The Brighton & Hove Checklist and the planning system
- How does the Brighton & Hove Checklist fit with the planning system?
- How is it integrated into regional and local planning policy?
- In major developments, is the Brighton & Hove Checklist intended for outline or full planning applications?
- Can it help speed up the planning process?
- Does it have a role in pre-application discussions?
- Doesn’t it just make extra work for the Planning Officer and Developer?
- Does the Checklist score decide whether or not planning consent is given?
- What about links to other formal assessments – eg Environmental Impact Assessments, Health Impact Assessments, Transport Impact Assessments for example?
- Does it relate to Sustainability Appraisals/Strategic Environmental Assessment?
- How does it help with the requirement for Annual Monitoring Reports?
- Can the Brighton & Hove Checklist be used by a developer where it is not required by the local planning authority?
How does the Brighton & Hove Checklist fit with the planning system?
Like the South East example, the Brighton & Hove Checklist has been designed to fit into the planning system.
Questions are directly drawn from local and regional policy and are planning matters, so they are relevant to the regulation of the development and use of land in the public interest and work towards the overall goal of sustainability as set out in the Planning and Compulsory Purchase Act 2004, PPS1, Brighton & Hove Local Plan and emerging Core Strategy policies.
Its unique monitoring system allows for qualitative and quantitative information gathered via the Brighton & Hove checklist to be fed into the Annual Monitoring Report (AMR) and relevant policy reviews.
How is it integrated into regional and local planning policy?
This can be done in two ways:
- At regional level. It can be required as part of development control applications in the South East Plan (SEP) or recommended for use by other local authorities and developers as part of its implementation plan. It can be customised by local planning authorities if required (see Tailoring the Checklist for local authorities).
- In Brighton & Hove all residential new build and conversions are required to submit a completed sustainability checklist with their applications. Other types of development are encouraged to do the same. Other local planning authorities can adopt the Checklist as a material consideration by requiring it to be filled in for applications of a particular type and size (see What sort of development can the checklist be used for?) in their Development Plan Document, then either taking it as a whole or modifying it to form an SPD or appendix to an SPD (where they wish to give more detail).
In major developments, is the Brighton & Hove Checklist intended for outline or full planning applications?
Since developers/planning applicants are increasingly putting more detail into outline applications (and local authorities are asking for more information), questions have been split into separate sets for outline and full applications as there is wide variance. Developers/Planning Applicants are encouraged to fill in the questions relating to those issues for which they are seeking outline approval (marking the others as “not applicable”, setting out which will be addressed at full application stage) and complete the remainder of the checklist at the full application stage.
Can it help speed up the planning process?
Yes. For the planning applicant, it ensures that they know what is required before the planning application is drawn up. It ensures that issues can be considered at the right point in the design process. Quality assurance systems have shown that redesign is more expensive the further down the design process, particularly where the redesign pertains to a fundamental issue such as energy systems. So the Brighton & Hove Checklist helps to avoid expensive re-work later in the design process if something has been missed out. Since the Checklist is designed to be completed by the development team, they will also know the strengths and weaknesses of their application before it is submitted and can re-appraise particular features to strengthen it, if required.
For the Development Control (DC) officer, the Checklist helps to provide sustainability information in one place, in the same format, for planning applications. The scoring overview guides the DC officer and Planning Committee Members to where follow-up or auditing may be needed.
Does it have a role in pre-application discussions?
Planning Policy Statement (PPS) 1 discusses the role of pre-application discussions. The Brighton & Hove Checklist provides a comprehensive framework for discussing the appropriate sustainability standards for particular development sites, for agreeing where good or best practice standards would be appropriate rather than minimums and for agreeing in advance which issues may not apply.
Doesn’t it just make extra work for the Planning Officer and Developer?
There is no new policy in the Brighton & Hove Checklist. It is designed to help to operationalise existing national, regional and local policy and to make requirements clear, up-front and understandable for the development team (in line with the P&CPA and PPS1). It also presents information about the application in a straightforward, easily audited and quick format for the Development Control officer and Planning Members.
Does the Brighton & Hove Checklist score decide whether or not planning consent is given?
No. This is a tool for decision makers, not a decision-making tool. It provides an overview of the sustainability performance of the development across each of the eight sections, as well as highlighting issues which have not been addressed in the application and issues for which minimum standards have not been met. It is for the Local Planning Authority, through its Members and Officers, to determine whether or not this is appropriate and acceptable for the intended development and the site on which it is located. The Checklist is designed to make this easier.
What about links to other formal assessments – eg Environmental Impact Assessments, Health Impact Assessments, Transport Impact Assessments for example?
The Brighton & Hove Checklist does not replace the need for EIAs – these are a statutory requirement for particular types of developments (see Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999). Since this is dealt with by formal legislation, these are not repeated it in the Checklist.
Expectations regarding Health Impact Assessments are detailed in the Checklist.
Does it relate to Sustainability Appraisals/Strategic Environmental Assessment?
The Checklist was not initially designed to be used in Sustainability Appraisals. However some local authorities and consultants suggest that it may be useful in the process. Referring to the ODPM Sustainability Appraisal/SEA guide, this would include:
- Task A1: Reviewing other relevant policies, plans and programmes and sustainability objectives
- Task A3: Identifying sustainability issues and problems.
How does it help with the requirement for Annual Monitoring Reports?
Under the Planning and Compulsory Purchase Act 2004, the Local Planning Authority has to provide an annual report showing the extent to which objectives in the local development plan are being achieved. When the Brighton & Hove Checklist is submitted as part of a planning application, the scores for specific questions are compiled to assess and show how progress is being made.
Can the the Brighton & Hove Checklist be used by a developer where it is not required by the local planning authority?
Yes. The Checklist has been developed as a tool for decision makers (the local planning authority, the land owner, the developer team or the potential purchaser of a development) and should be used as a guide and quality assurance tool in their design and planning process. It may also be useful in demonstrating the quality of the proposed development to other interested parties.