I’m a few months in to a part-time secondment to a local development management team and I’ve been quite surprised by the quality of the design and access statements (DAS) submitted with applications. To be brutally honest, many of the ones I’ve seen have been pretty meaningless and they’ve left me questioning the purpose of them.
It seems to be the schemes for 2 or 3 houses that are the main culprits for having DASs frustratingly short of information. Perhaps it’s because I’m much more used to the approach at Globe of combining the DAS, planning policy and summaries of any technical reports into one document. We’ve found that by presenting the information in an integrated way it’s far easier for someone looking at the application for the first time to understand the scheme and how it’s been informed by issues other than design. The sections also read discretely so consultees interested only in certain aspects of an application can easily read the bits that they need to.
Now, I’m certainly not advocating a change to the validation process to one which is much more subjective, but somehow there needs to be a shift away from DASs being written just to tick a box in a validation checklist and a few token lines presented under standard headings of amount, layout, scale, landscaping, appearance and access. There’s nothing wrong with this report structure. It is, after all, what the legislation requires (Paragraph 8 (3) of The Town and Country Planning Development Management Procedure Order 2010 for anyone who is interested) and there’s plenty of guidance out there supporting this structure. What I think is missing though is the understanding of the how valuable a good DAS can be and how it can be used by a planning officer positively right from the moment the file lands on the desk.
I’ve learnt that getting an understanding of what an application’s all about through the first scan of the file can be done much quicker if it’s spelt out clearly in the DAS. Importantly, from the applicant’s point of view, this allows key issues or questions to be identified at this point rather than further down the line, at the site visit for example (at which point the application might already be in to the 3rd or 4th week of the 8 week process). In other words, the time that would otherwise be spent on “fact finding” can be put to better use of actually assessing the proposals and raising any issues much earlier in the process. This can reduce the need for an application to be withdrawn because issues couldn’t be addressed before the target date.
The idea of spoon-feeding information to LPAs might not sit too comfortably with some given the ongoing debates about the potential increases in application fees, and some might also argue that the information is usually all there on the application form. I also appreciate that the margins for small developments are often much tighter so the need to get away with submitting the bare minimum is, in these cases, much greater. And I accept that there are cases where an “all singing, all dancing” report is just not necessary.
With players on both sides of the public/private fence feeling the pinch it’s important that we understand the pressures that each side is faced with. Simply pushing more of the onus on to the applicant without demonstrating that there is good reason won’t wash well. But if applicants and agents are persuaded to see the DAS as a sort of quasi executive summary, which covers all the relevant aspects of the scheme to a degree proportionate to the complexity of the proposals, and the case for investing in these paragraphs is presented within the context of it creating a more collaborative planning process, minimising the risk of withdrawal and the need to appeal, then I suspect there might be a willingness to provide it. Surely it’s worth a try?