Local Plan Representations: Technical Evidence That Strengthens Land Promotion Strategies

The Local Plan process represents the single most significant opportunity for landowners and developers to influence development policy across an entire local authority area. Unlike individual planning applications that address site-specific proposals, Local Plan representations allow strategic influence over which land gets allocated for development over the next 15-20 years.

According to the National Planning Policy Framework, local planning authorities must maintain a continuous supply of deliverable housing sites (typically a five-year supply) and identify specific, developable sites for years 6-10 and, where possible, years 11-15 of the plan period. The Strategic Housing and Economic Land Availability Assessment (SHELAA) provides the evidence base that informs site allocations, and representations submitted during Local Plan consultations directly influence which sites progress from SHELAA assessment to formal allocation. Critically, the SHELAA itself does not allocate sites—it identifies land with development potential which the local planning authority then considers alongside other evidence when making allocation decisions through the Local Plan process.

But success in Local Plan promotion requires more than simply submitting your site to the SHELAA call for sites. Strategic land promotion demands comprehensive technical evidence demonstrating that your site is not just available and achievable, but genuinely deliverable and free from constraints that would render development unviable.

Authorities assess hundreds of promoted sites during Local Plan preparation. The sites that secure allocation aren't necessarily the largest or best-located—they're the sites backed by the most compelling technical evidence addressing deliverability, infrastructure capacity, environmental impact, and policy compliance. Technical rigour separates successful site promotion from unsuccessful.

Understanding the Local Plan Process

Local Plans establish the framework for development across a local authority area for 15-20 years. They identify how much housing and employment land is needed, where development should be located, and what infrastructure is required to support growth.

The Plan-Making Stages

Local Plan preparation follows a structured process governed by the Town and Country Planning (Local Planning) (England) Regulations 2012. The typical sequence involves evidence gathering where authorities commission studies on housing need, employment land, infrastructure capacity, and environmental constraints. Regulation 18 consultation represents the initial "Issues and Options" stage seeking views on development strategy and potential site allocations. SHELAA preparation provides technical assessment of all promoted sites for suitability, availability, and achievability.

Regulation 19 consultation is the formal consultation on the "Proposed Submission" Local Plan with specific site allocations. Following this, submission and examination occurs where an independent Planning Inspector examines the Plan's soundness, and finally adoption where the Plan becomes part of the statutory Development Plan.

The critical window for site promotion occurs during Regulation 18 and SHELAA stages. By Regulation 19, the authority has already decided which sites to allocate—representations at this later stage can challenge allocations or policy wording, but introducing new sites is exceptionally difficult.

SHELAA: The Technical Foundation

The Strategic Housing and Economic Land Availability Assessment (formerly SHLAA) is the technical evidence base that identifies potential development land. National Planning Practice Guidance sets out the methodology authorities must follow when assessing sites (GOV.UK Planning Practice Guidance).

SHELAA assessments evaluate three criteria for each promoted site. Suitability examines whether the site is appropriate for development considering planning policy, physical constraints including flood risk, heritage, ecology, and landscape, and relationship to existing settlements. Availability confirms the site is genuinely available for development through landowner confirmation, absence of legal restrictions, and realistic timescales for delivery. Achievability assesses whether development is economically viable considering abnormal costs, market conditions, and infrastructure requirements.

Sites that satisfy all three criteria progress to the authority's "developable" category and become candidates for allocation. Sites failing any criterion are typically excluded from further consideration unless circumstances change.

According to Harborough District Council's SHELAA methodology, assessments consider suitability, availability, and achievability using a traffic-light system—green indicating no constraints, amber indicating constraints that can be mitigated, and red indicating severe constraints unlikely to be overcome. Sites with multiple red ratings rarely secure allocation regardless of how well they score elsewhere.

When Representations Matter Most

Strategic timing is crucial. Call for Sites submissions can be made when authorities open SHELAA consultations—typically every 2-3 years, though some maintain ongoing submission processes. The earlier you submit, the more time the authority has to assess constraints and the more opportunity you have to address issues through additional evidence.

