Pre-submission validation self-audit for planning packs
An invalid application does not start the determination clock. This is the order to check a pack in, from the location plan red line to the fee category and the local list.
An application that fails validation does not start the eight or thirteen week clock, so a pack sent in on Friday and invalidated on Wednesday has cost you a fortnight, not two days. The audit that prevents it takes about thirty minutes and it is mostly mechanical: form against drawings, drawings against scales, certificates against the title, fee against the schedule, then the authority's own local list line by line.
Work through the checks below in that order. They are arranged so that the ones that cause the most invalidations come first.
Where applications actually fail
Most invalidations are not about the quality of the supporting documents. They are about the form, the plans and the certificates.
The recurring causes, in rough order of frequency:
- a location plan with no red line, or a red line drawn round the wrong extent
- a site area on the form that does not match the area inside the red line
- the wrong ownership certificate
- no blue line where the applicant owns adjoining land
- drawings with no scale bar, or marked "not to scale"
- a missing existing or proposed elevation
- the fee calculated under the wrong category
- a local list item the agent did not know existed
Every one of those is caught by reading rather than by expertise.
Reading the authority's local list properly
Two sets of requirements apply. The national requirements sit in the Development Management Procedure Order 2015: the standard application form, a plan identifying the land, the ownership and agricultural holdings certificates, a design and access statement where one is required, and the fee. The local requirements sit on a list the authority publishes and which guidance expects it to review at least every two years.
Read the local list against your actual proposal, not against the project type. Local lists are usually organised by trigger, and the triggers are things like site area, distance from a watercourse, presence of a tree, proximity to a listed building or the number of bedrooms. A householder extension in a conservation area within the root protection area of a mature street tree can pull in three local list items that the same extension elsewhere in the borough would not.
Two habits help. Print the local list and tick items off against your document schedule rather than reading it on screen. And where a local list item does not apply to your site, submit a short note saying so with a reason, because an unexplained absence reads as an omission to a validation officer working through a queue.
A Design and Access Statement is required for major development and for development in a conservation area or World Heritage Site above the thresholds in the Order, and this is the single requirement most often assumed rather than checked.
Cross-checking the form against the drawings
The validation officer's job is largely reconciliation, so do it first.
- Site address and postcode on the form match the location plan and the title.
- Site area on the form matches the area inside the red line, to the stated precision.
- Existing and proposed floor areas on the form match the schedule on the drawings.
- Number of dwellings, bedrooms and car parking spaces on the form match the layout.
- Description of development covers everything shown on the drawings, including demolition, boundary treatment and any change of use.
- Every drawing referred to on the form exists in the pack, and every drawing in the pack is listed on the form.
- Drawing numbers include a revision suffix and that suffix matches the one quoted in the covering documents.
Point five is where most disputes with case officers begin. A description that says "single storey rear extension" and drawings that also show a new dropped kerb and the loss of a tree is either an invalid application or an application that will be amended later, and neither is what you wanted.
Drawings, scales and file conventions
Location plans are conventionally at 1:1250 or 1:2500, block and site plans at 1:500 or 1:200, and floor plans and elevations at 1:50 or 1:100. Include a scale bar on every sheet, a north point on every plan, and the original sheet size, because a PDF printed at the wrong size is the most common reason a drawing is rejected as not to scale.
| Drawing | Usual scale | Must show |
|---|---|---|
| Location plan | 1:1250 or 1:2500 | Red line, blue line, north point, at least two named roads |
| Block plan | 1:500 or 1:200 | Site boundaries, buildings, trees, parking, bin and cycle storage |
| Floor plans | 1:50 or 1:100 | Existing and proposed, with dimensions |
| Elevations | 1:50 or 1:100 | All affected elevations, existing and proposed, with materials noted |
| Sections | 1:50 or 1:100 | Where levels change or a roof form is in question |
On files: one document per PDF, named so a stranger can tell what it is, each within the portal's size limit, no password protection, no scanned image of a scanned image. Drawings as vector PDFs where possible. Avoid combining the whole pack into a single 40 megabyte file, which authorities routinely reject and which makes the officer's job unpleasant.
Certificates, notices and ownership
Get the certificate right by checking the register, not by asking the client. Certificate A is for sole ownership of the whole application site with no agricultural tenants. Where anyone else owns any part of the site, or holds a qualifying interest, the correct certificate is B, C or D and notice must be served on them, with the date of service recorded on the form.
The two traps are shared access strips and unregistered verges. A driveway crossing a strip retained by the original developer, or a front boundary that stops short of the highway, both turn a Certificate A into a Certificate B. Check the title plan against the red line before you tick anything, and keep a copy of the notice served in the file. Getting this wrong can invalidate a permission long after it is granted, which is a worse problem than a rejected submission.
Fee calculation checks
Fees come from the national fee regulations and are now revised on an indexed basis, so use the current schedule rather than a figure from a previous project. Check the category first: householder, full application for dwellings, change of use, outline by site area, reserved matters, prior approval and a section 73 variation all price differently, and an application covering two categories usually attracts the higher fee rather than both.
Then check the exemptions and reductions: works for disabled access, a second application within twelve months of a withdrawn or refused one on the same site by the same applicant, and the surcharge position where retrospective development is involved. Where the calculation is not obvious, ring the authority and note who confirmed it.
The final half hour
Set the pack aside, then read it as a validation officer would, in this order: form, location plan, drawing list, certificates, fee, local list, supporting documents. Ask one question of each item, which is whether a stranger could tell that it complies without asking you.
If it comes back invalid anyway, the note on what to do when an application is made invalid sets out the practical route back, and the fuller validation checklist of national and local requirements is worth keeping open alongside the authority's list while you assemble the pack.
This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.
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Frequently asked questions
What are the national validation requirements?
The Development Management Procedure Order 2015 requires the standard application form, a plan identifying the land, the ownership and agricultural holdings certificates, a design and access statement where one is needed, and the correct fee. Anything beyond that comes from the authority's published local list, which guidance expects to be reviewed at least every two years.
Why do most applications fail validation?
Form and plan problems rather than weak reports. A missing or wrong red line, a site area that does not match the red line, the wrong ownership certificate, no blue line where the applicant owns adjoining land, drawings without a scale bar, and a fee calculated under the wrong category account for a large share of invalidations.
Which ownership certificate should I use?
Certificate A applies only where the applicant owns the whole application site and there are no agricultural tenants. Where anyone else owns any part of the site or holds a qualifying interest, use B, C or D and serve notice on them, recording the date of service. Check the title plan against the red line rather than relying on the client's recollection.
What scales should the drawings be at?
Location plans are conventionally 1:1250 or 1:2500, block and site plans 1:500 or 1:200, and floor plans, elevations and sections 1:50 or 1:100. Put a scale bar and the original sheet size on every sheet and a north point on every plan, because a PDF printed at the wrong size is the usual reason a drawing is rejected as not to scale.
Does the description of development need to cover everything?
Yes. If the drawings show demolition, a dropped kerb, tree removal or a change of use, the description must say so. A narrow description with broader drawings is either invalid or will be amended during determination, and amendment means re-consultation and lost weeks. Draft the description from the drawings once they are final.
How should I check the fee?
Use the current national fee schedule rather than a figure from an earlier project, because fees are revised on an indexed basis. Identify the category first, since householder, full, outline by area, reserved matters, prior approval and section 73 applications all price differently. Then check exemptions, disabled access relief and the position on resubmissions within twelve months.
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.