AI and Planning

Using a draft to answer a validation checklist

6 min readBy PlanScope Editorial Team

Most applications are returned for clerical reasons. Build the document schedule from the authority's current local list first, then draft against it.

A drafted planning document gets you past validation only if it answers the authority's published list, item by item. Validation is a clerical test, not a judgement on merit: the officer checks the national requirements set out in article 7 of the Development Management Procedure Order 2015 and the authority's own local list, and if something is missing the application is not valid and the clock never starts. So the useful way to use a draft is to build the document schedule first, then produce the documents against it.

Most invalidations are boring. A missing ownership certificate, a plan without a scale bar, a fee paid short, a local list item nobody read.

Finding the authority's current validation list

Every local planning authority publishes a local list of information requirements, and national guidance expects those lists to be kept up to date and reviewed regularly, so the copy saved on your server last year may not be the current one. Download it fresh for each application and note the version date in your file.

Read the list against your proposal rather than against the application type. A householder extension in a conservation area can trigger a heritage item, a tree item and a drainage item on the same list that asks for nothing extra on an unconstrained site. The trigger text is the part to read closely, because it usually contains a threshold: floorspace, distance to a designation, number of units, presence of a tree within a stated radius.

Where the list is ambiguous, ask the validation team by email and keep the answer. A written statement from the authority that an item is not required is the least expensive insurance in the process.

National requirements against local ones

The national requirements are the same everywhere: the standard application form, the correct certificate of ownership and agricultural holdings notice, the plans and drawings necessary to describe the development, a design and access statement where one is required, and the fee. Those cannot be waived by agreement.

Local requirements are different in character. They can only be required where the information is reasonable having regard to the nature and scale of the proposal, and where it is a material consideration in determining the application. That gives you a basis for challenge, but challenge takes longer than compliance, so use it only where the item is plainly disproportionate.

Mapping each requirement to a document

Build a two-column schedule before drafting anything. Left column, the requirement as worded on the list. Right column, the document, drawing number and revision that satisfies it.

  1. Copy the requirement text verbatim, including the trigger wording.
  2. Name the document that answers it, with its number and revision.
  3. Where one document answers several items, say which section does so.
  4. Where an item does not apply, record the reason and the date you confirmed it.
  5. Submit the schedule with the application as a covering document.

That last step is worth the twenty minutes. A validation officer working through a bundle of fourteen files finds the schedule, ticks across it, and validates. Without it they search, and searching is how applications get returned.

The Planning Statement is usually the document that carries the policy narrative and can absorb several smaller local list items, such as a statement on sustainability or a justification for the description of development. The Design and Access Statement covers design, access and, where required, how consultation influenced the scheme.

Scale drawings and what they have to show

Drawings cause more invalidations than reports. The recurring faults are the same everywhere:

  • no scale bar, or a stated scale that does not match the sheet size
  • no north point on the location plan
  • the application site edged red without the access land included
  • other land in the applicant's ownership not edged blue
  • existing and proposed not drawn at the same scale for comparison
  • levels omitted on a sloping site
  • no roof plan where the roof form is the point of the application

Two of those are worth extra care. The red line has to include everything needed to carry out the development, including a new access across land the council may not expect, and the blue line has to cover other adjoining land in the same ownership. Get either wrong and the certificates can be wrong too, which is a more serious problem than a missing scale bar because a false certificate is an offence.

Where a draft satisfies the list, and where it cannot

A drafted document can do the narrative work well: policy identification, the structure the officer expects, the description of the site and its constraints, the sections a local list item asks for. It can draft the Heritage Statement structure, set out the sustainability response, and pull the development plan policies into the right order.

It cannot produce survey data. A bat survey needs a licensed ecologist and in-season fieldwork. A flood risk assessment needs modelled levels for the site. A noise assessment needs measurements. A structural report needs someone to open up the fabric. Where the local list asks for one of those, a draft gives you the report skeleton and the flags for missing facts, and a qualified professional supplies the substance. PlanScope inserts a marker wherever a site-specific fact is missing, which is a safeguard: an unresolved marker in a submitted document is an invalidation waiting to happen, so search for them before you export. Where sign-off by a competent person is legally required, the professional review route through the professional directory exists for that purpose.