Regulation 18 representations occur during the initial consultation on development strategy and broad locations for growth. This is when authorities are genuinely open to considering alternative site options and development distributions. Your representation should explain why your site should be allocated, supported by technical evidence addressing all likely concerns.

Regulation 19 representations are your final opportunity, but the focus shifts from "why allocate my site" to "the Plan is unsound without my site" or "the allocated sites cannot deliver the required housing." This requires demonstrating that allocated sites have fatal flaws or insufficient capacity, and your site offers a necessary alternative. The evidential burden is substantially higher.

Technical Evidence That Strengthens SHELAA Submissions

SHELAA assessments are desk-based exercises where planning officers evaluate sites against standard criteria. The quality and comprehensiveness of evidence you provide directly influences how officers assess your site.

Evidence Type 1: Access and Highways Feasibility

One of the most common reasons sites fail SHELAA assessment is inability to demonstrate adequate access. Authorities dismiss sites as "not currently developable" if access appears problematic, even if the landowner believes solutions exist.

Strong highways evidence includes a site access appraisal prepared by highways consultants demonstrating that safe vehicular access can be achieved with acceptable visibility splays, swept path analysis showing that refuse vehicles and fire appliances can navigate the proposed access and internal road layout, and capacity assessment of the local highway network demonstrating that junctions can accommodate additional traffic or identifying what improvements would be required.

If your site requires off-site highway works—perhaps a new junction or visibility improvements—preliminary designs and cost estimates demonstrate deliverability. Authorities often reject sites requiring complex off-site works as "unachievable" unless clear evidence shows the works are feasible and fundable.

For sites with constrained access—perhaps narrow lanes or awkward geometries—Transport Statements or Transport Assessments provide the technical justification that access concerns can be overcome. Without this evidence, officers default to the conservative position that access is inadequate.

Evidence Type 2: Flood Risk and Drainage Strategy

Flood risk is an absolute constraint. Sites in Flood Zones 2 or 3 face the Sequential Test requirement—demonstrating no alternative sites at lower flood risk exist. Recent Planning Practice Guidance updates have clarified that this requirement extends to all sources of flooding, including surface water flooding, significantly expanding the number of sites potentially affected.

Comprehensive flood risk evidence includes Flood Risk Assessments (even at outline stage) demonstrating the site can be developed safely, considering all flood sources including fluvial, surface water, and groundwater, along with climate change allowances. Surface water drainage strategy shows how SuDS will manage runoff, where attenuation will be located, and discharge rates to watercourses or sewers. For sites with any flood risk, Sequential Test evidence demonstrates that no reasonable alternative sites at lower risk exist within the authority's area.

Authorities increasingly apply precautionary approaches to flood risk. A site showing even limited surface water flood risk may be rejected as "unsuitable" unless robust technical evidence demonstrates that development can avoid flood risk areas or be made safe through engineered solutions.

Recent Planning Practice Guidance clarifications mean that sites previously considered acceptable may now require additional technical justification. Early flood risk assessment and drainage strategy demonstrate you've anticipated this concern and can deliver compliant development.

Evidence Type 3: Ecology and Biodiversity Net Gain

Ecological constraints can render sites undevelopable if protected species or habitats are present, or if achieving the mandatory 10% Biodiversity Net Gain (required under the Environment Act 2021) proves unviable. Increasingly, authorities also expect sites to demonstrate alignment with Local Nature Recovery Strategies (LNRS), which identify priority habitats and ecological networks at county level.

Robust ecological evidence includes Preliminary Ecological Appraisal identifying baseline habitat value and protected species potential, demonstrating seasonal survey requirements and timescales for addressing them. Biodiversity Net Gain assessment using the Statutory Biodiversity Metric demonstrates that 10% gain can be achieved on-site or, if not, quantifies the off-site provision or statutory credit costs required. For strategic sites, Nature Recovery Strategy alignment showing how the site contributes to county-wide ecological networks, priority habitat creation, or species recovery objectives strengthens sustainability credentials beyond minimum BNG requirements.

