in helping to get the public on board and generate support for the proposal while minimising objections.
Now that the legislation has finally caught up with our business model, the prospect of doing any major scheme (and indeed some more minor ones) without engaging with the public and affected parties is unthinkable.
The statutory requirement for PACC now means that for nearly any planning application, there is a public expectation that they are going to be consulted. This filters through to the politicians in the area, who, as the ultimate decision makers on many planning applications, will often be less than impressed if the applicant has failed to take on board public concerns or worse still not engage with the public at all.
The balance of power has certainly moved from applicant and planning officer to the public and the politician. This is not bad thing but has created a much more fluid and dynamic decision making process where those applicants stuck in the old way of doing things will fail.
In a recent residential application case we were brought in late in the day on to speak to local politicians prior to a Council meeting, it was clear that the lack of community engagement at the early stages of the application process was a cause for major concern for the Councillors. This is despite the fact that the application had been submitted prior to the statutory requirement for community consultation kicking in; however, such is the expectation now that all major schemes will have been subject of community engagement before they are presented to Committee for approval that it was suggested by one of the Councillors that the applicant should retrospectively engage before Members could look favourably on the application. Now, that didn’t happen as it was concluded through further engagement with the Councillors that it would be ineffective and would not have benefited the application, but it is testimony to the depth of feeling regarding proper and effective community engagement that exists amongst local politicians.
Pre-application communication on all fronts has forced everyone involved in major projects to take the issue of engagement and design consultation much more seriously. As a result, we are seeing everyone raising their game, creating better schemes along with more satisfied communities, planners and clients.
This article will appear in the next edition of Business First Magazine.« Back to News