Common reasons applications are made invalid

From the pattern of returned applications, the frequent causes are:

  • the fee, wrong category or short payment
  • ownership certificates, wrong certificate or missing notice to a landowner
  • an agricultural holdings declaration left blank
  • the description of development not matching the drawings
  • a local list item triggered by a constraint the applicant did not check
  • unsigned or undated forms
  • a document referenced in the covering letter but not uploaded

None of those involve planning judgement. All of them cost weeks.

Where an application is returned, ask for the reason in writing and fix only that. Resubmitting a whole revised bundle invites a fresh read of everything, and revision numbers that no longer match the schedule are how a second invalidation happens.

A final check before you submit

Run the same five checks every time, and run them on a printed set if you can.

  1. Open the local list, dated today, and tick the schedule against it.
  2. Check the red and blue lines against the certificates.
  3. Check every drawing has a number, revision, scale and north point where needed.
  4. Search every document for unresolved markers, placeholder text and the wrong site address.
  5. Check the fee against the current schedule, since fees are indexed annually from 1 April.

Our note on factual errors to look for in a drafted document covers the fourth check in more detail, and an internal review checklist sets out how practices formalise the rest.

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

Frequently asked questions

Can a council require anything it likes on its local list?

No. A local requirement can only be insisted on where the information is reasonable having regard to the nature and scale of the proposal and is a material consideration in determining that application. In practice, challenging an item takes longer than supplying it, so reserve the argument for requirements that are plainly disproportionate to what you are proposing.

How current does the local validation list need to be?

Download it for each application. National guidance expects local lists to be kept up to date and reviewed regularly, and authorities revise them alongside new supplementary documents and plan adoption. Record the version date in your file, because an item added three months ago will still be applied to your submission.

What is the difference between the red line and the blue line?

The red line is the application site: everything needed to carry out the development, including any new access, visibility splays and land for drainage. The blue line shows other adjoining land in the applicant's ownership or control. Getting either wrong usually means the ownership certificate is wrong too, which is a more serious defect.

Can an AI-drafted report satisfy a survey requirement on the local list?

No. Survey-based documents such as bat surveys, flood risk assessments, noise assessments and structural reports need fieldwork, measurement or modelling by a qualified professional, and several require a licensed or competent person by law. A draft gives you the structure and flags the missing facts; the professional supplies the substance and takes responsibility for it.

What should I check last before submitting?

Tick your document schedule against a freshly downloaded local list, check the red and blue lines against the certificates, confirm every drawing carries a number, revision, scale and north point, search all documents for unresolved placeholder markers and wrong addresses, and check the fee against the current schedule, which is indexed each April.

Sources and further reading

validationlocal listapplication documentsarchitectssubmission

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.

More in AI and Planning

View all →
AI and Planning7 min read

Where site judgement cannot be drafted in a design statement

A draft can carry the structure, the policy references and the checklist. Context, character and the access arrangements that depend on levels come from looking.

Read article →
AI and Planning6 min read

Explaining an AI-assisted draft to a client or a committee

Sooner or later a client, an officer or an objector asks how a document was produced. A planner who has thought about the answer in advance gives a better one.

Read article →
AI and Planning7 min read

Why planning applications are returned as invalid

Validation is a completeness check against the national requirements and the council's own local list. Here are the defects that cause a return and how to deal with an invalidity notice.

Read article →
AI and Planning7 min read

Drafting to an appeal deadline without cutting corners

Appeal timetables do not move, and a statement of case submitted late is normally returned unread. Here is where drafting buys time and where only evidence will do.

Read article →
AI and Planning7 min read

Version control when report sections are regenerated

A report assembled from independently produced sections is only consistent if somebody checks it after the last edit. The dependencies that break, and the controls that catch them.

Read article →
AI and Planning7 min read

What AI drafts get right, and wrong, in planning reports

A drafting tool knows what a Transport Statement contains. It does not know what the traffic count said. Where the real review time goes on an AI-assisted planning document.

Read article →