Report Deep Dives

Planning Statement: a section by section anatomy

7 min readBy PlanScope Editorial Team

A Planning Statement exists to run the section 38(6) exercise for the case officer. Here is what each section has to contain, in the order officers read it.

A Planning Statement exists to do one job: run the section 38(6) exercise for the case officer. Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires applications to be determined in accordance with the development plan unless material considerations indicate otherwise, so a Planning Statement that does not identify the relevant plan policies, apply them to the scheme and then weigh everything else has not done its job, however well written it reads.

Officers read these documents in a particular order. Site, proposal, history, then straight to the assessment. Everything before the assessment is scaffolding, and most of the fee is earned in two or three pages near the end.

Site and surroundings

Describe the application site as a planning officer would need to describe it in a report: address, area in hectares or m², current and last lawful use, boundaries, levels, trees, access arrangements, and the character of what surrounds it. State the designations that apply, with the source. Conservation area name and date of designation, listed buildings within influencing distance and their grade, flood zone, Tree Preservation Order reference, Air Quality Management Area, Green Belt or National Landscape coverage.

Give each designation a source the officer can check. "The site lies in Flood Zone 1 according to the Environment Agency Flood Map for Planning, checked on 12 February 2026" is useful. "The site is not constrained" is not.

Where a fact is not yet known, say so plainly rather than guessing. A drafted statement that carries a visible flag for a missing level survey is more use to a reviewer than one with an invented figure in it.

The proposal, described once and consistently

The description of development in this section has to match the application form, the drawing titles and the fee calculation exactly. Discrepancies between the three are a routine validation failure, and they are entirely avoidable.

Say which application type you are making and why. Full, outline with reserved matters identified, householder, listed building consent, a section 73 variation of condition, a section 96A non-material amendment or a prior approval under the General Permitted Development Order 2015 each carry a different test, and the statement should name the test it is about to apply. Where the scheme has changed during pre-application discussions, set out what changed and in response to what advice. Officers value that more than a clean narrative.

Floorspace, unit numbers and mix belong here as a short schedule. So do parking numbers, cycle parking and refuse storage, because those are the figures the highways and waste consultees will look for first.

Planning history that actually bears on the decision

List previous applications on the site with their references, dates and outcomes, and do not stop there. For each refusal, state the reason for refusal and the paragraph of the scheme that answers it.

This is the section that most often decides a resubmission. An officer who can see that reason for refusal 1 is answered by a reduced ridge height and reason 2 by the relocated access has very little left to do. An officer who has to work it out themselves tends to reach for the previous decision notice instead.

Appeal decisions on the site go here too, described as indicative of how an inspector approached the issue rather than as binding precedent. Nearby comparators can help, though they carry less weight than people hope, and an officer will usually say so.

The policy framework, cited precisely

Name the adopted development plan with its adoption date, then list the policies you are going to apply by number and title. Include the neighbourhood plan if one has been made, because a made neighbourhood plan forms part of the development plan.

Emerging plan policies get weight according to their stage, the extent of unresolved objections and their consistency with national policy. Say which stage the emerging plan has reached and what weight you say it carries, then defend it in one sentence.

For national policy, state the edition. The National Planning Policy Framework was re-issued on 17 August 2026 with policy-coded chapters in place of paragraph numbers, after the December 2024 edition renumbered the December 2023 one. Quoting a paragraph number from an older copy is the fastest way to lose an officer's confidence, so check the current codes on gov.uk at the point of writing. National Development Management Policies under the Levelling-up and Regeneration Act 2023 will sit alongside the Framework once they are brought into force, and until then should be described as forthcoming rather than applicable.

Section What the officer is looking for
Site and surroundings Designations with a checkable source
Proposal Description matching the form, drawings and fee
Planning history Previous reasons for refusal and your answer to each
Policy framework Adopted plan policies by number, plus the current national policy edition
Assessment Each policy test applied to this scheme, with the harm named
Other considerations Consultation responses, obligations, levy position
Planning balance The weighing exercise, stated as a conclusion

The assessment, which is the document

Take each policy test in turn and apply it. Principle of development first, then the detailed matters in the order the plan deals with them: design and character, residential amenity, highways and parking, trees and landscape, drainage, ecology, heritage, and whatever else the site throws up.

