No Design & Access Statement needed?

[Gimp]

I've just been told by the local planning department in my area that no DAS (Design & Access) statement is needed for a submission of outline planning permission for a single dwelling, (since 16th March 2016) my plot is in Wales. I previously heard rumour of this but found nothing concrete online from a google search. I now wondering where this leaves me, to me it seems idiocy not to have a DAS when applying for OPP. For sure as we have seen from the previous post you could get some b*llocks written in there and referenced to, however, how else am I supposed to relay what I am proposing to the planners and of course neighbours who may be more motivated to object if they don't understand the scheme? I'm not sure if a DAS would be needed for FPP or whether to just go straight for this or outline first and submit one anyway if feasible. There are of course the drawings and a good set can relay well what you want but I rather thought the DAS helped to get more detail into what is being proposed so be helpful more than anything.

 

My main concern is will proposals risk being turned down by planners without due cause just of the back of what they see on plan drawings? or do they just rubber stamp the vast bulk of it all?

[Stones]

I'd put one in regardless. It may not be a requirement, but nothing to stop you submitting additional supporting information.

[PeterW]

+1 to that - I submitted documents around a non material amendment that wasn't a requirement but helped to understand the logic behind the changes.  

[Gimp]

3 hours ago, Stones said:

I'd put one in regardless. It may not be a requirement, but nothing to stop you submitting additional supporting information.

Yeah, I think you're fully right here, thank you for the advice, it's focused my mind a bit. I'm thinking if I don't submit one then quite possibly I could be leaving all the power in their hands to say yay or nay at their interpretation of the planning policy alone. Which makes me wonder if this change has been made to benefit the planners in terms of their personal power over the planning system.

Edited November 29, 2016 by Gimp

[jack]

Not strictly a requirement for a single dwelling unless you're in a conservation area (and other designated areas), but you'd be bonkers in most cases not to include one.

 

See paragraph 30 here: http://planningguidance.communities.gov.uk/blog/guidance/making-an-application/validation-requirements/national-information-requirements/

[Gimp]

59 minutes ago, jack said:

Not strictly a requirement for a single dwelling unless you're in a conservation area (and other designated areas), but you'd be bonkers in most cases not to include one.

 

See paragraph 30 here: http://planningguidance.communities.gov.uk/blog/guidance/making-an-application/validation-requirements/national-information-requirements/

Think you're right but the way she wrote back to me in email was as if to say 'we don't do that anymore so don't' I found this surprising and I think her email should have been more neutral in its direction. Like had been said I would find submitting without one an impediment to the application before the process has even begun. I think she must be pushing a planning department preference to not have them submitted if it can at all be helped so it puts the power all in their hands. I wasn't even enquiring directly about DAS but about where to find their local plan as it doesn't appear on their website. I get the impression their whole approach is deliberately non transparent. 

Edited November 29, 2016 by Gimp

[Temp]

If not in the DAS where are you meant to make your case that your application is consistent with local planning guidance?

[Gimp]

4 minutes ago, Temp said:

If not in the DAS where are you meant to make your case that your application is consistent with local planning guidance?

Exactly! 

[Gimp]

Added to this I wonder how planning refusals and appeals are dealt with now since most of this was based on the DAS then upon what grounds are the points made. Would seem silly to submit application without a DAS only for it to be knocked back on some rule of local plan policy and only then get the applicants side when it goes to appeal. That's unless they can't be convinced to reverse their appeal beforehand but once decisions are made then I find people often get entrenched in their particular position and are less likely to accept the arguments of the applicant that they might have already otherwise considered before a decision was made.

 

I think I'll submit a DAS as usual, if its CABE recommended format then surely its best to go with the recommended rather than deviate and risk doing something under par. Makes sense to cover all bases I think, just seems ridiculous that they introduced this oddity into the process that most were happy with really. Risks creating more problems I think rather than less. 

[ToughButterCup]

Writing a DAS  exposes your thought process to everyone.

It answers the question: why are you doing it like this (or that) when there are so many other things you could be doing?

Useful piece of thinking, that.

[Ferdinand]

There is probably a value in writing a DAS in tandem with your early sketches even if only in outline and with yourself and your close commenters as the audience.

 

A good way of framing your thoughts.

[PeterW]

35 minutes ago, Sensus said:

Which can be very frustrating, because unfortunately you're not allowed to stand up from the public gallery and shout "Read page 15 of the DAS, you bunch of incompetent f***ing muppets!", no matter how much you'd like to!

 

 

We have about 300 members and I'm sure if we all put £2 each in it would be worth paying you to submit a planning application just so we can watch that .... 

 

I had pushback on a set of plans that didn't have a scale bar on them as it was "mandatory" until I pointed out none of the previous 2 weeks worth of validated plans had them on either ...... silence .....

[jack]

PMSL - genius!

 

"the constraint is the planning system".  

