Writing the alternatives considered section of a statement

Most planning applications need no alternatives section at all. English planning law contains no general duty to demonstrate that the proposal is the best of several options, and an applicant who volunteers a weak alternatives chapter usually hands objectors a free argument. So the first task when someone asks for an alternatives considered planning statement section is to work out whether any duty is actually engaged.

Three situations engage one. The project is EIA development. A policy test requires a sequential or comparative search. Or the scheme depends on an argument that only works if alternatives have been excluded, such as very special circumstances in the Green Belt or the absence of a satisfactory alternative in a protected species licence application.

Where the duty actually bites

Schedule 4 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 sets out what an Environmental Statement must contain. Paragraph 2 asks for a description of the reasonable alternatives studied by the developer, which are relevant to the project and its specific characteristics, together with an indication of the main reasons for the option chosen, taking into account the effects of the project on the environment.

Read that carefully. The obligation attaches to alternatives the developer studied. It does not require a blank-sheet appraisal of every site in the district, and it does not oblige a developer to study alternatives it had no intention of pursuing. What it does require is honesty about the options that were on the table.

Outside EIA, the tests are specific and self-contained:

1. The flood sequential test requires the authority to be satisfied there are no reasonably available sites at lower flood risk, applied across a defined search area.
2. The retail sequential test applies to main town centre uses outside a centre, working through centre, edge of centre, then out of centre.
3. Green Belt very special circumstances arguments almost always require alternatives to have been examined, because the absence of a non-Green Belt option is part of the case.
4. Regulation 64 of the habitats regulations requires that there are no alternative solutions before derogation is available.
5. A European protected species licence requires there to be no satisfactory alternative.

Each of these has its own search area, its own definition of availability and its own evidential standard. Running them together in one loose chapter is how the argument gets lost.

Alternative sites, and why the courts treat them as a narrow exception

The general position in the case law is that the merits of an alternative site are not a material consideration in the ordinary run of applications. An authority decides the application before it, not a comparison exercise.

Alternative sites become relevant where the development would have inevitable adverse effects whatever its location, where the proposal would be likely to inhibit development of another site, or where the case for the scheme rests on need that could be met elsewhere. That is a narrow category. Writing a long alternative sites appraisal for a suburban infill scheme achieves nothing except to invite a consultee to suggest a site you had not thought of.

Where an alternative sites appraisal is actually needed, define the search area first and say why that area is the right one. Then set out the availability criteria, apply them consistently, and record the date of the search. A search area chosen after the result is known is transparent to anyone who reads it twice.

Design evolution, written from the record

For non-EIA schemes, the useful version of this section is the design evolution narrative in a design and access statement. It explains how the scheme moved from first sketch to submitted drawing, and what moved it.

The material for that narrative already exists. Pre-application meeting notes, officer comments, the arboricultural constraints plan, daylight test results, the highway authority's view on the access position, the consultation feedback. Write it from those records and the section carries conviction, because each change has a cause attached to it.

Written after the fact, from memory, it reads as marketing. Case officers read a lot of these and can tell the difference.

Being honest about rejected options

A rejected option deserves a short paragraph: what it was, what it would have delivered, why it was not taken forward. Two or three sentences each is usually enough.

Two failure modes are worth naming. The first is the strawman, an option included purely so the chosen scheme looks inevitable, usually described in language that gives it away. The second is the omission, where an obvious option that was discussed internally is simply left out, and then surfaces in an objection or at a hearing. The second is more damaging, because it attacks the credibility of everything else in the document.

Illustrative example: a scheme of 48 flats on a former builders yard with a listed terrace to the north. The record shows three tested massings: a uniform five storeys, a stepped block dropping to three at the north boundary, and a courtyard arrangement. The stepped option was chosen after a daylight study showed the courtyard failed vertical sky component targets to two neighbouring flats, and the uniform option was resisted by the conservation officer at pre-application. Three short paragraphs, each with its evidence named, does the job. This example is illustrative rather than drawn from a real scheme.

Connecting alternatives to the mitigation hierarchy

Alternatives are the first rung of the mitigation hierarchy. Avoidance comes before reduction, and reduction before compensation, which means the alternatives section is the place where avoidance is evidenced.

That gives the section a practical use even where no legal duty applies. If the ecology chapter proposes compensation for the loss of a hedgerow, a reader will reasonably ask whether a layout avoiding the hedgerow was tested. Answering that question inside the alternatives section, with the layout study referenced, closes the loop before a consultee opens it.

A working outline

For a mid-size scheme that is EIA development, the chapter structure below covers Schedule 4 without padding:

1. The requirement, stated in one paragraph with the regulation cited.
2. The project objectives against which options were tested, stated before the options themselves.
3. Alternative sites, where studied, with the search area, criteria and date.
4. Alternative scales and quanta, with the reason each was set aside.
5. Alternative layouts and access arrangements, cross-referred to the technical studies that decided them.
6. Alternative processes or technologies, where the project type makes that relevant.
7. The do-nothing case, described as the baseline against which effects are measured.
8. The reasons for the chosen option, expressed as environmental effects rather than as commercial preference.

Keep each entry to the length the evidence supports. And resist the temptation to reuse the chapter on the next project, because a reader who has seen both will notice.

An Environmental Impact Assessment must be prepared by competent experts under the Regulations, so an AI-assisted draft of this chapter is a starting point for that team rather than a substitute for it. The same applies to the planning statement that carries the policy argument. You can see the full set of report types and start a draft from the outline above.

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