AI and Planning

Using an AI draft at pre-application stage

6 min readBy PlanScope Editorial Team

A pre-app is not a validation exercise. Here is where a draft document earns its place, how to frame the questions, and what to do with the officer's response.

Using an AI draft for pre-application advice works well, provided you are clear about what the pre-app is for. A pre-application enquiry is not a validation exercise. Nobody is checking whether your document list is complete, and no officer will refuse an enquiry because the planning statement is a draft. What the officer will do is answer the questions you put to them, so the value of a draft at this stage is that it forces you to write down the questions properly and gives the officer something concrete to react to.

For a developer with a site under option and a board asking for a view on planning risk, that is a useful trade: a few days of drafting in exchange for a documented officer position before the design spend commits.

What officers expect in a pre-application pack

Councils publish their own pre-application requirements and fee schedules, and they differ, so start with the authority's published service description. Across most of them the expected pack is short.

  • A site location plan with the application site edged red
  • A description of the proposal, with quantum: units, floorspace, use classes, parking
  • Indicative drawings, which may be sketch level
  • A statement of the planning case, referencing the development plan
  • A specific list of questions
  • The fee, calculated from the published band

The statement of the planning case is where a draft earns its place. Officers read a lot of enquiry letters that describe a proposal without engaging with policy. A draft Planning Statement that identifies the relevant development plan policies and states how the scheme responds to each gives the officer a structure to answer within, and their response tends to follow the same structure back.

Where a draft saves the most time

Not everywhere. The honest split is that drafting helps most with the parts of a document that are structural and policy-led, and least with the parts that require site knowledge or specialist judgement.

Document Value of a draft at pre-app Reason
Planning statement High Policy structure and site history are desk work
Design and access statement Moderate Needs site observation to be worth reading
Heritage statement Moderate Significance assessment needs the building
Transport statement Low at pre-app Needs trip data and highway authority input
Ecology reports None Survey-based and season-constrained

The pattern is consistent: where the content is policy analysis and site history, a draft is a genuine time saving. Where the content is observation or measurement, it is a template waiting for facts, and submitting it at pre-app wastes the officer's attention. The Design and Access Statement in particular reads badly without a site visit behind it.

Framing questions the officer can answer

This is the part most enquiries get wrong. "Would the council support this?" invites a non-committal answer. Specific questions get specific answers, and specific answers are what you can take to a board.

  1. Is the principle of development on this site acceptable in policy terms, and which policies are engaged?
  2. Which of the identified constraints does the authority consider determinative, as opposed to manageable by design?
  3. On the indicative scheme, what would the officer expect to see changed before an application is submitted?
  4. Which supporting documents will the validation checklist require, and are any local requirements additional to the national list?
  5. What is the officer's view on affordable housing provision and the likely section 106 heads of terms?
  6. Is the application likely to be determined under delegated powers or by committee?

Question four is worth asking even when you think you know the answer, because local validation lists vary and a written answer is a defence against invalidation later.

Question two separates the site-killing issues from the design problems, which is the distinction a board actually needs.

Marking a document as draft

Label it. "Draft for pre-application discussion" on the cover and in the footer of every page, with a version number and a date.

Two reasons. The obvious one is that an unmarked draft can be treated as a final position, and you do not want to argue later that a paragraph you have since changed was provisional. The less obvious one is that an officer reading a document marked as a draft engages with it differently, offering comments on content rather than treating it as a submission to be assessed.

Where the draft includes flags for facts you have not yet established, leave them visible rather than filling them with plausible text. A document that says the site levels are to be confirmed by survey is more credible than one that guesses them, and officers who spot a guessed figure discount the rest. The related habit of checking a draft for exactly this kind of error is covered in factual errors to look for in a drafted planning document.

Using officer feedback to revise

The response is usually a letter, sometimes a meeting followed by a letter, and it is not binding on the authority. Treat it as the best available evidence of how the case will be assessed, not as a decision.

What to do with it, in order. Extract every point the officer raised into a list. Categorise each as a design change, an evidence requirement, an obligation, or a disagreement. Address the design changes in the scheme. Programme the evidence requirements, particularly any that are season-constrained, because an ecology or noise survey window can be the critical path item. Price the obligations. And for the disagreements, decide whether to concede or to build the argument, and if you are building the argument say so in the eventual submission rather than leaving the officer to notice.

Then update the draft against the feedback and keep both versions. A submission that visibly responds to pre-application advice is easier for an officer to recommend, because it shows the advice was taken seriously.

Planning performance agreements for larger schemes

On a major scheme a planning performance agreement is usually better value than a standard pre-application service. It sets out a programme, the officer and consultee resource, and the milestones, and it gives you a named case officer for the duration.

They are not free and they are not a guarantee of a particular outcome. What they buy is predictability, which on a scheme with a funding deadline is worth a great deal. Where the scheme is referable to the Mayor of London or involves statutory consultees such as National Highways or the Environment Agency, the agreement can also cover their engagement, which removes the worst source of programme risk.

The cost of pre-application advice

Fees are set by each authority and published in a schedule, usually banded by scheme scale and sometimes with different bands for written advice and for a meeting. They are revised, so take the current figure from the authority's own published schedule rather than relying on a figure from a previous scheme.

Weigh it against the alternative. A refused application costs the application fee, the programme, the consultant fees for documents produced only to satisfy validation, and the delay to a land transaction. Against that, a pre-application fee and a fortnight of drafting is generally the right order of spending.

Where the draft documents themselves are the cost you are trying to control, PlanScope pricing covers one free report, £50 per report, or £150 per month for unlimited reports on the Professional tier for architects, agents and consultants. Drafts can then be sent for review through the professional directory before anything reaches the council.

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

Do pre-application submissions need finished documents?

No. A pre-application enquiry is not validated, so nobody checks the document list for completeness. The pack usually needs a location plan, a description with quantum, indicative drawings, a statement of the planning case, a specific list of questions and the published fee. A clearly marked draft planning statement is often the most useful item in it.

Which draft documents are worth submitting at pre-app?

Those built on policy analysis and site history, principally the planning statement. Design and access and heritage statements need site observation behind them to be worth reading. Transport work needs trip data and highway authority input, and ecology reports are survey-based and season-constrained, so neither adds much at this stage.

How should pre-application questions be worded?

Specifically. Ask whether the principle of development is acceptable and which policies are engaged, which constraints the authority treats as determinative rather than manageable, what would need to change before submission, which local validation requirements apply, the likely section 106 heads of terms, and whether the decision will be delegated or go to committee.

Is pre-application advice binding on the council?

No. It is the best available evidence of how the application will be assessed, and nothing more. Treat the response as a work list: design changes, evidence requirements, obligations and disagreements. A submission that visibly responds to the advice is easier for an officer to recommend.

When is a planning performance agreement better than standard pre-app?

On major schemes, where the agreement sets a programme, names the case officer, allocates consultee resource and can cover engagement with statutory consultees. It costs more and guarantees no particular outcome, but it buys predictability, which matters where a scheme has a funding deadline.

Sources and further reading

pre-applicationai draftingplanning statementmajor developmentprocess

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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