RTPI response to MHCLG consultation on streamlining infrastructure planning

RTPI response to MHCLG consultation on streamlining infrastructure planning

Consultation questions

Pre-application: guidance for applicants preparing applications

1. Please provide views about the potential risks and benefits of government producing more prescriptive or less prescriptive guidance about pre-application consultation and engagement in absence of statutory requirements. In particular, we are interested in views on how guidance on engagement can support an efficient, faster, proportionate and effective NSIP process or whether doing so risks undermining the potential time and cost savings.

The RTPI considers that any approach to producing guidance for any involved party in the NSIP regime should focus on clarity and delivering  certainty, so that applicants, consultees, examining authorities, local authorities, communities, and other stakeholders understand what is expected of them, what is reasonable and proportionate, and what matters can be influenced and are relevant to the preparation and examination of NSIPs. In this manner, guidance should distinguish between communication, consultation, and engagement and how they should be applied to provide a more streamlined pre-application process.

There have been, and continue to be, many examples of high-quality engagement and communication for infrastructure projects. It remains essential that good, meaningful, proportionate engagement is still a core part of the NSIP regime. The guidance for pre-application consultation should be informed by data on engagement and effectiveness of approaches, and the time taken to implement them. Overall, changes to the NSIP regime should prioritise meaningful communication and outcomes, rather than processes, and should not introduce additional steps and complexity to what is already a very complex and resource-intensive system.

More prescriptive engagement guidance may result in a more rigorous standard baseline for engagement standards, improving certainty and consistency across the country. This may lead to better outcomes including buy-in from communities, and a more focused, meaningful examination process. Yet, there is a risk that such guidance could simply replicate the statutory requirements it replaces, adding complexity without delivering improvements.

However, given the wide variety and scope of different NSIPs, a more prescriptive approach could be overly rigid and unsuitable for all types of projects, thereby stifling innovative and tailored approaches to engagement.

In Wales in particular there is a lack of resource and capacity to support the development industry within public sector bodies. Managing these constraints by recruiting necessary staff, addressing skills gaps or hiring consultants is something that also takes time and reduces the capability of bodies to properly and effectively engage within varying timeframes. This can lead to a potential ‘silence is acceptance’ approach that does not reflect high-quality engagement. While the removal of prescriptive pre-application guidance could provide the opportunity to speed up engagement processes and reduce application timelines, it should not be done at the risk of excluding specific consultees from engaging effectively in the planning process.

 

2. Should guidance note that collaboration outside of the NSIP process can help to address wider challenges that could otherwise impact development proposals? If so, what should it say?

The RTPI believes that guidance should capture collaborative efforts that identify the key impacts of the development proposals, while noting that these might vary depending on the project and infrastructure type. 

A careful balance needs to be struck between ensuring that stakeholders have the necessary information available to make prudent decisions, while also making sure the amount of information applicants are required to provide isn’t excessive or superfluous to the consenting process.

For the NSIP process to function effectively, public sector bodies need to be resourced and have access to necessary systems and skills. The government’s support of charging a fee for relevant services is important in supporting LPAs and statutory bodies but is not the direct solution due to a lack of specialist skills. Guidance could seek to support these bodies in identifying the resourcing necessary to ensure preparedness proposals, helping to evidence business cases for additional staff and income funding that may be required.

 

3. Would it be useful for applicants to consider these factors while preparing their applications and in particular in relation to any non-statutory engagement and consultation (at paragraph 19)? What changes or additions to these draft factors would you welcome?

 

• Prioritise front-loading, so applications are well-developed by the time they are submitted and provide the right information for the Planning Inspectorate to determine whether the application is suitable to proceed to examination, and are capable of being accepted and progressing through the regime within statutory timescales.
• Proportionate, so that applicants can identify and understand issues that must be explored, addressed and decided during the NSIP process to enable the application for consent to be determined. If consultation and engagement is undertaken with communities, landowners, local authorities and statutory bodies, it should be done in a way that is proportionate to these aims, considering the nature and complexity of the proposal while ensuring infrastructure can be decided and, where consent is granted, developed in a timely manner. While informal, light-touch engagement may be sensible, multiple rounds of non-statutory consultation should be avoided.
• Open and transparent, with applicants being clear about their proposals and the timescales they are working to, and considering how accessible and understandable their documents are. If they consult and engage, they should be clear on the matters on which they are seeking views and which people can influence, and how responses will be taken into account in progressing the proposal.
• Timely, so that applications progress to reasonable timeframes and informal engagement and consultation is timed to benefit the applicant’s overall programme for their proposed development, giving proportionate levels of detail and sufficient time for consideration and response.

