The Cost of Delivering a Development Management Service in Wales - Welsh Government
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Welsh Government The Cost of Delivering a Development Management Service in Wales 271751-00 January 2021
Cost of Delivering a Development Management Service in Wales Welsh Government Executive summary Ove Arup & Partners Ltd. is delighted to deliver this report to the Welsh Government which presents the findings of the ‘Cost of Delivering a Development Management Service in Wales’ research into planning fees. The research was commissioned in October 2019 and its overall purpose is to inform potential improvements to planning fees in Wales. Through detailed financial modelling, the research has been able to provide estimates related to fee income and overall costs across planning departments in Wales. Using this data, it presents the potential changes which would be required to planning fees in order for Local Planning Authorities in Wales to achieve full cost recovery. In addition, it explores what a reformed planning fee schedule could look like if the existing planning fee regulations were to be simplified. This report provides some consideration as to what the potential implications of the model findings might be. It will subsequently be for the Welsh Government to determine how this is applied within policy and legislation in collaboration with key stakeholders. January 2021 2
Cost of Delivering a Development Management Service in Wales Welsh Government Contents 1. Introduction 5 2. Stakeholder Engagement 6 3. Approach to the Research 7 4. Developing a Data Set 8 5. Building the Model 10 6. Scenarios and Model Schema 14 7. Testing the Model 18 8. Key Themes Emerging from the Model 22 9. Conclusion 24 January 2021 3
Cost of Delivering a Development Management Service in Wales
Welsh Government
Acknowledgements
This research has been supported by the following:
• Lewis Thomas – Welsh Government
• Owain Williams – Welsh Government
The Arup Project Team:
• Kieron Hyams
• Emmeline Reynish
• Guillermo Guridi Alvarez
• Allan Pitt
The Working Group, including representatives
from the following organisations:
• Neath Port Talbot Council
• Cardiff Council
• Welsh Local Government Association
• Monmouthshire County Council
• Bridgend CBC
• Blaenau Gwent CBC
• Royal Town Planning Institute
Planning Officers Society Wales representatives
from the following organisations:
• Gwynedd Council
• Vale of Glamorgan Council
Ffynnon Oer Wind Farm, Neath Port Talbot
January 2021 4
Cost of Delivering a Development Management Service in Wales
Welsh Government
Introduction
Project Context Research Objectives
Planning fees in Wales are detailed within the The key objectives of the research are as
Town and Country Planning (Fees for follows:
Applications, Deemed Applications and Site • To provide a broad definition of Full Cost
Visits) (Wales) Regulations 2015 (as Recovery (FCR) in the context of
amended) (herein referred to as ‘the delivering a Development Management
regulations’). The Welsh Ministers have the Service in Wales;
ability to set these regulations under Section
• To model FCR in a range of potential
303 of the Town and Country Planning Act
scenarios;
1990.
• Undertake ‘global’ calibration of the model
Previous work carried out by the Welsh Local
to help ensure total-cost remains constant
Government Association (WLGA) and the
across scenarios, application profiles and
Planning Advisory Service (PAS) has found
workload levels;
that overall the current system for calculating
fees is too complex and that there is a need • To engage with key stakeholders e.g. the
to reform the current fee regulations, both in Planning Officers Society Wales (POSW)
terms of the cost of individual applications, in defining FCR and testing model
and the way in which the current regulations scenarios.
are structured. The research undertaken covers all of Wales
Arup has been commissioned by the Welsh and considers potential changes to planning Wales Millennium Centre, Cardiff
Government to undertake research to inform fees under three scenarios.
improvements to planning fees and this The remainder of this report sets out the
report presents the findings. The Arup team steps taken by the project team to achieve
that has worked on this research is herein the above objectives.
referred to as ‘the project team.’
January 2021 5
Cost of Delivering a Development Management Service in Wales Welsh Government Stakeholder Engagement The Working Group At the project outset a Working Group was feedback on the scenarios and the key established to help inform the research. The themes emerging from the model findings. Working Group was comprised of Heads of At the first meeting, the Working Group also Planning from several local authorities in suggested further engagement with POSW. South East Wales, as nominated by POSW, as well as representatives from industry Planning Officers Society Wales bodies including the WLGA and the Royal Representatives of POSW have played an Town Planning Institute (RTPI). important role in providing input into and An initial Working Group meeting was held in advice on the data request which was sent to November 2019. The purpose of this meeting all Local Planning Authorities (LPAs) in Wales was to introduce the project and to carry out in March 2020. Further details in relation to an initial activity and discussion focused on the data request is provided later in this Working Group 1 – Sample Activity Sheet defining full cost recovery. report and at Appendix A. Based on the feedback received at this Focused meetings between the project team meeting, FCR for the purposes of this and the POSW Chairs were held in January research relates to recovering the costs of all and February 2020. The purpose of these activities associated with delivering a meetings was to agree the content and Development Management service, which format of the data request to be issued in includes planning enforcement, work carried acknowledgement of the resourcing out in relation to appeals, and input from pressures within LPAs and the limited time specialist Council officers into planning available to gather large amounts of data. decisions. The data collection exercise is described in A second meeting with the working group further detail later in this report. was held in November 2020. At this meeting, Working Group 2 – Meeting Agenda the project team shared the model and invited the Working Group to share their January 2021 6
Cost of Delivering a Development Management Service in Wales
Welsh Government
Approach to the Research
Key Stages
The diagram below sets out the key project milestones built into the approach to the research:
2. Building the
Model
4. Testing the
Model
• Adding existing
• Analysis of existing
data to the • Final issue of
model. • Defining • Test runs of the model and
data and identifying modelling modelling
strengths as well as • Making the
assumptions scenarios and accompanying
any data gaps. and method calibration to
where required Final Report
• Data request to LPAs driven by data for their ensure (this report).
or stakeholder incorporation consistency
1. Developing a feedback. into the of outputs.
Data Set model. 5. Final Output
3. Scenarios and
Model Schema
As mentioned above, stakeholder engagement has taken place via the Working Group and direct engagement with representatives from
POSW at Key Stage 1. The second Working Group meeting took place at Key Stage 4. The remainder of this report details the activities
which have contributed to each key stage within the research.
