RTPI response to the MHCLG consultation on fees for planning applications
1) Do you support the proposed National Default Fee Schedule, set at 90 per cent of full estimate cost?
Yes. The RTPI welcomes the Government’s move towards full-cost recovery, noting the significant and existing gap between fee income and service costs, and the resulting shortfall for planning authorities as set out in this consultation. This correlates with the RTPI’s own research in our recently published State of the Profession 2025 report, which identified a 9.6% reduction in spending in development management services since 2010 in England. The need to address such a shortfall needs to be contextualised alongside an anticipated increase in demand for planning services, and modelling by the Local Government Association (LGA) on projected cost pressures for local government projected an increase in spending of 6.2% on planning and development services between 2024/25 and 2026/7.
The RTPI particularly welcomes the proposals considering the provisions set out in the Planning and Infrastructure Act 2025 (PIA) to ensure that fee income is reinvested into the development management functions of a planning service.
The setting of a National Default Fee Schedule will complement the local fee-setting powers introduced by the PIA by ensuring local planning authorities (LPAs) can move towards full cost recovery but prevent a potential ‘race to the bottom’ in areas aiming to attract investment. The RTPI is clear that areas trying to attract inward investment need support to do so, but this should not come at the expense of effective and high-functioning planning services. Indeed, when planning services are working well, with sufficient resourcing, they are a critical factor in attracting inward investment.
Whilst we support the need to drive efficiencies through innovation, including the use of digital tools and streamlined processes, there is a clear need for a comprehensive programme of skills development and training for planning services across the country, especially during the upcoming transition period as planning teams adjust to reforms. This includes targeted support for development management teams as they consider the imminent new rules-based approach to decision-making as applications are submitted. This skills and training programme needs to consider the range of new assessments, tests and policy requirements, guidance and national standards as set out in the proposed draft National Planning Policy Framework (NPPF). This would include, for example, new approaches to viability assessments or life-time carbon assessments, as well as potentially expanding to cover areas like wildfires or military affordable housing.
Beyond putting in place long-term measures to improve the financial sustainability of development management services, the RTPI strongly recommends that solutions be found for the long-term financial sustainability of planning policy teams within England. Our State of the Profession report identified that since 2010, planning policy teams have been disproportionately affected by funding cuts of 28.8%. Whilst we acknowledge the £14 million funding announcement in 2026 to support local authorities with local plan-making, this is significantly below the level of estimated funding needed to support planning policy teams.
The end goal of these reforms is a better resourced and more efficient planning system, whereby planning authorities have the capacity to deliver a good service and applicants benefit from high-quality and timely decision making.
The government acknowledges in the consultation text that applicants will be willing to pay increased fees if they consider that the service they are paying for works well. To this end, the Institute considers that an increase in planning fees should be accompanied by a performance framework that includes planning authority reporting and rigorous measures to address performance issues.
2) Are there any proposed fees in the National Default Fee Schedule that you consider to be unrepresentative of 90 per cent of estimated full cost levels for LPAs (either too low or too high)?
No comment.
3) Do you support the proposed changes to the fee structures for outline, full and reserved matters applications for residential and non-residential development as set out in the proposed National Default Fee Schedule?
See our response to question 1.
4) What further changes, if any, do you think should be made to the structure of fees for outline, full and reserved matters applications?
While we consider that a banding structure may be sensible (and could be based on a version of the PS1 and PS2 categories), it would be difficult to apply a universal approach here, given that site characteristics may not be fully known at application submission stage. We would also point out that the planning performance agreements (PPA) system already works to consider site characteristics, and the knock-on impact on planning authority resources, to agree bespoke fees for large scale projects.
5) Do you support the proposed changes to the fee structures for applications for agricultural development as set out in the proposed National Default Fee Schedule?
See our response to question 1.
6) Do you support the proposal that PiP applications should attract a flat fee for two bands?
- PiP applications for developments of up to 9 dwellings
- PiP applications for developments of 10 to 49 dwellings
A flat fee for developments of up to nine dwellings could work, but the scope of variation across developments between 10 and 49 dwellings can be significant, and a flat fee would not sufficiently account for this.
