Planning without infrastructure evidence: a governance problem hiding in plain sight
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 is not an argument about ambition, growth, or political preference. It is a governance issue: whether decision-makers are being asked to exercise statutory powers in the absence of evidential closure on matters that are central to deliverability.
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.
These acknowledgements are not marginal. They are often made explicitly in committee, sometimes described as central risks to plan soundness or delivery.
Once such matters are acknowledged on the public record, they form part of the decision context.
Evidence versus assumption
A critical distinction must be drawn between evidence and assumption.
- Evidence consists of completed assessments, funding strategies, and delivery mechanisms capable of supporting planning judgments at the time they are made.
- Assumption consists of expectations that funding will be secured, infrastructure will follow, or viability constraints will resolve themselves over time.
Planning law tolerates judgment where evidence exists. It becomes procedurally fragile where assumption substitutes for evidence on matters that are foundational to the decision.
Infrastructure funding gaps and deliverability
Infrastructure is not an optional add-on to development. It is often relied upon to justify site allocations, settlement growth, sustainability conclusions, and mitigation of impacts.
Where authorities acknowledge that:
- the cost of required infrastructure substantially exceeds identified funding;
- developer contributions fall far short of what would be needed;
- alternative funding sources are uncertain or aspirational;
the question becomes unavoidable: whether deliverability is being demonstrated, or merely hoped for.
This is not a criticism of officers or members. It reflects a system under fiscal pressure. But fiscal pressure does not remove procedural obligations.
The consultation problem
Consultation presupposes that the public is engaging with proposals informed by an evidential framework.
Where the public record shows that:
- infrastructure requirements are known but unfunded;
- delivery mechanisms are unresolved;
- key impacts depend on infrastructure that may not materialise;
consultees are being asked to respond to outcomes without clarity on whether the supporting conditions can be met.
This raises issues of procedural fairness, regardless of how extensive or well-intentioned the consultation exercise may be.
Decision-making under acknowledged uncertainty
The most significant governance shift in recent years is not hidden failure, but open acknowledgement of uncertainty.
Committees increasingly proceed while recognising that:
- infrastructure funding gaps are real;
- solutions are not yet identified;
- delivery risk is being carried forward.
Once this occurs, decisions are no longer taken on the basis that infrastructure is secured, but on the basis that the problem will be addressed later.
That shift has profound implications for governance, because it moves the system away from evidence-led determination and towards risk-managed assumption.
Why this is systemic
This pattern is not authority-specific. It reflects a wider condition in plan-making:
- infrastructure costs rising faster than funding capacity;
- viability limits constraining contributions;
- central funding uncertainty;
- pressure to maintain plan progress despite unresolved deficits.
The result is a planning system that continues to function procedurally, while carrying unresolved delivery risk through successive stages.
Conclusion
Planning decisions do not fail because authorities lack ambition. They fail where ambition is allowed to replace evidence.
The public record now shows a growing disconnect between acknowledged infrastructure requirements and demonstrated deliverability.
This is not a question of planning merits. It is a question of governance: whether statutory powers are being exercised in circumstances where the evidential foundations are knowingly incomplete.
That question is increasingly central to plan soundness, procedural fairness, and public confidence in the planning system.
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