 

Yes/No/Don’t know, with room for comment

 

Prioritise front loading

Yes, to an extent. Whilst we support the front-loading of applications, this needs to be sensitive to the stage of the application, in line with the Rochdale Envelope approach, and be cognisant of the other principles. Front-loading of applications should not come at the expense of a process that is also proportionate and timely. To this end, the government needs to communicate clearly which information is essential to the initial stages of an application, depending on the type of project.

Proportionate

Yes. Guidance should be clear that requirements throughout the consenting process are proportionate, and relevant to the particular stage of the process, to ensure quality outcomes are achieved in a timely manner.  

Open and transparent

Yes. Guidance would benefit from the inclusion of the word accessible alongside openness and transparency. Although project details may not be finalised at the consultation stages, applicants should ensure that stakeholders are clear about the process, how a project progresses, and where and how they can meaningfully contribute. Where possible, applicants should refrain from using technical jargon to be as inclusive as possible.

While we support the need for transparency, this should not come at the expense of accessibility. The key elements of the project should be presented clearly and accessible to improve the way in which non-experts can engage with the process.

Timely

Yes. We agree with this principle, but consideration should be given to the resources, skills and associated costs needed to achieve this. However, timeframes need to be clear and realistic, allowing all stakeholders to plan effectively and to avoid costly delays for applicants.

 

4. Do you agree guidance should set out at a high level the benefits of non-statutory engagement and consultation? Are there any benefits not listed which we should include?

 

Yes/No/Don’t know, with room for comment

Yes, the guidance should reflect on how benefits can change at different stages of the process. For example, engagement and communication should occur continually through the consenting process to ensure transparency at all stages However, the nature of this guidance needs to be tailored to the specific stage(s) of the proposal, as with the potential benefits.

 

5. Should guidance encourage collaboration between applicants, stakeholders and statutory bodies? If so, what should it say? We particularly welcome views on how collaboration and prevent delays and the role for the sector to work collaboratively with stakeholders and how government can support this.

As noted in our response to question 4, whilst we absolutely support collaboration between applicants, stakeholders, and statutory bodies, the level of collaboration will change depending on the stage of the proposal and needs to be appropriately resourced and focussed on outcomes. Consultation and engagement exists on a spectrum and at various levels. It is important to keep this in focus and be transparent as to what type of consultation and engagement is taking place and what level it falls within.

 

Pre-application: the role of different stakeholders and statutory bodies at pre-application

6. Should guidance include advice to local authorities, statutory bodies and applicants on finding the right balance between engaging early and engaging with sufficient technical information without creating unnecessary delay? We would also welcome comments on whether and how guidance could encourage applicants, local authorities and statutory bodies to work together to most effectively manage resources in their engagement.

Yes. Guidance should be clear in setting out level of engagement and technical detail from pre-application into acceptance and examination and beyond, what information is considered necessary and proportionate at each stage, to inform meaningful engagement and decision making.

 

7. Is guidance needed to support applicants to identify which statutory bodies should be consulted based on the potential impacts of the proposed application? If so, what should that guidance include?

 

Yes, if it is produced in line with considerations over what information is necessary at each stage, and cognisant of potential changes to the statutory consultee system elsewhere in the planning system. It should also identify where to find relevant information, examples and criteria of engagement for statutory bodies.

 

8. Would additional government guidance on engagement with statutory bodies regarding environmental requirements be of value, in addition to the advice and guidance provided directly by those organisations? How can guidance support constructive engagement by statutory bodies? Please provide details on what would be most useful in government guidance relative to what is provided to other relevant organisations.

Yes/No/Don’t know, room for comment

Yes, but the RTPI believes that environmental requirements should be framed in terms of desired outcomes, to ensure that it remains useful and focused. We would like to see the impending Environmental Outcome Reports (EORs) support this key area of the process from pre-application through consenting and into delivery.