For sites with ecological sensitivity—ancient woodland, veteran trees, protected species records—early surveys and mitigation strategies demonstrate that constraints can be managed. Authorities often reject sites as "unsuitable" if they perceive ecological issues as insurmountable. Technical evidence showing that mitigation is feasible and proportionate overcomes this objection.

BNG requirements add cost and reduce developable area. Demonstrating that your site can accommodate the required habitat creation without compromising viability is essential evidence for SHELAA achievability assessments. Sites that can deliver substantial net gain—20-30% rather than the mandatory 10%—whilst also contributing to Local Nature Recovery Strategy objectives present stronger sustainability cases during allocation decisions.

Evidence Type 4: Heritage, Landscape, and Grey Belt Assessment

Heritage and landscape designations create policy presumptions against development. Sites affecting conservation areas, listed buildings, or valued landscapes face significant evidential burdens. For sites within Green Belt, the December 2023 NPPF introduced the concept of "Grey Belt"—previously developed land and land of limited environmental value within the Green Belt—which may be suitable for development where it meets specific criteria.

Heritage and landscape evidence includes Heritage Impact Assessments demonstrating that development can be accommodated without harming the significance of heritage assets or their settings. Landscape and Visual Impact Assessments show how development integrates with landscape character and visual receptors. For Green Belt sites, Grey Belt Assessment identifying whether land constitutes previously developed land or land of limited value that does not strongly serve Green Belt purposes. Masterplanning and design concepts illustrate how sensitive design, landscaping, and layout mitigate impacts.

For sites within Green Belt, demonstrating Grey Belt status can be transformative. The NPPF now recognises that not all Green Belt land performs Green Belt functions equally. Land classified as Grey Belt—typically brownfield sites, low-quality scrubland, or land adjacent to existing development—may be considered for release where it meets the "Golden Rules" including provision of at least 50% affordable housing (subject to viability), delivery of supporting infrastructure, and enhancement of environmental quality and biodiversity.

Grey Belt Assessment requires technical evidence demonstrating that land is previously developed (meeting the NPPF definition), or that land provides limited contribution to the five Green Belt purposes (checking unrestricted sprawl, preventing neighbouring towns merging, safeguarding countryside, preserving setting and character of historic towns, assisting urban regeneration), and that development would not cause substantial harm to remaining Green Belt openness or purposes.

Authorities often conclude that sites near heritage assets or in sensitive landscapes are "unsuitable" based on desktop assessment alone. Commissioning specialist assessments that demonstrate impacts are acceptable or can be mitigated through design removes this objection.

The key is demonstrating that impact can be managed, not denied. Authorities understand that some impact is inevitable—the question is whether it's acceptable. Technical evidence that honestly assesses impact and proposes credible mitigation is more persuasive than claims that no impact will occur.

Evidence Type 5: Infrastructure Capacity and Deliverability

Sites that overload existing infrastructure—schools, GP surgeries, utilities, sewerage—face achievability questions. Authorities question whether development can actually be delivered if essential infrastructure lacks capacity. Under current policy expectations, demonstrating "infrastructure-first" delivery is increasingly critical—Inspectors expect clear evidence that essential infrastructure will be in place before or alongside development, not years afterwards.

Infrastructure evidence includes utility capacity assessments from distribution network operators for electricity, water companies for water supply and sewerage capacity, and gas networks confirming capacity exists or identifying reinforcement requirements and costs. Education and healthcare capacity reviews demonstrating that existing facilities can accommodate growth or identifying where developer contributions would fund expansion. Viability appraisals showing that infrastructure costs including Section 106/CIL contributions, off-site works, and utility reinforcement are factored into development economics. Infrastructure delivery phasing demonstrating that critical infrastructure (access, utilities, drainage) will be delivered in early phases, not deferred to later years when developer interest may have waned.

Authorities often assume the worst—if you haven't demonstrated infrastructure capacity, they assume it's inadequate. Proactive engagement with infrastructure providers and evidence that capacity exists or can be provided removes a major deliverability concern.