January 2021 7
Cost of Delivering a Development Management Service in Wales
Welsh Government
Developing a Data Set
A Review of Existing Data
There is a wealth of existing data available in the existing regulations. This collaborative approach helped ensure
relation to planning application numbers in This can often be overlooked, but ‘time spent’ that the data request was both thorough, and
Wales. As such an important first stage in the is an important determinant of FCR which the as clear and easy to complete as possible.
research was to collate this extant Project Team felt should be considered.
information to understand how this could be
A further challenge was that the existing data
used, and to identify any further data
obtained from PAS did not correspond to the
requirements.
existing fee categories as presented within
Arup was provided with the following the existing fee regulations.
information by the Welsh Government:
As a result of this, the project team did not
• Development Management Quarterly have quantitative evidence as to how many
Surveys (DMQS) (2007- 2020); applications are received in each fee
• Data from the Planning Advisory Service category across Wales.
Benchmark exercise (2018); This challenge was discussed with the
• Planning Inspectorate (PINS) Planning Working Group, and it was agreed that the
Appeals data (2019). most appropriate way to address this was
This data has been used in the development through a request for information to be sent
of the model. to all LPAs across Wales.
Analysis of existing data highlighted that Notwithstanding this, LPA workload and
there were data gaps in relation to overall associated time constraints to complete an
annual fee income for LPAs across Wales, as expansive data request was duly noted.
well as information related to how LPAs are As a result, it was agreed that the
resourced and how much each type of project team would develop the data
application costs on average to determine, request in consultation with
based on the fee categories detailed within representatives from POSW.
January 2021 8
Cost of Delivering a Development Management Service in Wales Welsh Government Developing a Data Set Data Request to Local Planning Authorities A data request was issued to LPAs on 5 February 2020. As agreed with POSW representatives and the Welsh Government, the request comprised the following: 1. Time Estimates: LPAs were asked to estimate how much Officer time is spent on average for each type of application. 2. Number of Applications Validated within Each Fee Category and Total Income: LPAs were asked to record the fee and category for planning applications received by their authority over a four-week period. The purpose of this exercise was to gather ‘real time’ data from authorities so that the project team could begin to define FCR on an ‘all Wales’ basis. The original date of return was 17 March 2020. As a result of the impact of the Covid-19 pandemic and the national ‘lockdown’, this date was extended by a further four weeks. Overall 18 no. responses were received to the data request. This represents a 72% response rate although some of the data returns were only part complete. Notwithstanding this, it is considered that the primary data obtained through the request has made a valuable contribution to the model. The way in which the data has been utilised to inform the modelling is explained further later in this report. A copy of the data request issued to LPAs is provided at Appendix A. January 2021 9
Cost of Delivering a Development Management Service in Wales
Welsh Government
Building the Model
Laying the Foundations
Model Inputs Initial Estimation In order to test these estimates to help ensure
The first step required in the modelling After inputting all of the data into the model, robustness, the project team also prepared
process was working out what data should be the Project Team set out on a significant data alternative estimates of costs and fees
inputted into the model in order to work out the calibration exercise to ensure the model would arranged by LPA using the PAS data provided.
total planning fee income received across lead to robust and well rooted outputs. In deriving these initial estimates, a significant
Wales versus the costs of delivering the challenge was presented by data gaps. In
Firstly, this involved a series of estimations
development management service. In the first several incidences there was no data either
derived through the data within the model. For
instance this included the datasets as from the data request from March 2020 or
example, by combining the time estimates
previously mentioned: PAS data, DMQS data from the secondary PAS data.
data, salary data and data on working hours
and the primary data derived from the data provided by the LPAs, the project team was In attempting to overcome this, the project
collection exercise with LPAs in March 2020. able to make an estimate on the initial cost per team considered a range of options. It was
In consideration of all the data collated as part application for each application type within the found that there was a very positive
of the project, data parameters were set existing fee structure. correlation between population data at local
specifically in relation to salary data and authority level and the PAS costs data (0.84)
Similarly, fee income across each application
additional costs that were common across as well as between population data and PAS
type was estimated using the fee data and
Planning Departments in Wales e.g. postage fees data (0.87). This was a significant finding
data on application
and publicity for applications. as it meant that population data could be used
numbers received through the data request. to interpolate estimates where there were
As explained on page 8, whilst LPAs were gaps within the model, ensuring that an all-
only asked to record these figures over a four Wales picture could be achieved as set out
week recording period, through the use of within the research objectives.
DMQS data (which records application
volume) we were able to extrapolate these
figures to individual fee estimates by
application type across one year.
January 2021 10Cost of Delivering a Development Management Service in Wales
Welsh Government
Building the Model
Laying the Foundations
Initial Estimation cont. Recalibration
In order to ensure the basis of the model was as robust as possible, After completing the initial estimations, a large scale recalibration
several sensitivities were tested prior to the settling on a set of overall process was undertaken. This involved re-calculating fees and costs
figures. per application and combining the overall estimates with the data
For example, median fees and costs values across all Wales LPAs obtained by LPAs from the data request. In addition, the project team
were tested alongside the central approach, which consisted of using undertook an exercise to re-scale ratios of application types provided
the mean. The central approach proved to be more robust, hence the directly by LPAs against the DMQS over a four year period. The
median approach was discarded. purpose of this was to obtain fees and costs estimates on a per
application type basis rather than as an overall figure across all
The model showed that the estimates had elicited a robust set of
applications in order to be able to determine different proposed fee
figures, which illustrate the overall annual fee income of planning
changes across the 56 existing application types within the regulations.
departments versus the costs associated with delivering their
development management services. Notwithstanding this, prior to By combining the re-scaled fees, costs and application volumes a final
beginning the scenario modelling, the data was put through a detailed estimate of overall fees and costs at a pan-Wales level was derived.
recalibration process in order to fortify the estimates further.