The approach to remove statutory pre-application requirements for onshore wind application above the threshold in England, which falls under TCPA applications, introduces more consistency to the English planning system. However, more thought needs to be given to the risk of misalignment with the Welsh planning system, including the emerging Infrastructure Consent Regime. For example, with the differing approaches to pre-application consultation, further clarity is needed on how to ensure the DCO regime can exist seamlessly in both the Welsh and English planning system.

 

9. Is guidance needed to support proportionate, effective and constructive engagement from both the applicant and local authorities? If yes, what should such guidance cover?

Yes. This guidance should prioritise certainty, and how proportionate, effective and constructive engagement can achieve good outcomes.

 

10. Is guidance needed to encourage applicant engagement with landowners and affected persons in a proportionate, effective and meaningful way? If so, we would welcome views on how guidance should support engagement with landowners and affected persons.

Yes. In line with the approach to engagement set out in our previous answers, guidance should set out what proportionate, meaningful, effective engagement looks like and how applicants can engage with affected parties early.

Whilst engagement and communication with landowners and affected persons needs to be proportionate, it should also be ongoing and continual. They should be made aware of how the project will impact them, for how long, and their relevant rights and responsibilities.

 

11. Should guidance support applicants to identify Category 3 people to be notified once an application is accepted for examination? If so, what should it say?

Yes, and where possible, this should relate to the impact assessment of the application and likely significant residual effects and be considerate of the geographical areas within scope of this assessment.

 

12. Is guidance needed to encourage applicant engagement with communities in a proportionate, effective and meaningful way? If so, what should it say? We would also welcome thoughts on how guidance can provide clarity and support engagement by communities.

Yes. There needs to be clear guidance on how the Gunning Principles should be met. Continual application of proportionate, effective and meaningful engagement and communication is vital to the success of infrastructure projects. Communities should be made aware of how they will be affected, and for how long, and if this changes throughout the development of the proposal. This will require the applicant to provide sufficient information, communicated in a clear way.

As in our previous responses, a careful balance needs to be struck between giving communities enough information while also ensuring that the requirement on applicants is proportionate. Overall, guidance should have regard to effective outcomes rather than focusing on prescriptive steps, to avoid engagement becoming a tick box exercise.

Pre-application: guidance and documents to support acceptance, examination and decision

13. Should guidance continue to encourage applicants to use tools such as Issues and Engagement logs, and Principal Areas of Disagreement Summary Statements? Please comment on the value and scope of these documents for informing likely examination issues in light of the removal of statutory requirements for consultation. We also welcome views on any potential advantages or disadvantages for enabling a more effective examination if regulations required some of these documents to be submitted alongside an application.

 

Yes/No/Don’t know, room for comment

Don’t know. As set out in our response to question 1, a fundamental tenet of new guidance is that it provides as much clarity as possible around what proportionate and meaningful engagement looks like, through the pre-application, acceptance, examination, consent and delivery stages of the process.

In doing so, there may be opportunities to consolidate and declutter the process, for instance through amalgamating the Issues of Common Ground and the Principal Areas of Disagreement Summary Statements.

Removing statutory requirements in favour of guidance should not result in applications failing to get through the acceptance stage because there is a lack of clarity over what is acceptable. Therefore, guidance should consider how the use of these tools will feed into the assessment and engagement at the acceptance, examination and decision stages, noting that there needs to be consistency in how the quality of engagement is judged at each stage.

 

14. Are voluntary evidence plans an effective way of getting input on environmental issues early to inform environmental assessments and identify suitable mitigations? Please provide reasons.

Yes/No/Don’t know, room for comment

Don’t know. As recognised in the consultation, there are certain circumstances where the use of voluntary evidence plans may be beneficial.

 

15. Should guidance set out the circumstances in which use of voluntary evidence plans might be beneficial?

Yes/No/Don’t know, room for comment

Whilst the RTPI understands that setting out such circumstances would be helpful, this may be complex and beyond the reasonable expectations of what such guidance can cover.