[Gimp]

On 11/30/2016 at 17:54, Sensus said:

 

It does if the Planners actually read it. Which from experience they frequently don't... which is why we often deliberately separate out the Planning Policy stuff into a specific Planning Statement, if the application hinges on key Planning issues.

 

I've lost count of the number of Planning Committees I've attended where the Members and the Case Officer end up speculating about stuff that has been clearly explained in the DAS. Which can be very frustrating, because unfortunately you're not allowed to stand up from the public gallery and shout "Read page 15 of the DAS, you bunch of incompetent f***ing muppets!", no matter how much you'd like to!

 

Of course, exposing your thought process to everyone can also be a risky business, if you don't know  what you're talking about in terms of either design or Policy. I've similarly seen regular examples of Planners picking up some misinterpretation of Policy in the DAS and turning it into a justification for refusal..

 

With an Outline, it's going to hinge mainly on Policy (assuming it's an Outline with all matters reserved), so a Planning Statement may be a better tool to use, anyway. Not much you can say about design when you're not seeking design approval?

Is there any real full on design approval in the process? My thought was it goes OPP, FFP, then Building Regs drawings, or FFP then Building Regs drawings. So is there particularly any any more design approval in the FFP stage then OPP? I know there is reserved matters and I am thinking about moving to part reserved when I make my submit for OPP to cut down on the practical & aesthetical issues at FFP stage. So I guess tackle the design issues part at OPP and part at FFP if that is how it can be raised. My training is in design so that is where I should be strongest so would make sense to deal with this at an early stage as possible.

 

My thoughts on the OPP are to put in an DAS whether they read it or not. I'm thinking as my site has many positives in terms of location (within settlement, brown filed, not right next to neighbours, etc) is to capitalize on this with a DAS since even if they don't read it, it will go down better at appeal if it goes that way. I'm thinking a planning statement my well be better for a site that has some or many negatives so to avoid focus on them and like you say planners turning the argument into a negative and point for refusal.

 

Already though I am thinking that despite it all being a thought out application its likely to end up with rejection and appeal if only for the fact that you now don't need a DAS or even a planning statement so they will take that as a reason not to read and hence turn it down on whatever they like whether it is sufficiently explained in a DAS, planning statement or whatever. Like you say they just don't bother to read it anymore.

 

Already the responses I have received from my enquires with the LPA have not been great, just asking basic questions about the 'local plan' and I get constant, 'I don't understand, or 'I'm not sure what you mean' - I mean this woman works in planning and she doesn't seem to know anything. To asking for a link to the local plan I got a, "I’m not sure what information you are looking for.  If you would like a link to the LDP page on our website it is..." Well if it is on there website it is the best kept secret well hidden away because I couldn't find it from any of their menu's. To me it looks like they start of from a position of evasiveness to any new comer which shouldn't be how they should be acting in this day and age where it should all be equal access and doesn't bode well for an application before its even been submitted to my mind.  

[ToughButterCup]

On 30/11/2016 at 17:54, Sensus said:

Of course, exposing your thought process to everyone can also be a risky business, if you don't know  what you're talking about in terms of either design or Policy.

 

Which is exactly why it's useful. Sharpens thinking. Exposes ignorance.

[Gimp]

True, and FPP would be nice from the outset, but as I've brought up before the existing OPP has as a condition that it is just for a bungalow or dormer bungalow and I want to get rid of that, I'm not sure if I can do this with going forward with a FFP with a house build. I know I can apply to get this condition dropped but apparently it takes the same time as applying for OPP so my thought was to just apply for OPP for the new build. 

[Gimp]

6 hours ago, Sensus said:

 

Yes, you can.

 

What's more, if you've already got OPP for a dormer bungalow, you've already got a 'shopping list' of the information they're looking for at Reserved Matters... which gives you an ideal opportunity to go for a 'clean' Full Planning Permission, with no pre-commencement conditions to discharge. The only additional matter you then have to address is to demonstrate that full two storey is acceptable in terms of its design and setting.

 

 

Sensus that could be well worth me considering doing then, thank you. If I can avoid having to jump the hurdle twice then it might well be the best way to go. The design is mostly done out fully since even for OPP I wanted a fairly accurate sizing of the build so as you know really involves doing the design to all the required spacing for doors, etc. So yes might save a few quid and hassle by doing that since I don't think the planners will be able to add much what is needed at OPP stage anyway. If I did OPP had to appeal then did FFP and had to appeal it could be a real long drawn out process which could wear me down and be more work which wouldn't be great. My hope is that planners will see that this plot has had OPP several times before and will want to see progress towards something actually being built there within reason and of course within the rules. I'm pretty sure I can put up a decent argument for a two storey as the neighbouring houses are so have argued this in my DAS. I'm thinking if the planners are going to be a pain it may make sense not to linger by going through the two stage process but instead as you say go straight for FFP and if I get that then I'm done