Darren Muir, senior director – planning at the Pegasus Group, discusses the intricacies of making planning decisions
There’s a growing narrative in planning reform that if everyone simply “gets it right first time”, the system will run faster, smoother, and with fewer disputes. It’s a neat idea. It’s also wrong.
This notion assumes that planning decisions are a matter of identifying a single correct answer and presenting it clearly enough, but we all know that isn’t how it works. Planning is not a multiple-choice test. It is a discipline built on interpretation, balance, and professional judgement.
That’s why the latest changes to the Planning Inspectorate’s Procedural Guide for Planning Appeals for applications from 1 April 2026 deserve closer scrutiny. While the intent is clear, namely greater efficiency and consistency, the risk is that in tightening the process, we lose some of the nuance that good decision-making depends on.
A significant change in planning approach
The most notable change is the move toward fully front-loading appeals. In practical terms, that means the Full Statement of Case will now largely be gone for many written representations appeals. Instead, appellants are expected to present everything at the time of submission. That includes covering every potential argument, every technical report, every piece of supporting evidence.
There’s a certain logic to this approach. It should mean quicker decisions and less back-and-forth, but it also changes the nature of the process and, more importantly, the assumptions that sit behind it.
There is an implicit suggestion in the new approach that applicants should simply “get it right first time”. From a purely process perspective, this framing makes sense, but it fundamentally misunderstands how planning decisions are actually made, and the issue is not that applicants are getting it wrong.
More often than not, applications are supported by extensive technical evidence, professional advice, and a clear interpretation of policy. The reality is that planning decisions frequently turn on matters of judgment, such as on how policies are interpreted, how weight is applied to aspects of a proposal, and how competing considerations are balanced.
Appeals exist because there is no single, universally “correct” answer in many cases. This is precisely where you start to see why planning can’t be reduced to a purely technical exercise, and like it or not, planning is both an art and a science.
There is, of course, a scientific element to planning: data, modelling, standards, compliance. But layered over that is something less tangible: professional judgement. For example, how much weight should be given to design quality versus policy conflict? At what point does harm become unacceptable? How should precedent and appeal decisions influence current schemes? These are not questions with fixed answers; they require interpretation, experience, and, at times, debate.
The value of appeals
The appeal process has traditionally provided a forum for that debate to play out; to test positions, to refine arguments, and to allow Inspectors to arrive at a balanced view having seen the issues fully explored. By compressing everything into a single upfront submission, we risk reducing the space for genuine planning judgment to emerge.
The revised guide makes it clear that late evidence will be the exception, not the norm. That is understandable in principle. Nobody benefits from endless rounds of submissions. However, the pendulum may have swung too far if the underlying assumption is that any need for further evidence or clarification reflects a failure by the applicant.
In reality, it often reflects the opposite: a process where different interpretations are tested, new points raised, and the planning balance actively examined – rather than just a failure. That is not inefficiency, but rather the system doing what it is supposed to do.
The concern is that by limiting that process, we move toward a model in which appeals are determined by a fixed snapshot of evidence, rather than through a fuller exploration of the issues.
Practical concerns
In practice, the implications are immediate. This is not a case of raising standards; indeed, these should already be high. It’s about removing the flexibility to refine a case once it’s in play and expecting everything to be settled at the point of submission. There is far less scope to respond to evolving positions.
With reduced scope and flexibility, there will inevitably be a cost implication. More work is pushed up front, which increases risk, particularly for smaller SME developers who may not have the resources to assemble a fully loaded, appeal-ready case at the outset. It also subtly shifts the nature of the appeal process itself, from a forum for testing planning judgement to a more fixed, document-led exercise.
To be clear, the drive for reform is understandable. The appeal system can be slow, and there is a legitimate case for making it more efficient, but efficiency is not the same as effectiveness. A faster decision is not necessarily a better one. In a system where decisions shape places, communities, and economic growth, getting it wrong has consequences.
Less room to manoeuvre
The concern with the updated guidance is not that it will fail to speed things up. It almost certainly will expedite processes. The concern is that it may do so by narrowing the space for planning judgment, and by operating on the assumption that there is a single “right” answer that simply needs to be presented correctly at the outset.
The new appeals regime will demand more from everyone involved – clearer thinking, earlier preparation, and greater precision. That’s no bad thing. But planning is not about ticking the right boxes the first time. It is about balancing competing considerations, interpreting policy, and exercising judgment. It is, fundamentally, both an art and a science, and a system that prioritises one over the other risks producing poorer decisions.
We are already seeing how these changes are shaping advice to clients, requiring earlier strategic input, tighter alignment between technical disciplines, and a more forensic approach to applications. But to be very clear on one point: a planning system that values speed over scrutiny risks undermining the very confidence it is trying to build.
The challenge now is not simply to adapt to the new rules, but to ensure that in doing so, we don’t lose sight of what good planning looks like. In the end, getting the right answer still matters more than getting there quickly.
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