Planning Statement or Design and Access Statement

A design and access statement is required by law for certain applications. A planning statement is not required by law at all. That single difference explains most of what follows, including why so many submissions contain two documents that say the same thing twice and disagree with each other once.

Article 9 of the Town and Country Planning (Development Management Procedure) (England) Order 2015 requires a design and access statement with an application for major development, and with an application for development in a conservation area or World Heritage Site where the proposal is for one or more dwellings or for 100 m² or more of floorspace. A design and access statement is also required with an application for listed building consent. Outside those categories there is no statutory requirement, though local validation lists often ask for one anyway.

The statutory basis for each document

Article 9 also prescribes what a design and access statement must contain. It has to explain the design principles and concepts applied to the development, demonstrate the steps taken to appraise the context of the site and how the design takes that context into account, and explain the policy adopted as to access, including how relevant local policies have been taken into account and what consultation on access has occurred.

Read that list carefully, because it is narrower than most design and access statements you will read. It is about design reasoning and access reasoning. It is not a general policy compliance document.

A planning statement has no prescribed content, because it has no statutory source. Its job is to set out the planning case: the proposal, the site and its constraints, the relevant development plan policies and material considerations, and why permission should be granted applying section 38(6) of the Planning and Compulsory Purchase Act 2004.

What only a design and access statement contains

The design content that has no natural home elsewhere:

• The context appraisal: character of the area, building lines, plot rhythm, materials palette, topography, views and the relationship to neighbours, with the analysis drawings that support it.
• The design evolution: the options considered, what was tested, what was rejected and why. This is the section officers value most and the one most often missing.
• Amount, layout, scale, appearance and landscaping, described and justified, with the relationship to the drawings made explicit.
• Access: vehicular and pedestrian approach, inclusive access into and through the building, level thresholds, parking for disabled users, and how the approach responds to local access policy.
• Any pre-application design engagement, including a design review panel comment and the response to it.

The inclusive access section is the one architects most often under-write, and it is expressly part of the statutory content. A paragraph confirming that the building complies with Approved Document M is not an explanation of the policy adopted as to access.

What only a planning statement contains

The Planning Statement is also where the honest work of conceding harm happens. A statement that identifies a policy conflict, explains why it is outweighed and points to the evidence carries far more weight than one asserting full compliance with 14 policies. Officers read a lot of the second kind.

Where duplication causes contradictions

Duplication creates specific risks beyond untidiness.

The commonest is a design and access statement describing a scheme as three storeys while the planning statement, drafted from an earlier drawing set, describes four. Second commonest is a materials description that differs between the two, which then conflicts with the materials condition. Third is a parking count: 18 spaces in one document, 20 in the other, and a highways consultee asking which is right.

Each of those is a validation or consultation delay, and each is avoidable with a single rule: write the factual description of the development once, in one document, and cross-refer to it from the other.

Section 38(6) and the development plan test

Section 38(6) requires determination in accordance with the development plan unless material considerations indicate otherwise. That is the structure of the planning statement's argument, and it should be visible in the headings.

Work through it in order. Identify the development plan, including any neighbourhood plan and the relevant policies by number and date of adoption. Assess the proposal against each relevant policy, stating compliance, partial compliance or conflict. Reach a view on accordance with the plan as a whole, which is a judgement rather than a tally. Then set out the material considerations, including national policy, and explain whether they indicate a different outcome.

Where the plan is out of date or a relevant policy is inconsistent with current national policy, say so and explain the consequence. That is an argument for the planning statement and it has no place in a design and access statement.

Which one a small application actually needs

For a householder extension outside a conservation area, neither document is required. A short covering statement dealing with the design, the neighbour amenity impact and the relevant local policies is usually enough, and many authorities ask for nothing.

For a single dwelling in a conservation area, a design and access statement is required by Article 9 and a planning statement is not, though the heritage case has to be made somewhere. That is usually a Heritage Statement addressing significance and the effect of the proposal, since the statutory duties in the Planning (Listed Buildings and Conservation Areas) Act 1990 need to be engaged explicitly.

For a minor scheme of five dwellings outside designated areas, neither is statutorily required, but the validation list will almost certainly ask for one or both. Check the list before deciding.

A split that survives officer scrutiny

The arrangement that works on a major application:

1. One project description, in the planning statement, with drawing numbers and revisions listed.
2. Design and access statement covering context, evolution, the five design components and access, cross-referring to the planning statement for the description.
3. Planning statement covering history, policy, the section 38(6) assessment, material considerations, a summary of each technical document and the balance.
4. A single schedule of submitted documents, in both, generated from the same list.
5. A final consistency check across unit numbers, storey heights, floorspace, parking counts and materials before submission.

Step five takes an hour and prevents most invalidation. A Design and Access Statement drafted in PlanScope follows the Article 9 content and marks any site-specific fact it does not hold as one to be confirmed, which is a deliberate safeguard rather than an omission. The report index shows what else a major application usually carries.

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