January 2021 11Cost of Delivering a Development Management Service in Wales Welsh Government Building the Model Research Assumptions and Limitations Research Assumptions The key assumptions informing the model are as follows: • Time estimates, salary data and working hours have been based on the survey sent to LPAs as set out on page 8. The project team assumed most entries to be accurate and amended a few significant outliers. All data returns are confidential and not for publication. • The project team has ensured that the salary data available accounts for overheads. • The overall cost estimates presented in the model have been derived using a combination of primary data obtained through the data request from LPAs and PAS data. Machynlleth Station, Powys • To help ensure additional departmental costs related to postage and publicity are accounted for, these have been incorporated into the model at a rate of £100 for major applications and £10 for all other application types. Whilst it is recognised that in reality these figures will vary with each application, an assumption was made for the purpose of modelling. • The geographic assumptions as described on page 9, have been obtained using official data sources (ONS and StatsWales). • The model does not suggest that any changes are made to existing ‘exemption’ categories within the regulations but these have been accounted for. January 2021 12
Cost of Delivering a Development Management Service in Wales Welsh Government Building the Model Research Assumptions and Limitations Limitations of the Research Overall however, it was not possible for the study to account for such As with all research, there are limitations largely based on the difference particularly in consideration of the brief which was focused availability of data, timescales and resource. on the simplification of planning fees in Wales. It should be noted that the purpose of this research was not to It should also be noted that overall there was a general agreement compare the incomes and efficiencies of individual planning amongst Working Group members that a move towards simplifying authorities across Wales. Rather, the research seeks to provide a planning fees i.e. reducing the number of categories would be a Wales-wide picture of potential amendments to planning fees. preferable approach to creating further complexity. Part-way through the research programme, was the onset of the COVID-19 pandemic and first ‘national lockdown’. The extended deadline for returns to the data request fell during this period and as a result the level of return may have been impacted as LPAs grappled with urgent, unforeseen priorities. Notwithstanding this, as presented on page 8 the data request elicited a good response rate. During the research programme, in July 2020, the Senedd approved a general increase of 20% to all planning fees, amending the current fee regulations. In addition, upper limits to caps and fees were increased by approximately 4%. Given the advanced stage of the research at this time, the model is based on the fee regulations in place prior to the abovementioned amended regulations being introduced in August 2020. Finally, the project team acknowledges that there are some application types within which there is considerable variation. For example, one of the most challenging categories to account for was ‘Applications for the Variation or Removal of a Condition’ i.e. Section 73 applications given the degree of difference within submissions. January 2021 13
Cost of Delivering a Development Management Service in Wales
Welsh Government
Scenarios
Developing Model Scenarios
The following modelling scenarios were developed in consultation with the Welsh Government. The scenarios were selected in order to
present a range of potential options for potential planning fee reform in Wales and this is described in more detail in the next sections of this
report.
Scenario 0 Scenario 1 Scenario 2 Scenario 3 In addition to the adjacent
Business as Usual ‘Cost Recovery Simplified Charging Extremely Simplified Scenarios 2 and 3 have
Schedule Charging Schedule each be split into two ‘sub-
scenarios’ as follows:
This is a ‘calibrated’ Based on the existing Based on an amended Based on an extremely
version of the current and simplified fee 1. A “standard” version
fee structure with fees simplified free structure.
situation structure using actual (i.e. assuming LPAs
redistributed to reflect Applications split
Based on current costs. Applications split receive a fee for all
actual costs within each across the following
application numbers, fee across the following received applications)
fee category simplified fee
distribution and income simplified categories: 2. A “performance-
categories:
1. Reserved Matters related” version (i.e.
Householders
2. Householders assuming a proportion
Minor – Dwellings
3. Housing – Minor of all received
Minor – Land
4. Housing – Major Minor – Buildings
applications is not
5. Agriculture – Minor Major – Dwellings
determined in time and
6. Agriculture – Major thus no fee is received
Major – Land
7. Industrial by the LPA).
Major – Buildings
8. Other – Buildings Other – Buildings
9. Other – Fixed The scenarios and the
Other – Fixed
10. Other – Land results from the modelling
Other – Land
are presented in more
11. Exemptions Exemptions
detail later in this report.
January 2021 14Cost of Delivering a Development Management Service in Wales
Welsh Government
Scenarios
Developing Model Scenarios
Scenario 0/1 – Business as usual and Cost the land for which the application was being categories were not the right fit for the data after
Recovery submitted, with a couple of additional categories all. Thus, this led to two key changes; firstly,
Prior to exploring what potential there is for which are clearly defined. both of the above ‘Industrial’ categories were
changes to the existing planning fee structure it This methodology led to the following simplified merged into one single category, and
is important to first understand the status quo. categories, which were subsequently agreed additionally, the ‘Other’ category was split into
That is why the first step of the project team’s with the Welsh Government: three. This created the following 11 categories,
analytical work consisted of modelling ‘Scenario which still present a large degree of
1. Reserved Matters
0’ i.e. the current fee structure. simplification when compared to the existing fee
2. Householders
regulations:
This was followed by Scenario 1, which shows 3. Housing – Minor
by how much the fees of each of the 56 4. Housing – Major 1. Reserved Matters
application categories would have to change to 5. Agriculture – Minor 2. Householders
achieve FCR on an application-by-application 6. Agriculture – Major 3. Housing – Minor
basis. This means essentially ending the 7. Industrial – Minor 4. Housing – Major
current cross-subsidy between different 8. Industrial – Major 5. Agriculture – Minor
application categories. 9. Other 6. Agriculture – Major
10. Exemptions 7. Industrial
Scenario 2 – Simplified Charging Schedule
8. Other- Buildings
One of the key research objectives was to 9. Other – Fixed
The subsequent modelling work consisted of
explore simplification of the categories given the 10. Other – Land
producing estimates of the required fee
current fee structure presents a significant level 11. Exemptions
changes based on combining the data available
of complexity and has many caveats.
