Drafted statements and the local validation checklist

A drafted planning statement answers a local validation checklist item only where that item asks for an argument. Most of what defeats validation is not argument at all: it is a form, a fee, a certificate, a plan at a stated scale or a notice nobody served. Mapping drafted documents onto a local validation checklist is therefore a sorting exercise, and the sorting is what saves the week you would otherwise lose to a returned application.

Do it once per authority and keep the result. Local lists change slowly, and the version you built last year is usually still 90 per cent right.

National requirements against local lists

Two sets of requirements apply. The national information requirements, set out in the Development Management Procedure Order 2015, cover the application form, the correct fee, the location plan, the ownership certificates, the design and access statement where required and the other items prescribed for the application type.

On top of that each authority publishes a local list of information requirements. The local list is where the variation lives: a drainage assessment at a lower threshold than national policy, a bat scoping survey on any roof alteration, a parking survey in an area of stress, a retail impact statement at a local floorspace figure.

The practical difference matters. A failure on a national requirement makes the application invalid, full stop. A local requirement can only be insisted on where the Order's conditions are met, and that gives you more room than most applicants use.

How often a local list may be relied on

The Order allows an authority to require information from its local list only where the requirement was on a list published not earlier than two years before the application was made, and where the information is reasonable having regard to the nature and scale of the proposed development and the particular matters it raises.

Both limbs are worth checking. Download the list and look for its publication date. Lists more than two years old cannot be relied on, and authorities do let them lapse, particularly smaller districts between local plan reviews.

Then test proportionality. A full transport assessment for a two unit infill, a whole life carbon assessment on a conservatory, an arboricultural report where no tree is within influencing distance: each of those is a requirement that fails the reasonableness test as applied to that development.

Say so in the covering letter, at submission, with the reason. Raising it at the point of submission is far more effective than arguing after the application has been returned.

Reading the list as a document schedule

Convert the list into a table before you start drafting. One row per requirement, with four columns: the requirement as worded, the trigger that makes it apply, the document that satisfies it and the person responsible for producing it.

That table does three things. It shows at a glance which requirements your project triggers. It reveals the items nobody owns, which are usually the surveys. And it becomes the submission checklist.

Copy the wording rather than paraphrasing it. Validation officers work from the list as written, and a paraphrase hides the trigger.

Where a draft covers a listed requirement and where it does not

AI-assisted drafting is strong on the narrative documents, because the structure of a planning statement, a design and access statement or a heritage statement is largely determined by policy and the authority's expectations. A Planning Statement drafted against the adopted plan's policy numbers, then reviewed and corrected on the site-specific facts, will satisfy that line on most local lists.

It is weaker, and should be, on anything resting on measurement or survey. A flood risk assessment needs survey levels. An ecology report needs a site visit in the right season. A noise assessment needs a monitoring period. A contaminated land report needs a desk study by a suitably qualified person and often intrusive investigation. For those, the draft is a structure waiting for data, and the honest description of what it produces is a document with the site-specific facts flagged rather than invented.

Our note on what drafts get right about structure and wrong about evidence sets out that division in more detail.

The flagging behaviour matters here. A draft that inserts a marker where a measured level or a survey result belongs is doing the right thing, and the reviewer's job is to fill or delete each marker. Submitting a document with markers still in it is a validation failure of a different and more embarrassing kind.

Items no document can satisfy

Some lines on every list cannot be produced by any amount of writing. The application form, signed. The correct fee. The ownership certificate and any notice served under it. The agricultural holdings declaration. The biodiversity gain statement or exemption declaration. The community infrastructure levy additional information form. A location plan at a stated scale with the application site edged red.

These are the items that most often return an application. They are also the items that depend on facts only the applicant holds. Our note on why planning applications are returned as invalid covers the pattern, and the certificates deserve their own attention because a false one is a criminal matter rather than an administrative one.

Build them into the schedule as rows with the client named as owner, and chase them first. They take the longest and cost the least.

Challenging a validation request

Where an authority asks for something you consider unreasonable, the sequence that works is short and written.

1. Write to the validation officer identifying the requirement, the publication date of the list and the reason the information is not reasonable for this development.
2. Offer the proportionate alternative: a short statement instead of a full assessment, a desk-based screening instead of a survey, a drawing annotation instead of a separate document.
3. Ask for the request to be confirmed or withdrawn within five working days, so the point does not drift.
4. If the authority maintains the request, decide whether to comply or to press the point, and record the advice either way.

Where an authority refuses to validate an application you consider valid, the practical options are limited and slow: raise it through the authority's own complaints procedure, or treat the statutory period as running and consider an appeal for non-determination. Both are blunt instruments and both cost time, which is why the covering letter at submission is worth the half hour.

An illustrative example

Take an illustrative case: a two-storey side extension and loft conversion in a conservation area. The local list triggers a heritage statement, a bat scoping assessment because the roof is being altered, a tree survey because a protected tree sits 8 metres from the works, and a drainage statement. The heritage statement is drafted and reviewed. The bat scoping assessment is commissioned from an ecologist. The tree survey is produced by an arboriculturist to the relevant British Standard. The drainage statement is reduced, by agreement, to an annotated drawing showing the existing connection, on the basis that no additional impermeable area is created. These facts are illustrative.

Building a reusable submission checklist

Keep one file per authority containing the list, its publication date, your mapped table, the covering letter template with the proportionality arguments you have already won, and a note of anything the validation team accepted or refused.

Review it when the authority republishes its list or adopts a new plan. Two years is the outer limit on relying on a list, so a diary note at 18 months catches the republication.

And share it internally. The time lost to validation is almost always lost by someone who did not know an argument had already been had. For report types where a reviewer has to sign the document, the professional directory is the route to that sign-off, and the pricing page sets out what drafting each document costs.

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