Here in West Norfolk the planning process is like so many things in Norfolk, as large parts of it are done differently from elsewhere, mostly for reasons that are a lot less than clear and obvious. When describing some of the behaviour in West Norfolk as “quaint” to people familiar with planning matters from other counties they inquired how I spelt “quaint”, as in their opinion it should be spelt “bent”.
It is not healthy to describe the West Norfolk planning processes as bent. My belief is that they are misunderstood, much as in the same way as Saddam Hussain’s policies were misunderstood. For the most part there is a similarity to good practice. It is only in certain areas where one detects divergences; usually where money is involved or where careers are at risk. These financial divergences impact primarily on the collection and disbursement of development related funds. The career threatening divergences are linked proportionately on the quantity of new homes that can be dumped on West Norfolk and to the amount of work the salaried officials are obliged to do in relation to planning applications.
Planning officials are only human beings when all is said and done. They have similar motivations to the rest of us. What is wrong with a featherbedded job, easy working conditions, a healthy salary and a gold-plated final salary based pension scheme? Obviously, if these jobs are put at risk, it is normal to react and try to protect the situation. It is also normal for the senior managers to want to minimise such threats, because their remuneration packages are influenced directly by the number of people they have reporting to them and the size of the budget under their control. In other words the more people and the more it costs the tax payer, the more money the senior managers earn and the bigger their pension pot. This is an evaluation based on the Hay scale that allocates points for a range of measurables. A cynical interpretation is that to maximise earnings one needs to employ lots of people, control a large budget and have a complicated sounding job – or in other words be massively inefficient and spend too much with a pompous job description.
The current threat is from central government, because the planning officials in West Norfolk and elsewhere are failing to deliver enough new housing and missing their targets. At a presentation recently in King’s Lynn the poor planning officials were almost crying into their tumblers of over-chlorinated water at the prospect of losing their jobs to officials appointed by the Inspector. Actually, they would not lose their jobs, as there will still be a lot of basic paperwork to be provided to the Inspector, but their jobs will become even easier. Something else was explained and this was the new sifting process to filter out planning applications that do not really require submission to the full Planning committee for debate in Chamber, in order to lighten the load on the planning department. By the way, it is strange that there are still targets for Norfolk when they have been dropped in many other parts of the country. Maybe this is something else that is different for Norfolk.
What these planning officers really love is large-scale developments of hundreds of homes that go towards achieving targets more quickly. The effort for a few hundred units is not much more than that for a small development of a dozen houses. With all the sites in West Norfolk that have been discussed over the last couple of years there is no risk of missing targets that are based on passing new planning applications. The target for new homes is in the region of 650 a year apparently, but then we hit another problem in terms of converting the planned quantity into completed deliveries, because there is not enough capacity in the construction sector to build more than about 450.
This brings the conversation round to the phenomenon of the double counting with regards to these larger development schemes, as in the double counting of the available capacity of existing services. When the larger planning applications are submitted, the question is asked if there is enough capacity in the networks to accommodate the extra requirements for electricity, gas, water, effluent treatment, surface water run-off, etc. Similar questions are fired off sometimes about the availability of doctors, dentists, school spaces and teaching staff. Each time the question is answered, the service suppliers respond to the question in isolation, without taking into account the fact that the same question has been answered before on a few occasions. This means that the utility companies over-commit their limited services when there is a completely inadequate service in existence to cope with the hundreds of extra homes under consideration. The other dimension that is ignored in this double counting is that small scale developments are nibbling away at the available capacity while the larger developments continue to be discussed, meaning that whatever capacity might have been available ceases to be available. For Downham Market the same sparse resources have been committed several times and the same is probably true for many other communities. In some cases, such as with sewage treatment plants, the available resources are actually in the wrong physical location and cannot be used for the proposed schemes.
In addition to the multiple allocations of limited resources there is the phenomenon of impacting the resources of neighbouring communities. There is a range of planned developments that will have a disproportionate impact on the adjacent parishes from which all the services will be supplied. In these cases it is possible that Parish A will receive the mitigating impact payments through CIL and S106 because the development is within the boundary of Parish A, but the electricity and water supplies come from Parish B, the school is in Parish B, the waste and sewage treatment is handled by facilities for Parish B and Parish B receives nothing to compensate it for the extra burden.
When we talk about mitigating compensation to make new developments more acceptable, it should be noted that these negotiations tend to be held behind closed doors between the legal representatives of the developers and their counterparts in the Planning Department, with no opportunity for debate in Chamber, in contravention of the transparency requirements of the 2011 Localism Act (see below) and against the interests of the electorate. It has been identified that on many occasions the mitigating payments have been allocated in manners that are regarded widely as being unlawful and to make matters worse, some of the mitigating sums collected have never been disbursed.
Is this dishonest practice or is it simply just simple incompetence? For anyone in public office, it is usually better to confess to being less than adequately competent. Doubtless, our service providers have a different view of what has been presented, as there can be different ways to interpret the available evidence.
LOCALISM ACT 2011
A material consideration is a matter that should be taken into account in deciding a planning application or on an appeal against a planning decision.
Material considerations can include (but are not limited to):
• Overlooking/loss of privacy
• Loss of light or overshadowing
• Highway safety
• Effect on listed building and conservation area
• Layout and density of building
• Design, appearance and materials
• Government policy
• Disabled persons’ access
• Proposals in the Development Plan
• Previous planning decisions (including appeal decisions)
• Nature conservation
However, issues such as loss of view, or negative effect on the value of properties are not material considerations.