Each test needs the same three moves. State what the policy requires, state what the scheme does, state whether that complies and why. Where it does not comply, name the harm and its degree, then say what weighs against it. A statement that reports full compliance with every policy on a scheme that is plainly tight on one of them reads as advocacy, and officers discount it accordingly.

Design and character assessments carry more weight when they are anchored in evidence rather than adjectives. If the scheme sits in a defined character area, say which one and what the adopted appraisal says about it, which is where a townscape character area assessment does the heavy lifting. Keep the design narrative itself in the Design and Access Statement and cross-refer rather than repeating it.

Heritage needs its own sequence. The statutory duties under sections 16, 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 require special regard or special attention, the national policy balance then weighs the degree of harm against public benefits, and that balance has to be run and concluded before the overall planning balance. Running the two together is a drafting error that appears in appeal decisions regularly.

Other material considerations and the balance

Deal with the consultation responses you already have, including neighbour objections where the application has been through pre-application publicity. Address the planning points and leave the rest alone. Loss of a private view and effect on property value are not material considerations, and saying so once, politely, is enough.

Set out the planning obligation position and the levy position: heads of terms you are offering, the Community Infrastructure Levy liability or exemption you expect, and any affordable housing contribution. Attach the draft heads of terms if you have them.

Then write the balance. Where the presumption in favour of sustainable development is engaged, say why it is engaged and what follows, and verify the current policy code rather than copying the familiar paragraph reference. Where it is not, the balance is a straightforward judgement under section 38(6). End with a conclusion that an officer could lift into a committee report. That is the honest test of the section.

Appendices and cross-references

Keep the statement lean and push the evidence into appendices or the standalone technical reports. The statement should cite each technical document by title and date and summarise its conclusion in a sentence, no more. Methodology belongs in the specialist report, which is why a verified view methodology appendix sits with the visual work rather than inside the planning narrative.

A short appendix list, a named author, a date and a version number. Undated statements cause real problems at appeal, where the inspector needs to know which version of the policy framework the author was working from.

This is general guidance, not legal advice. Check the position with your local planning authority or a chartered planner before relying on it.

Enter your postcode on PlanScope to see which reports your site is likely to need, then draft the Planning Statement and send it for professional review. 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 should a Planning Statement be?

Long enough to apply every relevant policy test and no longer. A householder scheme may need six to eight pages, a minor residential scheme fifteen to twenty five, and a major application considerably more because the assessment section grows with the number of policy tests. Push methodology and data into appendices or standalone technical reports rather than the narrative.

Is a Planning Statement the same as a Design and Access Statement?

No. A Planning Statement applies development plan and national policy to the proposal and concludes on the planning balance. A Design and Access Statement explains the design process, the context appraisal and how access works. They overlap on character and layout, so cross-refer between the two rather than repeating the same material in both.

Do I have to cite the National Planning Policy Framework by paragraph number?

Cite whatever the current edition uses, and state the edition. The Framework re-issued on 17 August 2026 is organised by policy codes rather than paragraph numbers, after the December 2024 edition renumbered the December 2023 one. Check the live document on gov.uk at the point of writing, because copying references from an older statement is a common error.

How should the statement deal with a previous refusal?

Set out each reason for refusal verbatim and state which part of the new scheme answers it, with a drawing reference. Where a reason has not been addressed, say so and explain why you consider the position has changed. Officers determining a resubmission start from the old decision notice, so make that comparison easy for them.

Who should write the Planning Statement?

A planner, planning agent or architect with planning experience. The document needs policy judgement rather than drafting alone, and it has to name its author and carry a date and version number so that an inspector at appeal can tell which policy framework the author was working from. Professional review before submission is sensible on anything contentious.

Sources and further reading

planning statementreport writingsection 38(6)development planarchitectsvalidation

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.

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