for each of the 56 categories in Scenario 1. This
The project team set out to undertake this task was primarily done by using weighted averages Overall, it is considered that the above set of
by first rationalising the overall number of fee which brought the different categories together rationalised categories worked well to inform
categories by bundling related categories whilst acknowledging the greater volume of Scenario 2 in consideration of the data available
together. To do this, the approach was taken of applications of certain categories over others. and following a logical approach to simplifying
grouping categories based on the end use of the existing categories.
This work revealed that some of these
January 2021 15Cost of Delivering a Development Management Service in Wales
Welsh Government
Scenarios
Developing Model Scenarios
Scenario 3 – Extremely Simplified Charging Schedule dwellings or acres of land.
The purpose of Scenario 3 was to generate a set of categories that Therefore, this combination proved to be unrealistic and unachievable
would lead to an extremely simplified planning fee structure. From the and the project team was concerned that pursuing this option further
outset, it was clear that this was a complex task and its achievability would not add value to the overall research.
was uncertain. Notwithstanding this, it provided an interesting test case Notwithstanding the above, the project team did still want to explore the
as to how far the existing fee structure may be able to be altered and it potential for ‘extreme simplification’.
could be tested further at the modelling stage.
To this end, it was decided that, by splitting down some of these
Originally, the extremely simplified categories agreed with the Welsh categories, it would still be possible to create a scenario with fewer
Government were: specificities within scenarios compared to Scenario 2.
1. Householders Thus, Minor, Major and Other were split into three categories each,
2. Minor according to the unit of measurement used in the variable fee.
3. Major
This led to the following 11 categories comprising Scenario 3:
4. Other
5. Exemptions 1. Householders
2. Minor – Dwellings
These categories were derived on the basis of attempting to bundle the 3. Minor – Land
greatest number of Scenario 0/1 categories into each group to reduce 4. Minor – Buildings
the number of fee categories as much as possible, whilst retaining 5. Major – Dwellings
some degree of relatedness between the rationalised categories. The 6. Major – Land
modelling stage revealed that there were great disparities between the 7. Major – Buildings
categories bundled into several of these groups, particularly pertaining 8. Other – Buildings
to the way in which variable fees are calculated. 9. Other – Fixed
10. Other – Land
This is because some of the categories in Minor or Major, for
11. Exemptions
instance, would be based on different units, such as number of
January 2021 16Cost of Delivering a Development Management Service in Wales Welsh Government Scenarios Developing Model Scenarios Scenarios 2b and 3b – Performance Related Versions From the outset of the project, it was agreed with the Welsh Government that the project team would explore the feasibility of generating a sub-set of Scenarios 2 an 3 which would contain the same categories but present different proposed figures, accounting for the fact that LPAs do not necessarily receive a fee for all applications processed. These so-called ‘performance-related’ scenarios have been built using DMQS data which suggests that ca. 8% of all applications received by LPAs are either withdrawn or not decided within the given timeframe. Therefore, the proposed fee increases in these scenarios are moderately higher than those in Scenarios 2 and 3. January 2021 17
Cost of Delivering a Development Management Service in Wales Welsh Government Testing the Model Scenario Modelling The results of the model scenarios are shown in full in Appendix B. The summaries below present the key findings from each of the scenarios and the implications of these results are discussed in further detail on page 22. Scenario 0/1: Scenario 0, the ‘business as usual case’ and Scenario 1 ‘cost recovery’ are presented as one in the model output. Overall, the scenario shows that in order for development management services in Wales to achieve FCR, increases to planning fees would be required across almost all existing fee categories. Generally the fee increase required is more marked in relation to ‘minor’ planning applications. For example, the model suggests that householder applications would have to increase from a £190 fixed fee to a £475 fee (a 150% percentage increase) . In the case of full applications for more than 50 dwellings the model suggests a fee increase of 25% would be required. As can be viewed in Appendix B the model also considers potential variable fee rates for categories which have variable fees within the existing regulations. Utilising variable fees allows for more flexibility in the way in which fees are set. Regarding proposed maximum fees, these have been derived by uplifting the analogous scenario 0 figures by the same % change as the fixed or variable fees. Scenario 2: Scenario 2 considers the potential for a simplified fee structure organised under 11 fee categories as presented on page 9. The way in which the existing fee categories have been consolidated can be viewed in Appendix B. Given the consolidation of fee categories, the model presented a challenge in terms of the unit which should be used within variable fee categories (e.g. £X per ha, £X per dwelling etc.). In order to overcome this, an analysis of each of the variables of the scenario 0 categories which make up the scenario 2 categories was conducted. Through this exercise, it became evident that it was necessary to form scenario 2 categories by grouping scenario 0 categories which presented the same units. This approach was therefore followed when putting together scenario 2. Overall within the simplified fee structure presented in scenario 2 the necessary fee increases required in order to achieve full cost recovery are slightly less pronounced that in Scenario 1. The highest increase required would be across minor application categories, the largest being the ‘Minor -Land’ category (200%), followed by householder applications (175%) and ‘minor –land’ and ‘minor buildings’ (both 125%). The lowest percentage increase is proposed within the ‘other- building’s category at 25% January 2021 18
Cost of Delivering a Development Management Service in Wales Welsh Government Testing the Model Scenario Modelling Scenario 3: As presented in Appendix B, given the extreme simplification of the existing categories within Scenario 3, the proposed fee increases in order to achieve cost recovery, are much less pronounced than within Scenario 1. The proposed fee increase has been set at 50% across all categories, with the exception of the ‘other’ category within which the fee increase proposed is 125%. Similarly, to scenario 2 consideration was paid to potential variable fee categories and how these rates could be measured in consideration of how the existing fee categories have been consolidated Scenarios 2b and 3b: these scenarios present the same category structure as scenarios 2 and 3, respectively. The only difference is that, in scenarios 2b and 3b, consideration has been given to applications which are withdrawn – meaning that LPAs are required to do the work to process them but do not receive a fee in return. An evidence-based assumption has been made that ca. 8% of all received applications are withdrawn. Thus, the proposed fee changes in these scenarios reflect the need to recover an additional amount in fees due to withdrawn applications. January 2021 19