 

16. If guidance were to highlight the option to publish an engagement summary report, what might the potential advantages and disadvantages of this be? We would also welcome views on submitting this report alongside an application, especially what advantages and disadvantages there may be for a more effective examination if guidance encouraged or regulations required submission.

An engagement summary report could form part of the ongoing, effective communication surrounding an infrastructure project. It is important that consulted parties are made aware of how they can input into a project, what areas of the project they can influence, and the outcomes of this.

It is unclear if this engagement summary report would be for the benefit of stakeholders, or for the examining authority to assess at acceptance or examination stage. We are keen that changes to the consenting regime do not result in the production of more documents that duplicate information provided elsewhere by applicants and that they have an effective purpose.

 

Pre-application: enhancing notification and publicity

17. Do you agree that requiring the following information in notifications to the Planning Inspectorate, host local authorities, and the Marine Management Organisation would be beneficial in enabling them to prepare for examination? What other information or documents could be encouraged through guidance? Please give reasons.
    • Where the most up-to-date information is published and available to view

Yes/No/Don’t know

Yes.

• When notifying the Marine Management Organisation, whether a proposed application is expected to require a marine licence for any licensable activities

Yes/No/Don’t know

Yes.

• Publishing the notification on the applicant’s project website

Yes/No/Don’t know

Yes.

• Publishing the notification on the applicant’s project website

Yes/No/Don’t know

Yes.

• Other - please provide your views. 

No comment.

 

18. Should guidance indicate a point at which the applicant should issue the notification? If so, at what should it say?

Yes/No/Don’t know, room for comment

Don’t know. Any produced guidance should be aware of the risks of notifying stakeholders too late, and the benefits of early meaningful engagement focussed on outcomes. Notifying stakeholders too early, when the project is at options stage, risks preventing relevant bodies from providing useful input. At the same time, notifying stakeholders too late in the process might mean that bodies such as the Planning Inspectorate or host authorities are not able to support and plan for the project effectively.

 

19. Do you agree that a specific format with contents requirements, would be beneficial to standardise this duty for both the applicant and the Planning Inspectorate when ensuring that this Duty has been met (please specify why)? We would also welcome views on what further guidance may support this clarity.

Yes/No/Don’t know, room for comment

Consistency is good, as long as it can be implemented in a way that does not stifle innovation or progress and can incorporate the relevant information across different development types, environments and scales.

 

20. Do you agree with the proposal to move to a ‘digital first’ approach by only requiring information to be made available for inspection online? Please explain why. The government would welcome information and data about any potential impacts, including equalities impacts, of this change.

Yes/No/Don’t know, room for comment

Don’t know. We are supportive of the NSIP consenting process making use of innovative digital approaches, where possible, if these provide easily accessible and clear information on projects. We are, however, concerned that such information may be inaccessible for people lacking digital access, as well as training on digital methods. The RTPI would encourage the government to carefully consider how applicants should be cognisant of the communities and resources in the locality of a project and communicate relevant information to those populations.

 

21. What further guidance would support applicants to undertake effective publicity which enables transparency and public awareness?

Guidance should encourage clear, accessible language, translations, use of visual and VR aids and other methods that may be more accommodating to those with disabilities, and proactive outreach (e.g. community events, local media). It should also promote transparency about how feedback will be used.

Acceptance: changes to the acceptance test

22. What further advice is needed though guidance to ensure sufficient clarity about the test that will be applied by the Planning Inspectorate at the acceptance stage, and how applications can be prepared that will meet the acceptance test? What guidance if any should be provided to provide clarity about matters that are not tested at acceptance, in order to clearly establish the difference between past and future requirements?

We are aware that the government have reconsidered their proposed amendments in this area of legislation and the intention is to maintain the current application acceptance test.

Guidance on consistency of approach and expectation in the acceptance process for the Planning Inspectorate would be welcomed to ensure transparency, clear expectations on what is required and equity.

Including approaches to early corrections and response to S51 advice early in the process to ensure all matters to be examined are available to all at the earliest opportunity and using the pre-examination period more productively would be welcomed.

 

23. How can applicants outline how they have had regard to section 51 advice from the Planning Inspectorate when they submit applications, and what should be encouraged through guidance?