7) Do you agree with the proposed fee level for PiP applications for:
(a) developments of up to 9 dwellings - £825?
(b) developments of 10 to 49 dwellings - £3,150?
No comment.
8) Do you think the three-band fee structure currently used for section 73 applications remains appropriate?
No comment.
9) Should section 73 and section 73B applications be charged using the same fee structure?
No comment.
10) Do you think the fee for discharging conditions should be charged per condition rather than per application?
No comment.
11) Should applications for the approval of biodiversity gain plans be subject to a separate fee to reflect the specific work involved?
No comment.
12) Do you have an alternative suggestion on how the fee structure for discharge of conditions could be improved?
No comment.
13) Do you support the proposal to apply a flat fee of £310 for all other existing prior approval applications that are currently free of charge as well as the proposed prior approval under Class B of Part 15 (if brought forward)?
See our response to question 1.
14) Do you agree with the proposed fee for CAAD applications of £964?
See our response to question 1.
15) Do you support the introduction of a new national default fee for section 106A applications?
See our response to question 1.
16) Are there any other existing fee categories not mentioned above that you believe would benefit from restructuring?
No comment.
17) Do you agree with our working proposal that the planning fee surcharge should be in the region of 10 per cent of the national default fee (subject to further policy development and consultation)?
The RTPI has long called for a more sustainable funding model for statutory consultees, alongside a more comprehensive audit of their resourcing and capacity. The RTPI agrees with the principle of a planning fee surcharge to find significant and sustained means of funding statutory consultees to undertake their work, noting the provisions within the PIA 2025 introducing powers to levy a surcharge on planning fees to support national statutory consultees.
How the surcharge is to be split amongst consultees will need careful consideration. It is also important that that the administration of such a surcharge does not in itself become a significant burden on local planning authorities. In a similar manner to provisions in the PIA 2025 aimed at the reinvestment of planning fees, the RTPI would wish to ensure that that any fee income derived from a surcharge would be reinvested into the planning services of statutory consultees and not cross-subsidise other parts of the service.
It is difficult to comment on the appropriate level of any surcharge without a fuller understanding of the resourcing context for statutory consultees and their workloads with respect to local authority development management functions. To appropriately contextualise the surcharge proposals, a comprehensive audit of statutory consultees resourcing, capacity, and performance is necessary.
Similarly, in line with our response to question 1, the RTPI is concerned about the performance of plan making teams, and we would like to see consideration of how statutory consultees can be effectively resourced to contribute towards local plan preparation. Furthermore, statutory consultee involvement with the pre-application and application process should be LPA-led and integrated, rather than a separate process.
18) Do you have any comments on how local fee setting will operate? In particular, is there any additional information that you would wish to see covered through guidance?
The RTPI broadly supports the key principles set out for local fee setting but would reiterate the need for increased and sustained support for plan-making teams.
Additionally, regarding principle number 8 (Local fees should be reviewed regularly), the frequency of fee reviews should be specifically defined.
Regarding points 2 and 3 under ‘Calculating costs’ (in-house and external specialist advice), we would welcome some clarity around whether LPAs with local fees accounting for in-house or external expertise are able to also apply the statutory consultee surcharge.
19) Do you think local fee variations should be capped? If so, what level would be appropriate - 15 per cent, 25 per cent of the national default fee, or another figure?
No comment.
20) In the context of localised planning fees, what are your views on the future role of PPAs, pre-application advice and other discretionary charging regimes?
We agree that PPAs can still play a valuable role for larger and more complex schemes, but they should act as a bespoke service that supplements the core planning functions.
It is important that pre-application, application fees, and PPAs are cost recovery only, and it might be that as the system moves towards cost recovery, the need for PPAs to fund the ‘core service’ is lessened. The government should continue to monitor this area as these proposals progress.
21) Do you have any views on how the proposals in this consultation might affect you, the group or business you represent, or others – particularly those with protected characteristics? If so, please explain who might be affected and how. Is there anything that could be done to mitigate any impact identified?
No comment.
