Drawings for planning applications: what needs to be submitted?

 
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I recently submitted a planning application but the Local Planning Authority (LPA) wouldn’t accept it because the drawings were ‘incomplete’.

This was really annoying as I’d worked hard to make the submission, only to find some time later that there was a problem. By the time matters had been notified, corrected and resubmitted, the whole application process had been delayed by a couple of weeks.

Not surprisingly, the clients were frustrated by this, and naturally expected their architect to know what needed to be submitted in the first place.

So what was the problem in this instance and what should I have done to avoid it?

It turned out that I hadn’t submitted a roof plan and, unlike other LPA’s, this one had a specific requirement that all applications should include a roof plan. Obviously, with hindsight, I should have known that.

But the question remains, how do you know what needs to be submitted and in what circumstances?

The answers are not as clear cut as you might think they ought to be. They can be found partly at national level, through the Town & Country Planning Act and partly at local level, through a ‘Local List’ of requirements set by the LPA.

National requirements

The Town & Country Planning Act requires planning applications to include:

  1. A plan which identifies the land to which the application relates.

  2. Any other plans, drawings and information necessary to describe the development which is the subject of the application.

The first requirement results in the need for a ‘location plan’ and the second requirement results in whatever else is necessary. Neither requirement is very informative.

The Act also requires that ‘any plans or drawings required to be provided … must be drawn to an identified scale and, in the case of plans, must show the direction of North’.

That’s about as far as the Act goes. The UK Government website does, however, give further guidance. Regarding location plans:

A location plan should be based on an up-to-date map. The scale should typically be 1:1250 or 1:2500, but wherever possible the plan should be scaled to fit onto A4 or A3 size paper. A location plan should identify sufficient roads and/or buildings on land adjoining the application site to ensure that the exact location of the application site is clear.

The application site should be edged clearly with a red line on the location plan. It should include all land necessary to carry out the proposed development (eg land required for access to the site from a public highway, visibility splays, landscaping, car parking and open areas around buildings). A blue line should be drawn around any other land owned by the applicant, close to or adjoining the application site.

Regarding other drawings it advises the following:

Additional plans and drawings will in most cases be necessary to describe the proposed development…

These may be requested by the local planning authority through their local list of information requirements, where it is reasonable to do so.

Reference is then made to the National Planning Policy Framework (NPPF):

Local planning authorities should publish a list of their information requirements for applications, which should be proportionate to the nature and scale of development proposals and reviewed on a frequent basis. Local planning authorities should only request supporting information that is relevant, necessary and material to the application in question.

In other words, apart from the location plan which is a legal requirement, it is down to the LPA to decide what drawings should be submitted with an application. Which means that you’re going to need to know what those requirements are for the LPA that is relevant to your project.

I have included links to the various references above and would recommend that you look them up. Knowing the source of the requirements is really important and you will probably come across other things of interest while you’re looking.

Local list requirements

In preparing this post, I checked out the ‘Local Lists’ of two Local Planning Authorities which we work with on a regular basis: Bristol City Council and Cheshire West and Cheshire Council (CWAC).

Bristol has, what looks like, a detailed schedule of requirements for drawing submissions which you can see here…

In fact, on closer inspection, some of it is prescriptive and some of it isn’t. For instance, regarding roof plans, the document tells you what to include on a roof plan but it doesn’t tell you in what circumstances one should be submitted.

I couldn’t find anything on the CWAC website and so I rang a senior planning officer to make enquiries. I was informed that they didn’t have a specific list of requirements and assess each application on its merits. At least they were open and honest about it!

These are interesting examples. On the one hand, Bristol has, what looks like a detailed schedule, but which is only partially prescriptive, on the hand CWAC don’t have any guidance at all and just try to be reasonable about things.

As is so often the case, you are left to make your own judgement. Which is all well and good until someone disagrees with what you think is reasonable.

The real answer

The location plan, with the red and blue lines defining the application site and other ownership respectively, is a legal requirement that needs to be followed precisely.

Everything else is according to what might be ‘reasonably required’ and it is the LPA that has the last say. The best situation is when you’re used to working with a particular LPA and you have experience of what they want. Failing this, when working with a LPA for the first time, it would be worthwhile checking out their local list or speaking directly with the validation team or planning officer.

Here are some things that can sometimes catch you out, if not included:

  • A roof plan (obviously).

  • A cross-section showing proposed floor levels or storey heights.

  • Relating proposed floor levels to the level of a permanent site feature.

  • Relating proposed roof levels to the roof levels of adjoining or nearby properties.

  • Showing the proposal in context, eg an infill proposal shown within the street elevation.

It would be tempting to think that including every possibility would be a good fail-safe thing to do. But you need to be careful about submitting more information than is strictly necessary, since the resulting consent will require the development to be carried out ‘in accordance with the approved drawings’. And, of course, more drawings mean more time and cost.

Some tips

Bearing in mind my ambition to submit just the right amount of drawn information for a planning application, here are some issues that come up all the time and my response to them:

Dimensions: I avoid putting dimensions on planning applications (unless for a particularly good reason) which means that the size can only be determined by reference to the scale bar. This leaves things slightly more approximate, which is to your advantage.

Relevance: I avoid including information that is not relevant. This sounds obvious but needs some consideration. Here are some examples:

  • I wouldn’t draw the upper floor plans of an existing building if the proposal is limited to the ground floor.

  • I wouldn’t draw the front elevation of an existing building if the proposal is wholly to the rear, although I might include a photograph of it on the drawings.

  • If a building is being demolished and replaced, I would draw the elevations and the plan of the external perimeter, but I would avoid drawing the internal plan arrangement.

For illustration purposes only: There are often drawings that you want to include but you don’t want to be part of the formal drawing set. Such drawings might include ‘an indicative landscape plan’ to show the proposal in context, or ‘3D views’. These can be very useful in supporting your proposals but they should be labelled ‘indicative’ or ‘for illustration purposes’, or be included in the Design & Access Statement only.

Finally

As I write, I have just been informed that an application submitted a few days ago, will not go through the LPA’s validation process for another four weeks because of staff shortages. If the submission is ok, the start date will be taken to be the submission date, which is fine. If the submission is not ok, it will be start again time, which is definitely not fine.

Which only serves to emphasise how important it is to get it right, and for you to be confident in your assessment of what might reasonably be required:

  • Don't assume anything.
  • Think it through each time.
  • Go back and check the Local List for the particular LPA.
  • If unsure, seek confirmation (preferably in writing) directly from the LPA.
 
Andy FosterComment