We believe that a level of discretion is necessary to allow applicants to respond to key pieces of advice as they see fit and ensuring that this does not require lengthy reporting and documentation.  S51 advice needs to align with clarity, necessity and delivering good outcomes, but not stifling innovation.

Pre-examination and Examination: enabling sharper focus and stronger outcomes in the examination stage through focused IAPIs

24. What further steps should government consider to strengthen the role of the Initial Assessment of Principal Issues (IAPI), so that it supports early clarity for all stakeholders, procedural fairness, and a more focused and effective examination?

We welcome proposals to strengthen the definition for an IAPI to provide clarity on those issues that are relevant to the planning decision and those that are not. We agree with the principle that NSIP examinations should focus on the parts that matter and not get bogged down in detail which falls outside the original intention of the DCO process, whilst still maintaining a fair and open process.

To sharpen the focus of the process and create stronger outcomes, IAPIs may benefit from the rationalisation and amalgamation of other overlapping or duplicative elements of the NSIP consenting regime, such as Principal Areas of Disagreement statements.

At present IAPIs must be produced be the appointed Examining Authority within 21 days of the close of the relevant representations period.  Although these must be produced early in this process they are rarely if ever published before the Rule 6 letter notifying the date for the Preliminary Meeting.  There would be real benefit in bringing this into one set of issues with time to consider the application and representations and allowing any matters the relevant Secretary of State considers necessary to be considered and tested in Examination.

Pre-examination and Examination: supporting effective examination through guidance for public bodies

25. Do you agree that existing guidance provides enough information to aid local authorities in preparing meaningful local impact reports and should therefore retained? If further information would be beneficial to be included within this guidance, what should it say?

Yes/No/Don’t know, room for comment

No, there is inadequate guidance on what a meaningful LIR should address and provide.

The RTPI believes that any guidance produced should be clear about the purpose and scope for an effective LIR and adhere to the following principles:

• Providing clarity and certainty
• Focusing on outcomes rather than processes
• Being proportionate regarding its requirements for applicants
• Stress-tested and practitioner-orientated
• Produced in a timely manner to support infrastructure development whilst informing how local impacts should be informed and identified and any requests supported where reasonably related in nature and scale to the development and its likely effects.

 

26. Is existing guidance clear on the difference between a relevant representation, written representation and local impact report? What further information on the differences between a local impact report and relevant representation would be beneficial to assist local authorities?

Yes/No/Don’t know, room for comment

No, there is a lack of guidance on scope and differences. In practice, this area could benefit from clarification and rationalisation to assist the process and more effectively focus resources.

Guidance should clearly distinguish between relevant representations (initial positions), written representations (detailed views), and LIRs (objective impact assessments). Guidance should require that relevant representation is a ‘statement of case’ and that written representation should not widen or seek to reopen matters outside of the relevant representation.

 

27. How can guidance seek to reduce existing barriers that public authorities face in engaging with the process?

The RTPI considers that many of the barriers faced by public authorities in engaging with the NSIP process stem from a lack of capacity and resourcing. Beyond guidance, a workforce strategy is required to deliver the skills and professional services needed to effectively support reforms to the consenting regime and delivery of good outcomes.

It is important that public authorities have the resource to engage with infrastructure projects in a meaningful and impactful way, and this includes having sufficient senior staff with experience of the NSIP regime, and local leaders who can work with applicants to achieve positive outcomes at all stages of the process.

 

28. What should guidance say to ensure public authorities engage appropriately with examinations? We would welcome views on how guidance can outline the circumstances in which public authorities are relevant to the application.

See our answer to question 27.

 

Pre-examination and Examination: procedural flexibility for land acquisition amendments during examination

29. Do you consider that regulations for compulsory acquisition as part of DCOs should, where possible, limit the duplication of procedures where land acquisition changes are required and to provide the Examining Authority with greater discretion to set reasonable timeframes to reflect the specific circumstances of each DCO and its associated land acquisition issue?

Yes/No/Don’t know, room for comment

Yes.

 

30. Are there any further changes that could be made to the infrastructure planning CA Regulations and supporting guidance to contribute to the streamlining of the DCO examination process by reducing repetition or timescales where changes to land acquisition are required post submission?

