A Structural Problem in Plan-Led Decision-Making
Planning decisions and Local Plan consultations are commonly described as evidence-led. In practice, many now proceed in circumstances where authorities openly acknowledge that essential infrastructure requirements cannot currently be funded, delivered, or fully evidenced.
This research is not concerned with whether development is desirable, nor with questions of housing need, ambition, or political preference. It examines a narrower issue: whether statutory planning decisions are being taken on the basis of an evidential foundation that authorities themselves accept does not fully exist.
Over the past year, I have analysed planning decisions and plan-making material across more than fifty local authorities using PGAT (the Planning Governance Assessment Tool), supported by detailed follow-up research including committee transcripts, consultation documents, infrastructure funding statements, and FOI responses.
Method and scope
PGAT is designed to identify governance and decision-stage evidential issues quickly. It allows decision-making failures to be detected in minutes rather than months, but it does not replace detailed investigation.
Once an issue is identified, further work is required. This includes:
- reviewing Local Plan policies and the evidence they claim to rely upon;
- examining committee reports and officer recommendations;
- analysing infrastructure funding statements and transport material;
- transcribing committee meetings and audio recordings;
- converting image-based PDFs into searchable text;
- seeking confirmation through FOI where evidence is said to exist but is not published.
This process has been repeated across authorities at different stages of plan preparation, under different political control, and in different regions. The outcome has been consistent.
What the public record now shows
Across multiple authorities, committee reports, infrastructure topic papers, infrastructure funding statements, and monitoring discussions now routinely acknowledge:
- large gaps between identified infrastructure costs and available funding;
- reliance on future or hypothetical funding mechanisms;
- viability constraints that limit what development can realistically contribute;
- uncertainty as to whether key infrastructure can be delivered at all.
In parallel, Local Plan policies and decision-making frameworks continue to assume the existence of strategic infrastructure evidence covering matters such as transport capacity, walking and cycling safety, accessibility, and wider network impacts.
In several cases, authorities have expressly confirmed—through complaint responses or FOI disclosures—that such evidence does not exist in a completed or usable form.
Despite this, consultations and planning decisions proceed on the basis that proposals are supported by evidence.
Procedural fairness
This research is not directed at planning merits or eventual outcomes. It does not ask whether a plan will ultimately be found sound, or whether development should or should not proceed.
The issue is procedural fairness.
Consultation and decision-making assume that affected parties are engaging with proposals supported by relevant evidence. Where entire categories of infrastructure evidence are acknowledged to be absent, that assumption no longer holds.
An iterative plan-making process may justify refinement of existing evidence. It does not justify consultation or decision-making where key categories of evidence are confirmed not to exist at all.
Where an authority proceeds with plan-led decision-making while admitting that required categories of infrastructure evidence do not exist, decisions taken within that framework are procedurally unfair.
Why this condition is systemic
The consistency of these findings across every authority examined indicates that this is not a matter of isolated failure or poor local practice.
Infrastructure funding deficits are now structural. Authorities are aware that the infrastructure implied by plan-led growth cannot realistically be funded or delivered at the scale assumed.
At the same time, national policy requires housing delivery and the maintenance of an up-to-date plan. Failure to do so carries significant consequences.
Authorities therefore operate within a constrained set of options:
- acknowledging evidential absence risks undermining the plan;
- delaying plan-making risks policy failure or intervention;
- proceeding honestly exposes the gap between policy expectation and fiscal reality.
The result is a system in which decision-making proceeds on an evidential fiction, not because councils are acting improperly, but because the legal and policy framework places them in an impossible position.
Conclusion
This research does not argue that planning decisions should be invalidated wholesale, nor that development should cease.
It identifies a structural condition in which procedural unfairness has become embedded in plan-led decision-making, as a consequence of misalignment between legal expectation, policy requirement, and funding reality.
Until that contradiction is addressed at a framework level, planning decisions will continue to be taken in circumstances where evidential completeness is assumed but not present.
The issue is not individual error. It is systemic impossibility.
How change occurs within the planning system
The issues identified here cannot be resolved by individual authorities acting alone. Nor can they be corrected through isolated decision-making challenges or localised reform.
Planning authorities, inspectors, and consultees all operate within a shared legal and policy framework. Where that framework places actors in an impossible position, individual compliance or non-compliance is not the decisive factor.
In practice, change within the planning system tends to occur only when a condition is recognised as systemic rather than local, and when responsibility is understood to sit at framework level rather than with individual decision-makers.
Historically, this has happened not through accusation or litigation alone, but through the gradual accumulation of evidence showing that a problem is structural, repeatable, and unavoidable under existing rules.
When shared constraints are acknowledged openly, professional norms begin to shift. Expectations adjust, guidance evolves, and the space for honest reform emerges without requiring individual actors to admit fault or assume disproportionate risk.
The purpose of setting out these findings is therefore not to undermine planning decisions, but to make visible a condition that cannot be resolved at local level and cannot be addressed while it remains unspoken.
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