Today's entry looks at making it easier for promoters to identify pre-application consultees.
This is the third in a series of entries leading up to the second anniversary of when the Infrastructure Planning Commission (IPC) started to be responsible for applications for infrastructure on 1 March 2010. This article deals with pre-application consultees. The previous two entries are here and here.
The requirement for pre-application consultation is now a well-known feature of the Planning Act regime, and one that is not going to go away. By seeking, and responding to, views from statutory bodies and local people, applications are more likely to be more acceptable, get permission and need fewer changes later in the process, when changes are more difficult and more expensive.
The list of statutory bodies that must, or might, be consulted is a long one. It contains 50 categories of body, and some, such as 'relevant statutory undertakers' include a large number of organisations. The local authorities that must be consulted is also large - currently up to 40, although this figure will reduce once the provisions of the Localism Act come into force.
The IPC must consult a similar list of organisations if it is asked to provide a scoping opinion (on what environmental assessment should cover). A secondary reason for asking for a scoping opinion is that the work of identifying the consultees for the promoter's own pre-application consultation will be done for it. Although the list should be double-checked for changes, and whether the promoter agrees with the IPC on some of the conditional entries - e.g. whether the application affects waste infrastructure - it is an invaluable starting point.
I calculated the average number of consultees for the first 25 scoping opinions and it was 126. Thus the creation of this list is no small job.
Today's suggestion is to go one step further and have the IPC - or its successor the Planning Inspectorate - maintain a list of consultees for everyone to use. It is having to do so anyway for its own purposes, so why not share this to reduce the burden placed on promoters to construct their own lists?
Each recipient organisation will have a preferred route for receiving these requests (in some cases they don't want them at all but sadly for them they can't be left off the list even if they want to be). Sometimes this will be a single national address or email, sometimes a regional office. Why reinvent the wheel (and continually pester these organisations by everyone asking the same questions about consultation)?
Ultimately, one could enter a postcode and be given an automatically tailor-made list of consultees, but that is probably too ambitious at this stage. A first step might simply be a list of contacts for national and regional organisations, and local authorities, as these bodies are likely to be consulted multiple times. This should benefit promoters, the consultation bodies and the process itself.
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