Yes/No/Don’t know, room for comment

The RTPI would support changes to these regulations that ensure they are proportional, and do not set a bar that is so high as to disproportionately impact the delivery of NSIPs and necessary and beneficial changes.

Pre-examination and Examination: guidance on pre-examination and examination of applications

31. In addition to the changes highlighted in Chapter 3 of this consultation, what further changes to pre-examination and examination guidance would support efficient and effective examination of applications for development consent?

No further comment.

 

32. Are there further changes to secondary legislation - for example, the Infrastructure Planning (Examination Procedure Rules) 2010 - which you believe government should consider to support effective and efficient examinations?

The Examination Procedure Rules would benefit from streamlining and less prescription particularly on notifications and advertisement during examination once an examination timetable has been published.  There would also be benefit in moving to a more responsive examination submission process that removes duplication and repetition. The consequential paper chase that the current common submission deadlines create is partly driven by the Procedure Rules prescriptive steps.

 

Reforming NSIP Services: pre-application services

33. Is government correct in seeking to reframe the pre-application services provided by the Planning Inspectorate in this way? Are these the right objectives? Are there any additional changes to these services in light of the removal of statutory pre-application consultation that guidance should seek to clarify? We would particularly welcome reflections from developers on what factors they take into account in determining which services is most appropriate for their project.

This depends on the type of infrastructure development, as some are quite similar in practice, while others can differ quite widely. A more bespoke pre-application service would make sense to customise the process for some development types, and the government should bear this in mind as they seek to re-frame pre-application services.  Pre-application services also need to be of the highest professional standard, informing, and meaningfully engaging to ensure coordination and delivery.

 

34. What alternative models could government consider for pre-application support in order to enable better collective oversight and co-ordination of input across statutory bodies?

No comment.

 

35. What steps could government take to make the enhanced service more attractive to applicants of complex and high priority projects?

To make the enhanced service more attractive to applicants, it should focus on providing certainty and consistent, quality outcomes, rather than just aiming to speed up consenting. The speed in consenting can be delivered through the enhanced service with less risk and uncertainty by clarifying intent and outcomes.

 

36. Should guidance be more directive in setting out that, where applicants are advised that a project has been assessed by the Planning Inspectorate as being in need of a higher level of service (for reasons including project complexity and local circumstances), applicants are expected to adopt that level of service?

Yes/No/Don’t know, room for comment

No. There are significant costs and resource implications to this. The service being delivered at different levels has not yet demonstrated value for money or evidenced the delivery of meaningful outcomes, though these may emerge at later stages of the process and delivery.

 

37. Should guidance also specify that recommendations made by the Planning Inspectorate on the allocation of their pre-application services ought to be informed by considerations about whether the project or project type has been identified by government as a priority? If so, would this have any unintended consequences? Would it be important for government to be clear and transparent on what its priority projects are?

Yes/No/Don’t know, room for comment

No – see response to question 36.

 

38. Are there any changes that could be made to pre-application service offerings by public bodies?

Firstly, the Institute believes that adequate resourcing of public bodies is essential to enable meaningful engagement on infrastructure projects throughout the process. We are also aware that some applicants feel that public bodies can request excessive amounts of information to input or comment on development proposals.

These bodies need to be equipped with sufficient leadership and empowered to input into NSIPs without all the information, with an appropriate level of uncertainty, to reflect the original intention of their role in the consenting regime.

In addition, guidance should clearly set out what level of detail and information is required from applicants at the pre-application stage of the process, to give clarity and certainty to all stakeholders involved.

We would encourage any reform in this area to be supplemented by a skills development programme targeted particularly towards public bodies such as the Marine Management Organisation, Environment Agency and Natural England. This would help aid them in making decisions and inputting into infrastructure projects at each stage of the consenting process. 

 

39. Should the ability to cost recover be extended additional or all statutory bodies that are prescribed in the Planning Act 2008 and Schedule 1 to the 2009 Regulations (as amended?)

Yes/No/Don’t know, room for comment

Yes, but on a proportionate and value delivery basis aimed at the pre-application stage.

 

40. How should government develop key performance indicators for public bodies providing cost recoverable services for NSIP applications, and if so, what should those key performance indicators contain?