For larger strategic sites, Infrastructure Delivery Plans demonstrating how schools, healthcare, utilities, and transport will be phased and funded provide confidence that development is genuinely achievable. These plans should identify trigger points—at what point in development will new infrastructure be required—and funding mechanisms, whether through developer contributions, direct provision, or partnership arrangements with infrastructure providers.

Evidence Type 6: Viability and Deliverability

The ultimate SHELAA question is: will this site actually deliver housing? Sites that appear viable on paper but have hidden costs often fail achievability tests.

Viability evidence includes development appraisals demonstrating that development is economically viable after accounting for land acquisition, abnormal costs, Section 106/CIL, affordable housing obligations, and infrastructure contributions. For Grey Belt sites specifically, the NPPF's "Golden Rules" require at least 50% affordable housing provision (subject to viability), meaning viability assessments must transparently demonstrate either that this threshold can be met, or identify specific infrastructure or abnormal costs preventing it. Delivery programmes showing realistic timescales for planning approval, infrastructure provision, and build-out rates. Market evidence demonstrating demand exists for the proposed housing in this location at viable price points.

Authorities use viability as a filter—sites where viability appears marginal or uncertain are often rejected in favour of sites with clearer economics. Professional viability assessments, ideally prepared by RICS-qualified surveyors, provide credible evidence that development is deliverable.

For sites with known abnormals—contamination, ground conditions, heritage requirements—upfront cost estimates demonstrate you've accounted for these in your viability assessment. Authorities are sceptical of appraisals that ignore obvious cost items. For Grey Belt releases, demonstrating that policy requirements can be met whilst maintaining viability is essential—simply claiming that requirements make development unviable without detailed supporting evidence will not withstand examination scrutiny.

Making Effective Representations: Structure and Content

Beyond technical evidence, the representation itself must be structured persuasively. Planning officers assess hundreds of representations—clarity and structure matter.

Opening: The Strategic Case

Begin by explaining why your site should be allocated in strategic terms. Does it deliver housing in a sustainable location close to services and employment? Does it provide a natural extension to an existing settlement? Does it offer infrastructure benefits or resolve existing problems?

Frame your site as the solution to the authority's challenge—delivering housing numbers, providing affordable housing, supporting economic growth, or offering community benefits. Make the case that allocation serves the authority's objectives, not just your commercial interests.

Section 1: Suitability

Address each suitability criterion systematically. For planning policy compliance, demonstrate consistency with NPPF, emerging Local Plan strategy, and any relevant Neighbourhood Plans. For physical constraints, present technical evidence on flood risk, ecology, heritage, landscape, and explain how impacts are acceptable or can be mitigated. For locational sustainability, evidence accessibility to services, employment, schools, healthcare, and public transport.

Acknowledge constraints honestly and explain how they will be addressed. Authorities are sceptical of representations that claim no constraints exist—every site has some limitation. Credibility comes from demonstrating that constraints are manageable.

Section 2: Availability

Confirm the site is genuinely available with supporting evidence including signed landowner statements confirming availability for development, details of land ownership and if multiple owners, confirmation that all agree, and realistic timescale for delivery confirming no legal or contractual restrictions preventing development.

Authorities are cautious about sites with uncertain availability. Multiple landowners, unclear ownership, or vague timescales raise red flags. Clear evidence of control and commitment is essential.

Section 3: Achievability

Present viability evidence demonstrating development is economically deliverable. Include development appraisal summary typically an executive summary rather than full appraisal which may be commercially sensitive, infrastructure costs and how they will be funded, abnormal costs identified and costed, and market evidence supporting demand and values.

If your site requires significant infrastructure—new roads, school expansion, utility reinforcement—explain how this will be funded and delivered. Authorities question achievability if infrastructure costs appear prohibitive.

Section 4: Deliverability and Development Programme

Provide a realistic delivery trajectory showing indicative planning application timescale, infrastructure delivery programme, and housing delivery by year demonstrating contribution to five-year supply and later plan periods.

Authorities value sites that can contribute to the early years of the plan period—sites requiring lengthy infrastructure provision may be allocated for later phases. If your site can deliver quickly, emphasise this.

