Responding to a Mayoral stage one report in London
A stage one report tells you the strategic objections in writing, months before determination. Here is how to read it, structure the response, and use the window before stage two.
A Mayoral stage 1 representation is not a consultation response you answer at leisure. It is a published report setting out where the Greater London Authority considers the scheme does not comply with the London Plan, and what changes might remedy that. The borough reads it as a checklist, and at stage two the Mayor can direct refusal or take the application over. So the response has to deal with every point the report raises, in the report's own order, before the borough's committee date.
The report is also an opportunity. It tells you precisely what the strategic objections are, in writing, months before determination.
When an application is referable at all
Referral is governed by the Town and Country Planning (Mayor of London) Order 2008, and Schedule 1 to that Order defines the categories. The thresholds that catch most schemes are these.
| Category | Threshold |
|---|---|
| Housing | More than 150 houses, flats, or houses and flats |
| Floorspace in the City of London | More than 100,000 m2 |
| Floorspace elsewhere in central London | More than 20,000 m2 |
| Floorspace outside central London | More than 15,000 m2 |
| Height adjacent to the River Thames | More than 25 metres |
| Height in the City of London | More than 150 metres |
| Height elsewhere | More than 30 metres |
| Green Belt and Metropolitan Open Land | Development on such land, subject to the category's terms |
Read Schedule 1 itself rather than a summary, because the categories include qualifications on floorspace definitions, central London boundaries and proximity to the Thames that decide marginal cases. Boroughs occasionally refer schemes that are not referable, and occasionally fail to refer ones that are, and the second of those can undermine a permission.
Where a scheme is close to a threshold, decide deliberately whether to sit below it. Dropping from 152 to 149 units to avoid referral is a legitimate commercial choice, though it also forfeits the Mayor's support where the scheme is strategically favourable.
What a stage one report contains
The borough refers the application after receiving it, and the Mayor has six weeks to issue the stage one report. The report follows a consistent structure: a summary, the site and proposal description, case history, then the strategic planning issues assessed in turn, the borough's position, legal and financial considerations, and a conclusion.
The strategic issues section is the substance. It will work through land use principles, housing and affordable housing, urban design and tall buildings where relevant, inclusive design, sustainable development including energy and carbon, and transport.
The conclusion is the part to read first. It states whether the application complies with the London Plan, and where it does not, it lists the deficiencies and the changes that might remedy them. That list is your work programme.
Reading the compliance table
Officers write these reports in a recognisable pattern, and the language signals how much room there is.
- "Does not comply" with a stated remedy means the point is capable of resolution and the remedy is the price.
- "Further information is required" means the objection is evidential rather than principled, and a better document answers it.
- "Strategically unacceptable" means the scheme as submitted will not be supported, and a material change is needed.
- "Supported in principle, subject to" means the issue is detail and can usually be conditioned.
Sort the points into those four categories before drafting anything. The response effort should be concentrated on the third category, because the first and second are mostly document work.
Where the report raises an affordable housing point, check which route the scheme is on. The London Plan's threshold approach sets a percentage above which schemes avoid a viability review, with a higher figure on public land and on industrial land released for residential use, and the tenure split and review mechanisms follow from that choice. Industrial land cases carry an additional policy layer, which our note on industrial land and no net loss sets out.
Drafting the response to each point
Write one document, structured by the report's own headings and numbered paragraphs, so the reader can follow it against the report.
- Quote the report's point, or cite its paragraph number, then respond. Do not paraphrase the objection in friendlier terms.
- Say plainly whether the scheme is being changed, whether further evidence is being supplied, or whether the point is resisted.
- Where the scheme is changing, include the revised drawings and a schedule of changes rather than describing them.
- Where the point is resisted, give the policy reading and the evidence, and acknowledge the Authority's position rather than ignoring it.
- Close with a short table mapping each stage one point to its resolution, which is what the borough's officer will lift into the committee report.
That final table does more work than anything else in the response. Borough officers writing a committee report need to show how the strategic issues have been addressed, and a ready-made table gets used.
