Reading a site allocation and answering its requirements
An adopted allocation is a published brief with a checklist attached. Answer every criterion with a cross-reference, and handle the ones you fail in the same table rather than burying them.
Answering a site allocation policy means treating its criteria as a checklist the council has already published, and responding to each one in the order it appears. An adopted allocation is part of the development plan, so under section 38(6) of the Planning and Compulsory Purchase Act 2004 the application has to be determined in accordance with it unless material considerations indicate otherwise. Most allocations run to a paragraph of text and eight to fifteen criteria, and most refusals on allocated sites come from an applicant who answered ten of them and ignored the rest.
Read the allocation before the design starts. It is the cheapest brief you will ever be given.
Where allocations sit in the development plan
An allocation appears on the policies map with a reference, supported by a policy in the local plan or in a separate site allocations document. A made neighbourhood plan can allocate sites too, and those allocations carry the same statutory weight.
Three documents travel with it and are frequently overlooked. The evidence base that justified the allocation, typically a strategic housing land availability assessment or an employment land review. The examination inspector's report, which often explains why a criterion was added or reworded. And any supplementary planning document, masterplan or development brief the policy requires or refers to.
The inspector's report is the most useful of the three and almost nobody reads it. Where a criterion was inserted at examination to address a specific objection, the report tells you what the objection was, which tells you what evidence will satisfy it.
Reading the allocation text line by line
Take the policy apart into numbered criteria, including the ones buried in prose. Then mark each one.
| Criterion type | What it needs |
|---|---|
| Quantitative, such as a dwelling number or floorspace figure | A statement of what the scheme delivers and how it compares |
| Locational, such as access from a named road | A drawing showing compliance, or a justified alternative |
| Evidential, such as a heritage or ecology assessment | The named report, prepared to the relevant standard |
| Procedural, such as a masterplan agreed before submission | Evidence that the step was carried out |
| Infrastructure, such as a contribution or a new school site | A section 106 position, agreed in principle before submission |
| Design, such as compliance with a design code | A cross-referenced section of the Design and Access Statement |
Watch the verbs. "Will" and "must" are requirements. "Should" and "will be expected to" are strong expectations. "May" and "where appropriate" leave room for argument. An officer reading your statement is doing exactly this exercise in reverse, and matching the language of the policy makes their report easier to write in your favour.
Indicative capacity and whether it binds
Allocation policies usually give a capacity, often expressed as "approximately" a number of dwellings or a floorspace figure. The word carries weight.
An indicative capacity is drawn from an assessment made before any detailed survey work, and it is not a cap. Schemes regularly come forward above it where the layout justifies the density and the constraints allow. They also come forward below it, which is the harder conversation, because a council counting on that site for its housing trajectory will resist under-delivery.
Argue either departure with evidence rather than assertion. Above the figure, show the design quality, the amenity standards met, the parking provision and the townscape response. Below it, show the constraint that reduced the capacity, whether that is an easement, a root protection area, a flood extent or a heritage setting. Do it in the Planning Statement in its own section, not in a footnote.
Infrastructure and phasing requirements
Infrastructure criteria are where allocated sites stall, because they usually involve a third party.
Common examples: a spine road to be delivered before a stated number of dwellings is occupied, a primary school site to be transferred, an off-site junction upgrade, a foul drainage upgrade dependent on the water undertaker's investment programme, or a contribution to a strategic transport scheme.
Each needs a delivery mechanism agreed before determination, and the mechanism is usually a combination of a section 106 obligation and a negatively worded condition. Start those conversations at pre-application, because the highway authority and the water undertaker work to their own timescales and neither will be hurried by your committee date.
Phasing criteria deserve particular care where a site is in multiple ownership. A policy requiring the allocation to come forward as a whole can prevent one landowner applying alone, and the answer is usually an agreed masterplan for the whole allocation with a phased application for your part.
Masterplans, briefs and supplementary documents
Where the policy requires a masterplan or development brief, treat it as a separate consent step with its own programme. Some authorities adopt the brief as a supplementary planning document, which involves consultation and a formal adoption decision that can take months.
A supplementary planning document is not part of the development plan and cannot introduce new policy, but it is a material consideration and it carries real weight where it was properly consulted on. Arguing that it is only guidance is technically right and tactically poor.
Where no brief exists and the policy requires one, offer to prepare it. An applicant-led masterplan agreed with officers and taken through consultation is slower at the start and much faster afterwards.
Answering each criterion in the planning statement
Put a compliance table in the planning statement, as a distinct section rather than an appendix. One row per criterion, the policy wording quoted or closely summarised, the response, and the document and page where the evidence sits.
Two rules make it work. Never write "complies" without a cross-reference, because an unsupported claim invites the officer to check it and find nothing. And deal with the criteria you do not meet in the same table, in the same format, with the justification stated. Burying a non-compliance elsewhere in the document is how a straightforward application turns into a credibility problem.
Where the site has an industrial history, the evidential criteria will usually include contamination, and our note on contaminated land registers and what a search shows covers the first step of that work.
Departing from an allocation and justifying it
Departures happen for good reasons. New survey information, a designation made since adoption, a changed market for the allocated use, or a constraint the plan-makers did not know about.
The structure of the argument comes from section 38(6). Identify the conflict with the allocation precisely, so the officer does not have to. Explain why the material considerations outweigh it, with evidence. And show that the scheme still delivers the planning purpose the allocation was serving, or explain why that purpose can be met elsewhere.
Departures on use are the hardest. A housing scheme on an employment allocation needs marketing evidence over a sustained period and an assessment of the authority's employment land supply, and anything less is refused. Departures on a single criterion, such as an access point moved for visibility reasons, are usually straightforward if the technical justification is there.
One habit worth adopting: write the officer's refusal reason yourself, then answer it. If you cannot answer it, you have found the real problem while there is still time to change the scheme.
This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.
If you are scoping an application on an allocated site, browse the report types on PlanScope and match them to the policy criteria. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
Is the dwelling number in an allocation a cap?
No. An indicative capacity comes from an assessment made before detailed survey work and is not a limit. Schemes come forward above it where design quality, amenity standards and parking justify the density, and below it where a constraint reduces capacity. Either departure needs evidence rather than assertion, set out in its own section.
Does a masterplan requirement have to be met before applying?
Where the policy says so, yes, and it should be programmed as a separate step. Some authorities adopt the brief as a supplementary planning document, which involves consultation and a formal adoption decision and can take months. Where none exists and the policy requires one, offering to prepare it is usually faster than arguing about it.
How much weight does a supplementary planning document carry?
It is not part of the development plan and cannot introduce new policy, but it is a material consideration and carries real weight where it was properly consulted on and adopted. Arguing that it is only guidance is technically correct and tactically poor, because officers and inspectors apply it as the detailed expression of the policy.
Can I depart from an allocation?
Yes, where material considerations outweigh the conflict. Structure the argument on section 38(6): identify the conflict precisely, evidence why other considerations outweigh it, and show that the planning purpose the allocation served is still delivered or can be met elsewhere. Departures on the allocated use are much harder than departures on a single criterion.
What documents travel with an allocation?
The evidence base that justified it, usually a housing land availability assessment or an employment land review, the examination inspector's report, and any supplementary planning document, masterplan or development brief the policy refers to. The inspector's report is the most useful and the least read, because it explains why criteria were added.
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.