Section 5: Benefits and Wider Impacts

Conclude by summarising the benefits your site offers including quantum of housing delivery, affordable housing provision, employment opportunities if mixed-use, infrastructure improvements, environmental enhancements including habitat creation and public open space, and community facilities.

Frame allocation as delivering multiple policy objectives simultaneously. Sites that offer wider community benefits beyond housing numbers are more attractive to authorities and local communities.

Post-Allocation Strategy: Maintaining Momentum

Securing allocation doesn't guarantee planning permission—it creates the policy framework supporting an application. But the transition from allocation to permission requires continued technical input.

Masterplanning and Design Codes

Many allocated sites require masterplans or design codes to be agreed with the authority before detailed applications are submitted. These documents establish design principles, layout parameters, infrastructure phasing, and landscaping strategies.

Masterplanning involves multiple consultants—architects, landscape architects, highways engineers, and technical specialists coordinating the vision. Early masterplanning engagement, ideally pre-application discussions with the authority, ensures your proposals align with policy expectations.

Infrastructure Delivery and Section 106

Allocated sites typically require Section 106 agreements securing affordable housing, financial contributions for education, healthcare, libraries, and public transport, on-site infrastructure including roads, drainage, and public open space, and phasing and trigger points for delivery.

Negotiating Section 106 agreements requires understanding policy requirements, viability constraints, and infrastructure priorities. Legal and viability advisers work alongside technical specialists to structure obligations that satisfy policy whilst maintaining development viability.

Reserved Matters and Discharge of Conditions

For outline permissions, Reserved Matters applications require detailed technical submissions including final site layouts, building designs, landscaping schemes, and materials specifications. These must align with parameters approved at outline stage whilst satisfying detailed design and technical requirements.

Conditions attached to outline permissions require discharge through technical submissions—drainage strategies, construction management plans, ecological mitigation, archaeological investigations, and contamination remediation. Technical specialists coordinate these submissions, ensuring conditions are discharged efficiently without delaying construction programmes.

The Sovatech Approach: Technical Evidence for Strategic Land Promotion

At Sovatech Consulting, we coordinate the technical evidence that strengthens SHELAA submissions and Local Plan representations. Our role involves preparing site location plans and constraint mapping at appropriate scales, coordinating technical assessments across multiple disciplines including highways, flood risk, ecology, and heritage, ensuring consistency between technical evidence and representation narrative, and liaising with local planning authorities to understand assessment criteria and address concerns.

We understand that Local Plan promotion is a long-term strategic process requiring sustained technical input across multiple consultation stages. The sites that secure allocation are those where landowners and promoters invest early in comprehensive technical evidence, addressing constraints proactively rather than waiting for the authority to identify problems.

Our expertise in technical drawing, regulatory compliance, and multi-disciplinary coordination ensures your SHELAA submission and Local Plan representations are supported by credible, professional evidence that addresses the authority's deliverability concerns. We work alongside your planning consultants, providing the technical foundation that transforms a promoted site into an allocated development opportunity.

Strategic Land Promotion: Investing Early for Long-Term Returns

Local Plan allocations create substantial land value uplift—agricultural land worth £10,000-20,000 per acre can become residential development land worth £500,000-1,000,000+ per acre. But capturing this value requires strategic investment in technical evidence, professional representation, and sustained engagement across the plan-making process.

The landowners and promoters who succeed in Local Plan processes are those who recognise that strategic land promotion isn't a lottery—it's a technical and evidential process. Authorities allocate sites where deliverability is demonstrated, not assumed. Comprehensive technical evidence, coordinated across multiple disciplines and presented through structured, persuasive representations, separates successful promotions from unsuccessful.

The opportunity to influence Local Plan allocations occurs infrequently—typically once every 5-10 years as authorities review their plans. Missing the SHELAA submission window or submitting without adequate technical evidence means waiting years for the next opportunity.

If you're promoting land through the Local Plan process and need technical evidence to strengthen your SHELAA submission or Regulation 18/19 representations, contact Sovatech Consulting. We'll coordinate the technical assessments, site plans, and constraint analysis that demonstrate deliverability—helping you secure allocation and unlock development value.