Cost of Delivering a Development Management Service in Wales Welsh Government Testing the Model Presenting the Scenarios The outputs from each of the model scenarios are presented in Appendix B of this report. The image overleaf presents a snapshot of Scenario 1 as presented within Appendix B. It pulls out key aspects of the scenario outputs to assist readers in their analysis. In particular it should be noted that in each scenario the figure shown in the ‘required fee change’ column differs from the figure presented in the ‘proposed fee increase’ column. This is because whilst the model at the outset endeavoured to present FCR on an application-by- application basis, as the outputs progressed it became clear that an element of cross-subsidy between applications would be required in order to create a consistent and more realistic output. The ‘proposed fee increase’ column takes the model findings and proportions proposed increases on a more incremental basis across different fee categories. This was carried out using professional judgement on the basis that the project team also wanted to ensure that there was a level of consistency and usability within the scenarios. As a result, the decision was taken to use rounded figures for increases rather than drilling down into more complex percentage figures. The proposed scenarios still present what would be required to achieve FCR on an all- Wales basis with fairly limited cross-subsidy, particularly when compared to the current situation. January 2021 20
Cost of Delivering a Development Management Service in Wales
Welsh Government
Testing the Model
Proposed fees based Scale of required fee change is pulled
Presenting the Scenarios Existing fees based directly from model findings
on fee regulations on model outputs
Blank cells unable to
be modelled due to
lack of available data
Cells shown in grey are those
where there is no existing
category within the current fee
regulations i.e. there is no
maximum fee
Proposed fee increases are
considered holistically
against other categories in
order to create consistency.
January 2021 Model Scenarios – Readers Guide 21Cost of Delivering a Development Management Service in Wales Welsh Government Key Themes Emerging from the Model For Consideration LPAs in Wales currently do not achieve full With additional data it may be possible to Notwithstanding this, it is helpful to understand cost recovery explore potential for fee changes further, what this ‘extreme’ simplification could look like An important first point to note is that the particularly in consideration of potential and the resultant impact that there would be modelling undertaken clearly demonstrates simplification of the existing regulations. on planning fees. that costs incurred by Development Increases required in minor application The model also highlights the difficulties in Management services in Wales currently categories trying to simplify a complex existing structure outstrip income. It is however important to note Across all three scenarios, a pattern emerges particularly around determining how variable again that the model does not account for the that suggests there is a requirement for larger fee rates should be organised and this is an 20% planning fee increased approved in July increases across minor application categories, area which requires further consideration. 2020 and in consideration of this, the proposed which currently do not recover the costs Performance Dependent Fee Structure increases presented within the model would be incurred by LPAs in determining them. The model explores the potential for a slightly less pronounced if this was Anecdotal data from meetings with the performance dependent fee model, however incorporated. This must be considered when Working Group reinforces these findings and this may provoke further debate as to whether using the model to inform any changes to feedback received has suggested that these this approach is implementable and whether or planning fees in Wales. types of applications take more resource to not such measures should form part of wider Data recording determine than the income received. holistic changes to planning processes in This research highlighted gaps in data Simplification of the existing fee schedule Wales e.g. fast track application schemes etc. recording of planning fees across LPAs and at Scenarios 2 and 3 demonstrate how the which is beyond the scope of this particular a Wales wide level. A recommendation existing fee schedule as presented within the research. emerging from the research would be to regulations could be simplified. As mentioned The purpose of this study is not to create a establish regular reporting of overall fee previously, the Working Group generally new fee schedule and as such how the income to planning departments in Wales. agreed that simplification of planning fees findings of this research are translated into Another potential consideration in terms of would be beneficial although there was a policy and legislation is for the Welsh data would be tracking of resource expenditure consensus that perhaps ‘scenario 3’ takes this Government to determine in collaboration with in terms of Officer time spent on applications. too far. key stakeholders. January 2021 22
Cost of Delivering a Development Management Service in Wales Welsh Government Key Themes Emerging from the Model For Consideration Recommended Fee Structure Therefore, the recommended fee structure planning professionals and the general In addition to the considerations presented proposes a set of fees that more closely public. on page 16, the project team has also match the cost of processing each of the 56 However, this would need to be balanced developed an overall recommendation to the application types whilst retaining a small level carefully with the intention to ensure accurate Welsh Government as to how the planning of cross-subsidy. cost recovery. This would be aided by the fee structure could evolve and improve in the Whilst requiring legislative action, it is regular reporting of overall fee incomes and future. This recommendation is presented at acknowledged that this approach would tracking of resource expenditure, which this Appendix C. require limited change and disruption to the report recommends. The recommended fee structure is to existing planning system at a time of great With additional data in the future, there would progress with Scenario 1, which is based on uncertainty (e.g. associated with Covid-19 be potential for greater changes, particularly the existing fee structure with fees and Brexit). in consideration of the potential simplification redistributed to reflect actual costs within It is however acknowledged that a bolder of the existing regulations. each fee category. vision for a planning fees reform could yield We recommend that this is undertaken in the The recommended structure would help significant benefits. medium to longer term, to help reduce the ensure that more minor fee categories such In particular, a simplification of the structure risk of the Covid-19 pandemic distorting as householders and discharge of conditions similar to that proposed in Scenarios 2 or 3 2020/2021 data. applications achieve full cost recovery in would help streamline the planning process On balance, therefore, Scenario 1 is at this consideration of the model findings that and facilitate the participation of private time considered to be the most appropriate increases in fees are particularly required for individuals and organisations with no prior recommendation on the basis of the data minor application categories. planning experience in the process. available. In light of this, a low level of cross-subsidy Feedback from the Working Group in relation The findings of this research provide a has been considered to be acceptable due to to this research suggests across Planning foundation for the Welsh Government to the greater capacity of larger applications to Departments in Wales there could be support consider improvements to planning fees in absorb an increase in planning fees for the simplification of the current fee Wales in both the short and longer term. compared to minor applications. regulations to improve accessibility both for January 2021 23
