The RTPI welcomes MHCLG's Building a safer future: proposals for reform of the building safety regulatory system consultation.
However, it points out that the responsibility borne by planning professionals and others might get confused through some of the proposals. The RTPI also stresses the importance of the pre-application process as the appropriate occasion to rain key design issues, so to make the formal application process more speedy and efficient.
The RTPI highlights how the role of planning in agreeing materials in planning permission can be source of delay and wasted resources. We therefore suggests the extensive use of pre-application procedures, so to create a ""Gateway Zero"" at which relevant professional input is secured to ensure that a future planning permission would be likely to be approved and could also be built.
We also point out the risks linked to permitted development of office into residential building, even more so as the current ""Prior Notification"" procedure does not allow a thorough processing of the application.
The RTPI also agrees that Fire and Rescue Authorities should become statuary consultees for buildings in the planning permission stage of building in scope. However, it must be made absolutely clear in planning guidance and or regulations from MHCLG that if the FRA does not respond within the timescale the local authority will refuse the application. It must also be considered that this will cause an additional burden on planning departments, which will require an adequate financing. The RTPI suggest a special supplement on planning application fees for buildings over 18 meters.
The RTPI recognises the opportunity of a Fire Statement to be added to the existing Design and Access Statements. However, it should identify and be confined to clearly relevant Planning matters to be given weight in the Planning decision making process as distinct from those relevant at Gateway 2. The Best practice would be to share the information that would eventually go in a Fire Statement at pre-application stage as set out in NPPF and NPPG. Fire and Rescue Authorities should therefore respond to pre-application requests for comment.
FRA should be consulted also on applications for developments withing the 'near vicinity' of buildings in scope, with the radius defined dynamically depending on the route that fire appliance may need to take. Legacy development in scope should be mapped as constraint on GIS in LPAs so to allow to single out the application in need of FRA consultations.
The RTPI calls for a clear guidance to determine what applications prejudice emergency access to buildings in scope.
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