Yes/No/Don’t know, room for comment

Any approach to the monitoring of public bodies should be done in conjunction with performance monitoring across the planning system. The RTPI would like to see indicators that focus on more than speed of decision-making, with the inclusion of measurements around quality outcomes.

 

41. In what ways can government support local authorities as they implement cost recoverable services?

The government should consider a long-term workforce strategy and skills development programme, that seeks to provide local authorities with the expertise and skills necessary to properly engage with the NSIP consenting regime.

The RTPI has raised concerns around changes to the Level 7 Apprenticeship and has asked MHCLG for immediate intervention to support the viability of Chartered Town Planner Level 7 Apprenticeship courses. On 23 September 2025, we wrote to the Housing and Planning Minister, asking for their support in enabling our Planning Schools to continue delivering the apprenticeship for up to 400 students over the remainder of this Parliament.

As this intervention has not been made, there is an increasing need to fund an alternative provision to ensure that the number of planners entering the profession remains at current levels, and particularly to deliver the 150 nationally significant infrastructure projects committed to by the government within this parliament.

Furthermore, local authorities will be managing significant reform elsewhere in the planning system, alongside local government reform, so support through this period will be essential to ensure they can continue to function effectively in infrastructure and housing delivery as well as significant economic and decarbonisation delivery.

The NSIP centre of excellence, originally funded through the government innovation and capacity fund, would benefit from continued investment and support. Similarly, investment and support should be provided to the Planning Advisory Service and reinvigoration of the Advisory Team for Large Applications Service which should provide expert advice on NSIP delivery.

 

42. How else can government support local authorities in their role engaging with NSIP applications, as they adapt their role to take account of reforms through the Planning and Infrastructure Bill?

See our response to question 41.

 

Reforming NSIP Services: the fast-track process

43. Do you agree that there remains merit for applicants in a fast-track process, based on shortened examinations delivered through primary legislation and with the process set out in guidance, that is designed to deliver a faster process for certain projects? If yes, give reasons why it is not being used currently; if not, please give reasons.

Yes/No/Don’t know, room for comment

Don’t know.

Experience to date of the NSIP regime would suggest that efforts would be better focused on delivering the current process consistently and effectively, prioritising essential matters, rather than introducing new processes and procedures that are untried and tested.

We also retain concerns that the fast-track process does not represent value for money for applicants, with timeframes not necessarily being guaranteed. Concerns around excessive timescales are more often geared towards the pre-application and decision timescales, rather than the examination timeframe.

 

44. The current fast-track guidance designed to deliver upfront certainty for making decisions within 12 months of applications being accepted. Do you consider it fit for purpose? If not, please give reasons.

Yes/No/Don’t know, room for comment

See our response to question 43.

 

45. How do you think the existing fast-track process could be amended to support delivery of government’s priorities, and be more widely applied to applicants? We are also interested in views on how government should determine and communicate which projects it considers to be a priority for taking through the pre-application, examination and decision process.

See our response to question 43.

 

46. In what ways can government and its agencies best support applicants and relevant stakeholders to achieve robust, and faster decision timeframes during the pre-application, examination and decision process? Please indicate your views on the following potential changes, covered in this section. Please suggest practical measures, tools, or desired policy changes, and give reasons to support these.

(a) Adapting the existing process so that it supports those projects which are considered by government to be a priority for fast-tracking.

No comment.

(b) Developing an approach based on a more proactive role for government and its agencies facilitating fast-track projects through the pre-application, examination and decision process. 

No comment.

 

(c) Support priority projects to be fast-tracked, by reducing/ removing applicant choice from the decision about whether to apply a fast-track process.

No comment.

 

(d) Introduce greater flexibility by adapting the current guidance to make it clear that the priority level of the project will form part of an overall assessment about the eligibility of the project for the fast-track process. 

No comment.

 

47. Do you have any other comments or suggestions regarding the fast-track process or related policies?

No further comments.

Mandatory pre-application requirements under the Town and Country Planning Act 1990

48. Do you agree that pre-application consultation requirements under the Town and Country Planning Act for onshore wind developments should be removed? Please give reasons.

Yes/No/Don’t know, room for comment

No comment.