Civic Voice welcomes the efforts being made by the Government and the Inspectorate to streamline the planning appeal process so as to speed up decision making and reduce costs for everyone involved. In appropriate circumstances the proposed removal of the ability to comment on proposals at the appeal stage in written representation cases will be beneficial.
We are concerned, however, that in some cases this change may prevent Civic Societies and other interested parties having their concerns properly considered.
The proposed changes are to apply to almost all written representation planning appeals as the default position. The Inspectorate will retain the ability to decide that any individual case should be dealt with in the manner which is now the norm, whereby third parties can make submissions at appeal stage. However, we have seen nothing to indicate how this ability will be exercised.
In many cases, applicants submit additional information after the application is registered and made available for public comment. This may be to respond to concerns or queries raised by the Council, to add to their initial argument, or to refine their proposal. In addition, Councils often receive submissions from highway authorities, the environment agency and other external consultees before they determine applications. Third parties are often unaware of such submissions and unable to comment on them at application stage. In these cases the proposed changes to the appeal procedure could deprive Civic Societies and other interested parties of the opportunity to comment on relevant matters of which they were unaware previously and on which they have valid points to make which the Inspector should consider.
Civic Voice has requested an assurance from the Inspectorate that the extended streamlined procedure will not apply where, for any reason, changes have been made or additional information has been provided by the applicant or consultees after the application was submitted. Without these additional comments from Civic Societies and other parties, the Planning Inspector may not have a full picture of the implications of a planning application. Their absence could therefore weaken the decision making process and result in flawed decisions.