Cost of Delivering a Development Management Service in Wales Welsh Government Conclusion Next Steps By way of conclusion, the Cost of Delivering a Development Management Service in Wales research shows that increases to planning fees would be required in order for Local Planning Authorities in Wales to achieve full cost recovery, across all application types. The research also demonstrates the complexities of simplifying the existing fee schedule, but notwithstanding this, also provides some ‘food for thought’ in terms of what a consolidation of planning fees in Wales could look like. The recommendations made within this report and the findings of the modelling as presented in the Appendices will now be for the consideration of the Welsh Government, in collaboration with key stakeholders. Any changes to the current planning fee regulations would have to be made through changes to legislation. Consideration should also be had to the ongoing work being undertaken by the Law Commission in codifying planning law in Wales to see what Burry Port Harbour, Carmarthenshire implications and synergies there may be between this work and the outcomes of this research. January 2021 24
Contact: Kieron Hyams Ove Arup & Partners Ltd. 4 Pierhead Street Capital Waterside Cardiff CF10 4QP We shape a better world | www.arup.com
Snowdonia National Park
The Cost of Delivering a Development Service in Wales • Welsh Government Appendix A Data Request as issued to Local Planning Authorities (February 2020) January 2021 27
RESEARCH INTO THE COST OF DELIVERING A DEVELOPMENT MANAGEMENT SERVICE IN WALES - LPA DATA REQUEST
Thank you to both your authority and to the Planning Officers Society for Wales (POSW) for supporting this Welsh Government research. Arup has been commissioned to model planning
application fees in order to model a range of fee structures and any resulting changes in fees to reach full cost recovery. To do this, we need from you up-to-date information on the profile
of planning applications within each current fee category and the related fee income from these applications.
We would like your administration/validation team(s) to record all planning applications received by your authority over a 4 week period and to categorise these into the relevant fee
category. A 'tally sheet' has been provided, should you wish to use it, to help keep a record as applications are processed.
At the end of the 4 week period we would like you to record (in the table below) the total number of applications received in each fee category, the total income received from these
applications and the number of these applications which attracted the maximum fee.
You can begin the 4 week recording period at any time however we would ask that all responses are emailed to us by the 17th March 2020.
PLEASE ONLY COMPLETE CELLS SHADED GREEN. Please return completed forms by email to Emmeline Reynish at emmeline.reynish@arup.com. Queries may also be send to this
email or you can telephone 02920 266688.
Name of Authority
Name of Officer making this return
Email address
Phone Number (direct)
Time period covered (date start and date end) (this should be four full calendar weeks) From: To:
Return deadline: TUESDAY 17 MARCH 2020
Planning Application Numbers
Number of Total FEE No of
applications INCOME MAXIMUM
RECEIVED received (£) FEE
CODE DESCRIPTION applications
A OUTLINE APPLICATIONS
1 Not more than 2.5ha
2 More than 2.5ha
B HOUSEHOLDER APPLICATIONS
3 Alterations/extensions to single dwelling including works within boundary
C FULL APPLICATIONS
4 Alterations/extension to two or more dwellings, including works within boundaries
5 New dwellings (up to and including 50)
6 New dwellings (for more than 50)
Full applications - Erection of Buildings (not dwellings, agricultural, glasshouses, plant nor machinery)
7 Increase of floor space (no more than 40m2)
8 Increase of floor space (more than 40m2 but no more than 75m2)
9 Increase of floorspace (more than 75m2)
Full applications - Erection of Buildings (on land used for agriculture/agricultural purposes)
10 Site area of no more than 465m2
11 Site area more than 465m2 but not more than 540m2
12 Site area more than 540m2
Full applications - Erection of glasshouses on land for the purposes of agriculture
13 Site area not more than 465m2
14 Site area more than 465m2
Full applications -Erections/alterations/replacement of plant and machinery
15 Site area not more than 5ha
16 Site area more than 5ha
Full applications- applications other than building works
17 Car parks, service roads or other accesses
Waste (use of land for disposal of refuse or waste materials or deposit of material remaining after extraction or storage of materials)
18 Site area not more than 15ha
19 Site area more than 15ha
Operations connected with exploratory drilling for oil or natural gas
20 Site area not more than 7.5 hectares
21 Site area more than 7.5 hectares
Other operations (winning and working of materials)
22 Site area not more than 15ha
23 Site area more than 15ha
24 Other operations (not coming within any of the above categories)
D LAWFUL DEVELOPMENT CERTIFICATE
25 Existing use or Operation
26 Existing use or Operation - lawful not to comply with any condition or limitation
27 Proposed use or operation
E PRIOR APPROVAL
28 Agricultural and Forestry buildings and operations or demolition of buildings
29 Telecommunications Code Systems Operators
F RESERVED MATTERS
30 Application for removal or variation of a condition following grant of planning permission
31 Application for approval of reserved matters following outline approval
G CHANGE OF USE
32 Change of use of a single dwelling to be used for two or more dwellings (not more than 50 dwellings)
33 Change of use of a single dwelling to be used for two or more dwellings (more than 50 dwellings)
34 Change of use of a building for 1 or more separate dwellings (not more than 50 dwellings)
35 Change of use of a building for 1 or more separate dwellings (more than 50 dwellings)
36 Other material change of use (of a building or land)
H ADVERTISING
37 Relating to the business on the premises
38 Advance signs which are not situated on or visible from the site , directing the public to a business
39 Other advertisements
I APPLICATION FOR A NON-MATERIAL AMENDMENT
40 Applications for householder developments
41 Applications in respect of other developments
J FEES FOR DISCHARGE OF CONDITIONS
42 Applications for householder developments
43 Applications in respect of other developments
K EXEMPTIONS
44 For alterations, extensions etc. to a dwellinghouse for the benefit of a disabled person
45 An application solely for the purposes of providing a means of access for disabled persons to or within a building or premises to which members of
the public are admitted.
