Ein cyf/Our ref: NICW/25/PlanResourceCon

WG50622: Promoting a resilient and high performing planning service
Planning Directorate
Welsh Government
Cathays Park
Cardiff
CF10 3NQ

E-mail: planconsultations-a@gov.wales

17^th January 2025

Dear Sir / Madam

Promoting a resilient and high performing planning service

Thank you for the opportunity to comment on the consultation paper regarding planning application fees and resources for the planning system in general.

The National Infrastructure Commission for Wales (NICW) believes that a properly funded and resourced planning function in Wales is key to unlocking investment in Wales’ infrastructure whilst also ensuring that the necessary safeguards are in place to protect the environment and make properly informed decisions that are in the best interests of communities for the long term.

We have not answered all the questions in the consultation, but have based our responses in terms of themes.

Planning Application Fees

We agree that the move to full cost recovery (FCR) should be the basis for the setting of planning application fees. We consider that the move to this should be undertaken as quickly as possible. We agree that there should be an automatic annual rise of fees based on the CPI to ensure that planning fees are kept proportionate to the costs of other goods and services, this will ensure that local planning authorities (LPAs) can budget and plan accordingly. Likewise, the development community will also be able to account for these costs.

In terms of the phased implementation approach, we do have some reservation on the need to bring in stepped changes to the fees. Planning application fees are in essence, usually, a ‘one off’ cost for developers and we question the need for this phased approach, if sufficient notice is given of the changes. We consider that LPAs have been not adequately resourced previously by fee increases and this should be rectified as soon as possible. We would urge consideration be given to speeding up these increases to ensure that the benefits from them can be realised as soon as possible.

Ringfencing of Fees

We agree that the additional income arising from proposed fee increases should be ringfenced for spending within LPA planning departments. Developers and applicants are paying for a service and that should be honoured by properly funded and responsive local planning authority departments and officers. A written commitment by the local authority (not necessarily the local planning authority, as these are different entities) would help this; however, it might be prudent to add additional clauses to the fee setting regulations which stipulate, in legislation, what the fees are to be used for.

Planning Performance Framework

NICW agrees that the Planning Performance Framework should be reintroduced in order to monitor the functions of planning authorities and to observe whether the increase of planning fees results in timely decision making by LPAs.

In terms of resilience measures it may be pertinent to include the average number of major / minor and householder applications per officer to ensure that workloads for each individual employee are comparable across LPAs. This would ensure that figures could be compared across planning authorities and benchmarking could take place.

No mention is given within the consultation document to the return of the Sustainable Development Indicators, which were part of the previous monitoring framework (see page 54 of the link).

Our recently published report on flood risk management in Wales examined this issue in detail, particularly in relation to SD4. Our report recommended that the Welsh Government should establish a new nationally consistent planning performance flood metric and new reporting framework which considers all sources of flooding. This recommendation was informed by our research workstream on flooding and land use planning by JBA Associates.

The Welsh Government are still considering their response to our recommendations. However, we would emphasise the need to monitor this situation, and the performance of local planning authorities in this area, as an indicator of how an LPA is implementing national planning policy. NICW are happy to assist the Welsh Government planning teams in this regard.

Skills, Recruitment and Retention

Throughout its current term, NICW has heard from numerous sections of built environment sectors that are struggling to recruit into posts; both in terms of resources available and the talent (both emerging and established) in the industry to fill vacancies that arise.

In order to support greater capacity and capability within local planning departments and pathways into the profession, the Welsh Government should seriously consider the introduction of apprenticeships within the planning profession. There appears to be a reluctance to consider Level 6 Degree Apprenticeships, however this would be an excellent way to give A’ level school leavers in Wales a vocational way to enter the planning profession directly.

Shared Service Delivery and Planning Skills Hubs

NICW are wholly in favour of establishing shared service delivery hubs to enable specialist technical skills to be shared over larger parts of Wales.

Recommendation 6 of 2023 report on renewable energy suggests that a ‘shared service’ be established, led by the Welsh Government or regional groups of local authorities for giving technical support on renewable energy planning policy and applications. This has already been established for the Wales Minerals and Waste Planning Service which assists local planning authorities on such matters using existing resource. It could also consider a ‘call-off’ style system where private-sector assistance is brought in, on a needs basis, to help. 

The use of these groups could boost the specialist knowledge available to local planning authorities. However, caution should be used against using these hubs to pool together officers with specialist skills which are decreasing generally within local planning authorities. Workforce planning needs to be undertaken to ensure that new officers are brought forward and trained to continue these services in the future and that the knowledge is not lost due to retirement or onward moves.

Should you require clarification on any of the above comments, please contact the NICW Secretariat: NationalInfrastructureCommissionforWales@gov.wales

Yours faithfully

Dr David Clubb                 Stephen Brooks
NICW Chair                       NICW Lead Commissioner