Competence for a sequential test submission

Who prepares a sequential test is a question with two answers, because there are two different tests with the same name. A flood risk sequential test and a retail sequential test ask different questions, draw on different evidence and need different competence behind the conclusion. Confusing them is the most common error in scoping the work, and it produces a document that reads as though the author has done this before without actually answering the test the authority applies.

Both need a chartered planner to own the conclusion. Only one of them routinely needs a chartered surveyor to own the availability evidence.

The two sequential tests, and why the competence differs

The flood risk test asks whether the development could be located in an area at lower risk of flooding. Its currency is flood zones, surface water mapping, site areas and the authority's own evidence base, and it is applied within an area of search agreed with the local planning authority.

The retail test asks whether a main town centre use proposed outside a defined centre could be accommodated within one, applying the town centre first approach. Its currency is defined centre boundaries, unit sizes, format requirements and the flexibility the applicant is willing to show on scale and format.

The overlap is the availability judgement. Both ask whether an alternative site is available, and that is the part of either test most often decided against the applicant.

What the author is actually judging

Strip away the formatting and the author makes three judgements, each of which can be challenged.

The first is the scope of the search. On the flood test that means the geographic area and the development's functional catchment. On the retail test it means which centres are sequentially preferable and in what order.

The second is suitability, meaning whether the alternative site could physically and policy-wise accommodate the development, with the flexibility the test requires.

The third is availability, meaning whether the site could realistically be used for this development within a relevant period. This is a market judgement dressed as a planning one, and it is where competence questions arise.

An author who treats all three as planning judgements will produce a test that collapses under scrutiny on the third. An author who recognises the third as a property question and evidences it accordingly produces a test that holds.

Where a planner's judgement ends and a surveyor's begins

A chartered planner should own the test, the policy framework, the search scope and the conclusion. Where the availability conclusion carries real weight, bring in a chartered surveyor with local agency knowledge.

The division works like this in practice. The planner establishes the search area and the criteria, identifies the long list from the authority's evidence base and the plan, and screens on policy and physical grounds. The surveyor addresses marketing history, current availability, asking terms, likely delivery timescales and whether a site is realistically obtainable. Then the planner draws the conclusion, citing the surveyor's evidence rather than paraphrasing it.

That matters at appeal. An inspector asked to prefer one availability conclusion over another will give weight to a named surveyor's dated evidence about a specific site over a planner's assertion that the site is not available. On a contested major application, a short annexed letter from a local agent, signed and dated, is worth more than several pages of narrative.

Where junior staff do the search work, the file needs to show who checked it. Our note on supervision chains and graduate work signed by a chartered author sets out the arrangement authorities accept, and it applies squarely here, because a site search is exactly the sort of task delegated downwards.

Transparency in the search methodology

The competence an authority can actually assess is methodological. So the method has to be visible.

Say where the long list came from, naming each source document and its date. Say what criteria were applied and when they were written, which should be before the search. Say what was excluded and on which single criterion. Say which sites were visited and when.

Then say what you could not establish. A test that admits two sites could not be confirmed either way, and explains what was attempted, is stronger than one that quietly drops them. Officers notice gaps in a numbered list.

Avoid the two patterns that signal a predetermined answer. Criteria that exactly match the application site's characteristics, including ones with no functional basis. And a search area whose boundary happens to follow the edge of the applicant's land interests.

Availability evidence and who can obtain it

Availability evidence has a hierarchy, and knowing it helps you brief the work properly.

1. Written confirmation from the owner or their appointed agent, dated, stating whether the site is available and on what terms.
2. Current marketing particulars with the date of first marketing and the asking terms.
3. A documented approach that received no reply, with the date, the method and the addressee.
4. Register or title evidence showing the site is committed to another use, under construction, or recently transferred.
5. A site visit record with photographs showing active occupation.

Anything below that, including general market commentary and the author's impression, is not evidence. Where the only available material is at level three or below for a particular site, say so plainly and let the officer weigh it.

Title checks are worth doing on the three or four sites most likely to be raised against you. Discovering at appeal that a discarded site changed hands eight months ago, to a party that has since applied for permission, is a bad afternoon.

How the authority tests the search area

Expect the authority to test the scope before it tests the detail, because that is where a test is most easily defeated.

On the flood test, officers check whether the agreed area of search matches the development's catchment and whether anything in the authority's own land availability work was missed. Where the applicant has narrowed the area, the officer asks why. Agreeing the area at pre-application stage and recording the agreement neutralises this almost entirely.

On the retail test, officers check whether all sequentially preferable centres were considered, whether the flexibility shown on scale and format was real, and whether an edge of centre site was dismissed on grounds that would not survive the required flexibility. A retail test that refuses to contemplate any reduction in floorspace or any change in format tends to fail, because the policy expects flexibility to be demonstrated rather than asserted.

Where the authority's conclusion differs from yours, the difference usually traces to one input. Find which one before responding.

Reviewing a weak test before it goes in

Run four checks on any sequential test before submission, whoever wrote it.

Check the dates. Every availability conclusion needs a date, and a search more than a year old needs refreshing before it goes in.

Check the criteria against the development rather than against the site. If a criterion would not have been written for a different site in the same ownership, it is reverse engineered.

Check that the conclusion is a threshold statement about alternatives and does not drift into planning balance. A conclusion that argues benefits tells the reader the alternatives evidence is thin.

Check who is named on it. The report should carry the author, their qualifications and the date, and where surveying evidence is relied on, the surveyor should be named too. A test with no named author invites the officer to treat the whole thing as unsourced, and the consequences of a document failing at validation are set out in our note on redress when a consultant report fails validation.

If the test cannot be passed, say so to the client in writing before the application is submitted. A sequential test written to a predetermined conclusion hands the authority a reason for refusal drafted by the applicant.

The structure of a Sequential Test (Flood) or a Sequential Test (Retail) draft can be set out quickly, which leaves the time where it belongs, on the dated availability evidence that only a person on the ground can gather. Reviewers with the relevant surveying competence can be approached through the professional directory.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.