46 Listed Building Consent
47 Conservation Area (CA) Consent
48 Works to Tree covered by a TPO or in a CA hedgerow removal
49 If the proposal relates to works that require planning permission only by virtue of an Article 4 direction
50 If the application is for a lawful development certificate, for existing use, where an application for planning permission for the same development
would be exempt from the need to pay a planning fee under any other planning fee regulation
51 If the application is for consent to display an advertisement following either a withdrawal of an earlier application (before notice of decision was
issued) or where the application is made following refusal of consent for display of an advertisement, and where the application is made on behalf
of the same person.
52 If the application is for consent to display an advertisement which results from a direction under Regulation 7 of the Control of Advertisements
Regulations 1992 dis-applying deemed consent under Regulation 6 to the advertisement in question.
53 If the application is for alternative proposals for the same site by the same applicant, in order to benefit from the permitted development right in
Schedule 2, Part 3, Class E of the Town and Country Planning (General Permitted Development) Order 1995 .
54 Revised applications following withdrawal, refusal, or non-determination which qualify under the terms of Regulation 8 (the 'free go' )
L CONCESSIONS
55 Applications submitted on behalf of Town and Community Councils
56 Applications made on behalf of a club, society or other organisation (including any persons administering a trust) which is not established or
conducted for profit and whose objects are the provision of facilities for sport or recreation including the making of a material change of use to the
land as a playing field or the carrying our of operations for purposes ancillary to the use of land as a playing field (other than the erection of a
building)
Please include an comments/clarifications you wish to make here:
Type here…RESEARCH INTO THE COST OF DELIVERING A DEVELOPMENT MANAGEMENT SERVICE IN WALES - LPA DATA REQUEST
Thank you to both your authority and to the Planning Officers Society for Wales (POSW) for supporting this Welsh Government research. Arup has been commissioned to model planning application fees in
order to model a range of fee structures and any resulting changes in fees to reach full cost recovery. To do this, we need from you up-to-date estimates of the average staff salaries and estimates of how
much time is spent on each type of application.
Time estimates should be from validation through to the issue of a decision notice (and should not include pre-application advice or monitoring compliance, but will include legal time on S106). You can
provide your time estimate as you wish, so you could type 7.25 hours in the hours column, or 1 day in the day column (but not both if you only mean one day in total). For larger amounts you can provide a
total in a combination of days and hours if that is helpful. For example if an officer or officers in a category spend a total of one and a half days, this could be entered a 1.5 days, 1 day and (say) 3.5 hours or
(say) 10.75 hours. PLEASE ONLY COMPLETE CELLS SHADED GREEN.
We understand that DM roles/grades will vary across authorities, as such for the purpose of this research we have split time between key job roles. In order to provide some guidance on how you define these
roles we have asked for an average gross salary band for each position. The 'gross salary' figure should include overheads such as National Insurance etc.
We have also asked for an annual lump sum figure for your department's central costs which would include for example budget spent on Committees, IT etc. All of this information will help us better define full
cost recovery.
Please note that all responses will be kept confidential and will only be used for the purpose of this study. WE ARE USING THIS TO PRODUCE AN 'ALL WALES' ESTIMATE - AND NOT TO COMPARE
LPAs. PLEASE BE HONEST WITH YOUR ESTIMATES AND GIVE US 'ACTUALS' WITHOUT WORRYING ABOUT PERFORMANCE. The purpose of the 'cost recovery' approach to fees is to set them at
a level that recovers costs.
Please return forms by email to Emmeline Reynish at emmeline.reynish@arup.com. Queries may also be sent to this email or you can telephone 02920 266688.
Name of Authority Specialist advice includes INTERNAL LOCAL AUTHORITY support such as (but is not limited to) legal
Name of Officer making this return support/S106/CIL, arboriculture, architecture, conservation, ecology, education, environmental health,
Email address flooding, highways, housing, landscape, leisure, minerals, planning policy, rights of way, urban design,
viability waste etc. It's intended as 'non-DM' time but we know that team structures vary.
