Local validation lists: what councils ask beyond the national list
A local validation list can only be enforced if it was published within the previous two years. Here is what the national list covers, what councils add, and how to dispute a request.
Every English planning application has to satisfy two lists. The national list is fixed by article 11 of the Town and Country Planning (Development Management Procedure) (England) Order 2015 and is the same in Cornwall as it is in Cumbria. The local validation list is the council's own, and it is where most invalid applications die. The useful rule that few architects know: a local list requirement can only be enforced if the list was published within the previous two years. An authority relying on a stale list is asking for something it cannot insist on.
That single point resolves a surprising number of validation arguments, and it takes ninety seconds to check.
What the national list requires on every application
Six things, and they do not vary.
- The application form, completed, on the correct form for the application type.
- The correct ownership certificate (A, B, C or D) and the agricultural holdings certificate.
- A location plan identifying the land, with the application site edged red and other land in the applicant's control edged blue.
- Any other plans, drawings and information necessary to describe the development.
- A Design and Access Statement where one is required: major development, and development in a conservation area or World Heritage Site involving one or more dwellings or 100 m² or more of floorspace. Listed building consent applications need one too.
- The correct fee.
Two national additions catch people out because they arrived recently. Since the biodiversity gain condition came into force, applications must state whether the applicant believes the condition applies, give the pre-development biodiversity value and the date it was measured, and describe any pre-application habitat degradation. And under article 9A, a fire statement is required for applications involving relevant buildings, meaning residential buildings of 18 m or more, or seven or more storeys, containing two or more dwellings.
Item 4 does a lot of quiet work. "Necessary to describe the development" is what a validation officer points to when the local list runs out.
How councils build a local list and how long it lasts
Authorities publish local lists after consultation, setting out the documents they require for particular categories of development. The lists are usually organised by application type and by trigger: a heritage document if the site is in a conservation area, a survey if trees sit within influencing distance, a drainage assessment above a stated site area.
The two-year rule sits in article 11 itself. A requirement can only form part of the validation position where the list has been published within two years of the date the application is made. Councils know this and republish, but not all of them republish on time. Download the list as a PDF, check the publication date on its cover, and keep the file with the application record. If it is out of date, say so politely in the covering letter and cite the article.
A local list requirement also has to be reasonable and proportionate to the application in front of the officer. National guidance is explicit that authorities should not ask for information that has no bearing on the particular proposal. A blanket request for a transport statement on a two-bedroom infill plot fails that test.
Reading the list before you draw anything
The list is a design brief as much as a paperwork brief. Read it at feasibility stage, because several items change the scheme rather than the submission pack.
A tree constraint plan under BS 5837:2012 fixes root protection areas, and root protection areas fix where foundations can go. A tree survey commissioned after the plans are drawn produces a redesign. Energy requirements can set the heating strategy. Contaminated land questionnaires can trigger an intrusive investigation with a six-week lead time.
Order the list by lead time rather than by the council's numbering. Ecology surveys and levels surveys go first, drainage and heritage next, narrative documents such as the Planning Statement last, because they can be written from a finished design in a day.
Documents most often missed on minor schemes
On householder and small residential applications, the same items come back as validation queries:
- The biodiversity gain statement, on applications that people assume are exempt.
- Existing and proposed levels, particularly on sloping plots where the drawings show only plan arrangements.
- A drainage or surface water statement where the site exceeds a stated area or sits in a critical drainage area.
- A preliminary roost assessment where the works affect a roof, soffits or an outbuilding.
- The CIL additional information form, which is not a planning document but stops validation in many authorities.
- Boundary treatment and refuse and cycle storage details on any scheme creating a new dwelling.
The Biodiversity Net Gain Assessment is the one that has changed the shape of small applications most. The statutory metric expects a competent person, and the exemptions are narrower than clients assume.
Disputing a validation request
Start with the list itself. If the document is not on a current list, and is not needed to describe the development, write to the validation officer with the article reference and the publication date, and ask them to validate. Keep it short and unemotional.
If the document is on the list but the trigger does not apply to your site, say which trigger and why it does not bite. Officers deal with this daily and will usually accept a clear explanation.
Escalate to the validation team leader or head of development management if the answer is a form response. Non-validation is not a decision you can appeal under section 78, because the eight or thirteen week period has not started, so the practical options narrow quickly to supplying the document under protest, using the council's complaints procedure, or in rare cases judicial review. Supplying under protest usually costs less than the argument.
Note: an application that sits unvalidated is not a live application, so nothing is running in the background while you argue.
Reviewing the list for currency
Set a calendar reminder. For any authority you work in regularly, check the local list every six months and record the publication date in your practice's project template. Lists change after a local plan adoption, after a new supplementary planning document, and after national reform.
Three things worth checking each time: whether the trigger thresholds have moved, whether a new document type has appeared, and whether the council has adopted a validation checklist for a specific area such as a conservation area appraisal zone.
A pre-submission check that takes twenty minutes
- Download the current local list and note its publication date.
- Tick off the national list items against the actual files you are uploading.
- Run the site through the council's constraints map and list every constraint that triggers a local item.
- Check the biodiversity gain statement fields on the form are completed, not left blank.
- Confirm the fee against the current fee schedule, which is indexed annually.
- Confirm the correct ownership certificate and that any notice has been served.
- Name every file so the officer can tell what it is without opening it.
Step 7 sounds trivial. It is the difference between a validation officer working through your submission in one pass and emailing you a query.
Illustrative example: a two-storey side extension in a conservation area, submitted with a location plan, elevations and a design statement, was returned because the list required a heritage statement for any extension in that area and existing and proposed street elevations showing the neighbouring buildings. Both items were on page four of the list. This example is illustrative.
PlanScope drafts the narrative documents a validation list asks for, structured to UK planning policy, with missing site facts flagged rather than filled in. Browse the 66 report types to match documents to your local list before you submit.
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.
Frequently asked questions
How long is a local validation list valid for?
A local list requirement can only be applied where the list was published within two years of the date the application is made. That comes from article 11 of the Development Management Procedure Order 2015. Download the list, check the date on its cover, and keep a copy with the project file so you can point to it if a request looks stale.
When is a Design and Access Statement required?
For major development, and for development in a conservation area or World Heritage Site that involves one or more dwellings or 100 square metres or more of floorspace. Listed building consent applications also require one. Outside those triggers a council cannot insist on one through the national list, although it may appear on the local list for particular categories.
Can I appeal against a refusal to validate my application?
Not under section 78, because the determination period has not started, so there is no non-determination appeal to bring. The practical routes are to challenge the request in writing with the article reference, escalate within the development management team, use the council's complaints procedure, or supply the document under protest. Judicial review exists but is rarely proportionate.
What biodiversity information must go on the form now?
Applications must state whether the applicant believes the biodiversity gain condition applies, give the pre-development biodiversity value and the date on which it was calculated, and describe any habitat degradation carried out before the application. Leaving those fields blank is a common reason for a small application being returned as invalid.
Which documents should I commission first?
Order by lead time rather than by the council's numbering. Ecology surveys have seasonal windows, levels surveys and intrusive ground investigation take weeks to arrange, and tree surveys under BS 5837:2012 fix root protection areas that constrain the layout. Narrative documents can be written from a finished design in a day, so they go last.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.