Everything I read suggests that the British system of explicitly requiring Council-specific 'planning permission" for new development is something of a disaster. It has tremendously enriched the cohort able to purchase under Thatcher, to the general detriment to everyone after.
Nominally, as zoning provides 'build-by-right', things should be different in America. But due to aggressive downzoning to the degree that most new infill/redevelopment also requires a zoning change, it's hard to tell the difference.
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And your thoughts on the matter?