The RTPI champions the power of planning in creating prosperous places and vibrant communities. As learned society, we use our expertise and research to bring evidence and thought leadership to shape planning policies and thinking. As a professional body, we have over 27,000 members across all sectors, and are responsible for setting formal standards for planning practice and education.
Q.1. Do you agree that the build out reporting measures should apply to developments which involve the building of new dwellings (including mixed use development)?
Yes/no/don’t know.
Yes, the RTPI believes that build out reporting measures should apply to all developments that involve the building or conversion of new dwellings. This would better ensure the improved collation and sharing of data relating to build out rates which could integrate and enhance the process of producing annual monitoring reports proposed as a part of the new-style local plans (LPs). Looking at the range of proposals more broadly the Institute urges Government to further consider the proposals including those relating to Development Progress Reports and the associated Delayed Homes Penalties.
Q.2. Are there any other types of residential development that the build out measures should apply to? If yes, please give your reasons.
Yes/no/don’t know.
As discussed in response to Q1, the build out rates should apply to all forms of new dwellings to ensure a consistent and robust approach to data collection. This would include all development types included in proposals for mixed tenure thresholds as set out in the corresponding working paper.
Q.3. Do you agree with the proposed threshold of 50 dwellings for the build out measures to apply to?
Yes/No/Don’t know. Please give your reasons.
This very much depends on the nature of build out measure proposals. We agree that requirements from planning applications need to be proportionate to the scale of development and support the Governments intentions to reduce barriers and accelerate delivery for SMEs. As expressed in response to the corresponding working paper, the RTPI is concerned that the proposed system of development progress reports, alongside the Delayed Homes Penalty, could manifest as a significant resource burden, for both LPAs and developers, negatively impacting upon SMEs in particular.
However as set out in response to Q1, we believe the elements of proposals that could bring most benefit to the current system relate to the better collation and sharing of build-out rate data. To do so would require build out measures to apply to all residential development types. In many authorities, especially in rural contexts, a significant amount of development coming forward would sit within or below this threshold. Therefore, how housing land supply and delivery would be monitored efficiently and accurately in such locations would require further consideration.
Q.4. Do you think a higher threshold should be set for development progress reports and the power to decline to determine applications? If so what should this threshold be?
Yes/No/Don’t know. Please give your reasons.
As set out in response to Q3, the nature of the measures proposed relating to development progress reports, the power to decline to determine applications and the Delayed Homes Penalty will need to be clearly set out in order to understand the appropriate proportionately for different scales of development. Furthermore, the ability to share data relating to build out rates across development types, as discussed in response to Q3 remains a key consideration for the RTPI.
Q.5. Do you agree that this information should be covered in the build out statements?
Yes/No/Don’t Know. If not, please explain why you disagree and set out any other information you think it should cover
Whilst the RTPI recognises the intentions to bring together information in a clear and concise manner, identifying potential risks and issues at the planning application stage could be complex. The additional process of applying conditions to identify any changes to projections set out in the build out statement prior to the commencement of the development may add further complexity, delay and duplication of efforts. As set out in response to q(e) of the working paper there would be a strong incentive for developers to be pessimistic to avoid potential penalties which may be disputed by the LPA. Potential conflict scenarios like this could make it hard to discharge conditions and potentially add delays to commencement.
The role of a land promoter in applying for outline permission has not been made clear in the consultation, as they would have to factor in the time it will take them to secure a developer and timescales to submit a reserved matter application.
Q.6. Do you have any further comments on the build out statement?
No further comment.
Q.7. Do you agree that this information should be covered in commencement notices?
Yes/No/Don’t Know. If not, please explain why you disagree and set out any other information you think it should cover
Consideration needs to be given to large multi-phase schemes, with an ability for commencement of different phases to be recorded. Difficulties again may be encountered at outline application stage where the tenure mix may not be known. There may be a duplication of process with CIL commencement notices, so ideally both would be consolidated into one procedure.
Q.8. Do you agree with setting a 2 month period after the reporting period ends to submit the development progress reports?
Yes/No/Don’t Know. If not, please explain why you disagree.
We considered that 28 days would be sufficient. However, to support this, digital planning should be harnessed to create clear standardisation of information requirements and format to ensure an efficient and robust reporting process.
Q.9. Which option for the reporting period for development progress reports do you agree with?
We support the lead option prescribing an annual reporting period based on the financial year. However, a 28 day deadline for submission would also be necessary to fit with LPA reporting.
Q.10. We recognise the information in development progress reports may be useful for LPAs to calculate 5 year land supply (5YLS), are there any impacts with the reporting periods proposed and the interaction with 5YLS?
We would seek clarity on how such reports would dovetail with the local plan monitoring reports but see great benefit in the better exchange of information in this regard.
Q.11. Do you agree with the proposals for how the completion date is specified for the purposes of development progress reports?
Yes/No/Don’t Know. If not, please explain why you disagree.
Yes, an application for a completion certificate submission is the most reasonable way to demonstrate completion, however this would require very clear guidance on how completion dates are calculated, to ensure that a consistent methodology is applied across the country.
Q.12. Do you agree with the proposals about who submits the development progress report?
Yes/No/Don’t Know. If not, please explain why you disagree.
Yes, however the RTPI is aware that there may be complexities when there are multiple developers involved in delivering different parts or phasing of a scheme.
Q.13. Do you agree with the information it is proposed development progress reports will cover?
Yes/No/Don’t Know. If not, please explain why you disagree.
Yes, however consideration needs to be given to how the reasons for delay can be mapped against a national set of exemptions. In order to achieve a clear and consistent approach to the preparation of development progress reports the RTPI would urge the Government to considered issuing of mandatory templates. Clarity may also need provided if there have been any variations in the permission.
Q.14. Is there any other information you think development progress reports should cover?
The RTPI believes that, to improve transparency and accountability, development progress reports and associated information should made public through regulations.
Q.15. Do you have any views on how a joint approach to submitting a commencement notice could be facilitated on sites where multiple developers are involved?
Joint reporting may be difficult and in terms of providing better accountability, the RTPI would wish to see the exploration of the merits of a system whereby different developers at different phases submit reports against the parts of the scheme they are responsible for. Clarity on how self-build would be treated in this scenario would be helpful.
Q.16. Do you agree with making provisions in the regulations that would enable a joint submission of the development progress report where multiple developers are involved?
Yes/No/Don’t Know. If not, please explain why you disagree.
No further comment.
Q.17. Do you agree that this information should be covered in development progress reports where a joint approach is taken?
Yes/No/Don’t Know. If not, please explain why you disagree and set out any other information you think it should cover
No further comment.
Q.18. Do you have any views on what information other than in build out statements and development progress reports LPAs should have regard to when considering whether the carrying out of the earlier development has been unreasonably slow?
Please give your reasons.
Considering any relevant infrastructure funding statements would be beneficial, especially as local authorities can use them to report on the delivery and provision of infrastructure.
Q.19. Do you have any comments on the scope of the guidance?
Considering any relevant infrastructure funding statements would be beneficial, especially as local authorities can use them to report on the delivery and provision of infrastructure.
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