Avoid the two common failures. Responding only to the points you can answer, which leaves the report's remaining objections live at stage two. And responding with a general statement of support for the scheme, which answers nothing.
The documents that usually resolve the technical points
Most stage one reports raise the same set of evidential issues on a residential-led scheme.
An Energy Statement following the energy hierarchy of be lean, be clean, be green and be seen, with the on-site carbon reduction against the Building Regulations baseline stated and any shortfall addressed through the offset mechanism. Monitoring commitments under the be seen requirement are frequently the missing element.
A Whole Life Carbon Assessment and a circular economy statement, both expected for referable applications, prepared to the Authority's guidance and submitted in the required template rather than as free text.
A Fire Statement, which is required at Planning Gateway One for relevant buildings under the Building Safety Act 2022 framework and article 9A of the Development Management Procedure Order 2015, and must be prepared by someone with the necessary fire-engineering competence. This is a report type where a competent professional is legally required, so an AI-assisted draft is a starting point for that engineer rather than a substitute.
A play space assessment against the ten square metres per child standard, with the child yield calculation shown and doorstep, neighbourhood and youth provision distinguished.
Urban greening, biodiversity and daylight evidence as the report requires. On dense sites the daylight and sunlight case is usually the hardest, and the approach to applying the daylight guidance in dense London matters more than the headline numbers.
Negotiating before the borough decides
The window between stage one and the borough's committee is where schemes are resolved, and it is routinely wasted.
Ask the Authority's case officer for a meeting on the response, with the borough present. A tripartite discussion fixes points that correspondence cannot, particularly on design and affordable housing, and it produces a shared record of what has been agreed.
Where density or massing is the issue, the design-led approach to capacity is the frame the Authority will use, and our note on optimising site capacity sets out how that assessment is structured. Bringing a capacity study rather than a defence of the submitted scheme changes the conversation.
One honest uncertainty: the weight the Authority gives to a borough's local policy position varies with the strategic significance of the scheme and with the political context of the moment. Two schemes with similar issues can receive different treatment, and that is not something an applicant can model.
Stage two, and the timescales that do not move
When the borough resolves to grant or refuse, it refers the application again. At stage two the Mayor has fourteen days to decide whether to allow the borough to determine the application, to direct refusal, or to take it over and act as the local planning authority.
Fourteen days is not negotiable and nothing useful can be submitted inside it. Everything the Mayor will consider at stage two must be on the file before the borough's resolution.
Two practical consequences. Get the response, the revised drawings and the agreed heads of terms submitted well before the committee date, not in the week of it. And read the borough's committee report when it is published, because any stage one point it fails to address will be the point the Authority picks up.
Draft your London supporting statements on PlanScope and have them reviewed by a qualified professional before the borough refers the application.
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
Which applications are referable to the Mayor?
Those falling within the categories in Schedule 1 to the Town and Country Planning (Mayor of London) Order 2008. The most common triggers are more than 150 homes, floorspace above 100,000 m2 in the City, 20,000 m2 elsewhere in central London or 15,000 m2 outside it, and heights above 25, 30 or 150 metres depending on location.
How long does the Mayor have at stage one?
Six weeks from the borough's referral to issue the stage one report. The report states whether the application complies with the London Plan and, where it does not, lists the deficiencies and the changes that might remedy them. That list is effectively the work programme for the response.
What happens at stage two?
Once the borough resolves to grant or refuse, it refers the application again and the Mayor has fourteen days to allow the borough to determine it, direct refusal, or take it over as local planning authority. Fourteen days leaves no room for new material, so everything must be on the file beforehand.
How should the response be structured?
As a single document following the report's own headings and paragraph numbering, saying for each point whether the scheme is changing, further evidence is supplied, or the point is resisted. Close with a table mapping each stage one issue to its resolution, because borough officers commonly lift that into the committee report.
Can I avoid referral by reducing the scheme?
Yes, dropping below a Schedule 1 threshold is a legitimate commercial choice, and schemes are regularly adjusted for that reason. It also forfeits Mayoral support where the proposal is strategically favourable, and it does not remove the London Plan from the borough's own assessment of the application.
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.