Phone Number (direct)
To calculate the average specialist advice gross salary, please take the highest salary point for officers
Return deadline: TUESDAY 17 MARCH 2020 involved, with your estimate the combined average of those. (This avoids you needing to find out salary
Average Technical Assistant/Planning Support Officer Gross Salary (£) information of those outside your team as you can use their salary grade level instead.) If you're not
Average Planning Officer/Planning Assistant Gross Salary (£) sure, get in touch with us.
Average Senior Planning Officer Gross Salary (£)
Average Team Leader Gross Salary (£) We only expect you to estimate based on your experience of what you think it takes to determine an
'average' application. Our experience suggests that LPAs tend to under-estimate the time taken to
Average Manager/Principal Planning Officer Gross Salary (£)
process individual applications so please consider your responses carefully. You might find it easier to
Average Chief Planning Officer/Service Head (or equivalent) Salary (£) review the form with a colleague.
Average Specialist Advice Gross Salary (£)
Average working day (hrs) 7.25
Average total time to determine an 'average'
application across all staff involved
Technical Planning Officer / Senior Planning Team Leader Manager / Chief Planning Specialist
Assistant / Planning Assistant Officer Principal Officer or
Planning Support Planning Officer equivalent
DaysOffi Hours Days Hours Days Hours Days Hours Days Hours Days Hours Days Hours
CODE DESCRIPTION
A OUTLINE APPLICATIONS
1 Not more than 2.5ha
2 More than 2.5ha
B HOUSEHOLDER APPLICATIONS
3 Alterations/extensions to single dwelling including works within boundary
C FULL APPLICATIONS
4 Alterations/extension to two or more dwellings, including works within boundaries
5 New dwellings (up to and including 50)
6 New dwellings (for more than 50)
Full applications - Erection of Buildings (not dwellings, agricultural, glasshouses, plant nor machinery)
7 Increase of floor space (no more than 40m2)
8 Increase of floor space (more than 40m2 but no more than 75m2)
9 Increase of floorspace (more than 75m2)
Full applications - Erection of Buildings (on land used for agriculture/agricultural purposes)
10 Site area of no more than 465m2
11 Site area more than 465m2 but not more than 540m2
12 Site area more than 540m2
Full applications - Erection of glasshouses on land for the purposes of agriculture
13 Site area not more than 465m2
14 Site area more than 465m2
Full applications -Erections/alterations/replacement of plant and machinery
15 Site area not more than 5ha
16 Site area more than 5ha
Full app
17 Car parks, service roads or other accesses
Waste (use of land for disposal of refuse or waste materials or deposit of material remaining after extraction or storage of materials)
18 Site area not more than 15ha
19 Site area more than 15ha
Operations connected with exploratory drilling for oil or natural gas
20 Site area not more than 7.5 hectares
21 Site area more than 7.5 hectares
Other operations (winning and working of materials)
22 Site area not more than 15ha
23 Site area more than 15ha
24 Other operations (not coming within any of the above categories)
D LAWFUL DEVELOPMENT CERTIFICATE
25 Existing use or Operation
26 Existing use or Operation - lawful not to comply with any condition or limitation
27 Proposed use or operation
E PRIOR APPROVAL
28 Agricultural and Forestry buildings and operations or demolition of buildings
29 Telecommunications Code Systems Operators
F RESERVED MATTERS
30 Application for removal or variation of a condition following grant of planning permission
31 Application for approval of reserved matters following outline approval
G CHANGE OF USE
32 Change of use of a single dwelling to be used for two or more dwellings (not more than 50 dwellings)
33 Change of use of a single dwelling to be used for two or more dwellings (more than 50 dwellings)
34 Change of use of a building for 1 or more separate dwellings (not more than 50 dwellings)
35 Change of use of a building for 1 or more separate dwellings (more than 50 dwellings)
36 Other material change of use (of a building or land)
H ADVERTISING
37 Relating to the business on the premises
38 Advance signs which are not situated on or visible from the site , directing the public to a business
39 Other advertisements
I APPLICATION FOR A NON-MATERIAL AMENDMENT
40 Applications for householder developments
41 Applications in respect of other developments
J FEES FOR DISCHARGE OF CONDITIONS
42 Applications for householder developments
43 Applications in respect of other developments
K EXEMPTIONS
44 For alterations, extensions etc. to a dwellinghouse for the benefit of a disabled person
45 An application solely for the purposes of providing a means of access for disabled persons to or within a building or premises to which members of the public are
admitted.
46 Listed Building Consent
47 Conservation Area (CA) Consent
48 Works to Tree covered by a TPO or in a CA hedgerow removal
49 If the proposal relates to works that require planning permission only by virtue of an Article 4 direction
50 If the application is for a lawful development certificate, for existing use, where an application for planning permission for the same development would be exempt from
the need to pay a planning fee under any other planning fee regulation
51 If the application is for consent to display an advertisement following either a withdrawal of an earlier application (before notice of decision was issued) or where the
application is made following refusal of consent for display of an advertisement, and where the application is made on behalf of the same person.
52 If the application is for consent to display an advertisement which results from a direction under Regulation 7 of the Control of Advertisements Regulations 1992 dis-
applying deemed consent under Regulation 6 to the advertisement in question.
53 If the application is for alternative proposals for the same site by the same applicant, in order to benefit from the permitted development right in Schedule 2, Part 3,
Class E of the Town and Country Planning (General Permitted Development) Order 1995 .
54 Revised applications following withdrawal, refusal, or non-determination which qualify under the terms of Regulation 8 (the 'free go' )
L CONCESSIONS
55 Applications submitted on behalf of Town and Community Councils
56 Applications made on behalf of a club, society or other organisation (including any persons administering a trust) which is not established or conducted for profit and
whose objects are the provision of facilities for sport or recreation including the making of a material change of use to the land as a playing field or the carrying our of
operations for purposes ancillary to the use of land as a playing field (other than the erection of a building)You can also read
