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Fixing the Pinch Points: The Future of Infrastructure Planning
The UK government has launched a consultation on streamlining the infrastructure planning system. It sits within the wider reform agenda being taken forward through the Planning and Infrastructure Bill (‘the draft Bill’), which is currently before Parliament. The Bill sets the statutory framework for reform, while the consultation seeks views on how those changes should be implemented in practice.
 
For promoters and operators, this is more than a technical exercise. It is a chance to influence the rules that will shape how nationally significant projects are brought forward. The real opportunity is to make sure reforms work on the ground, not just on paper. The stakes are high: these reforms will help determine whether Britain can deliver the energy, transport, digital, water networks and other national infrastructure needed to underpin growth and net zero.
 
I consider the consultation through three lenses: starting smarter, focusing sharper, and delivering faster.

Theme 1: Starting Smarter – Engagement and Early Steps

  
(i) Rethinking How We Talk to Communities (Pre-Application reform)
  
  • The Draft Bill: Removes the statutory requirement for pre-application consultation. 
  • Consultation: Seeks views on replacing that duty with an expectation that applicants demonstrate effective engagement, supported by PINS guidance.
Nearly ten years ago, as a bright-eyed young(er) planner armed with spreadsheets and plenty of optimism, I prepared a paper called DCO: Friend or Foe? The research showed that while the NSIP regime was delivering decisions in about three years on average, the pre-application stage was the real wildcard — lasting anywhere from 7 months to 4.5 years, with projects spending on average about 16 months in pre-application.
 
A decade on, the picture looks remarkably similar. The government’s 10-year infrastructure plan published in June 2025 notes that it took on average 3.6 years to secure a DCO in 2024, compared with 2.6 years in 2012. These figures cover the whole DCO journey, just as my research did a decade ago, and both highlight the same issue: while examinations and decisions have largely kept to their statutory timetables, it is the front end that continues to stretch.
 
That is why the consultation matters. Rather than keeping rigid statutory duties, the government wants to shift the emphasis onto outcomes: that applicants engage meaningfully, that this feeds into stronger applications, and that PINS can judge at Acceptance whether a scheme is genuinely ready to proceed. Done well, this could replace process-driven consultation with a more flexible system that rewards quality and readiness.
 
Upside
  • Freedom to design engagement that fits each project.
  • Space for digital tools and innovative engagement methods.
Watchpoints
  • Without clear guidance, there is a risk of inconsistency in how the quality of engagement is judged at the Acceptance stage.
  • Greater need for evidence of effective engagement to withstand scrutiny.
  • Danger of losing community buy-in if consultation feels lighter-touch.

 

(ii) Cutting Red Tape at the Start Line (Notification, Publicity, Acceptance)
 
  • The Draft Bill: Creates scope for modernised notification and publicity requirements.
  • Consultation: Seeks views on how these should operate, including whether wider consultation requirements at Acceptance should also be streamlined. It also proposes giving applicants the chance to rectify issues within the 28-day Acceptance Stage rather than risk outright rejection, and introducing a “suitable to proceed” assessment to give PINS a basis to decide if an application is ready to move to the next phase of the process.
 
The acceptance gateway is critical. By this point, applicants have already invested heavily, so procedural knockbacks can be costly. Currently, relatively small deficiencies in notification, publicity or other procedural consultation requirements can derail applications, even when the underlying scheme is sound. Allowing fixes within the statutory window is a pragmatic step that should prevent unnecessary delays and wasted effort.
 
Upside
  • A safety valve for applicants to resolve issues quickly. 
  • Fewer delays for minor technical errors.
  • More proportionate publicity requirements.
Watchpoints
  • Transition arrangements must be clear for projects already in preparation.
  • Streamlining must still ensure transparency and public awareness. 
  • Consistency in how Examining Authorities apply the rectification process.

 

Theme 2: Focusing Sharper — Examinations and Consultees

 

(i) Clarity from Day One (Initial Assessments of Principal Issues)
 
  • The Draft Bill: Strengthens the statutory basis for Initial Assessments of Principal Issues (IAPIs).
  • Consultation: Seeks feedback on how IAPIs should be structured, standardised, and used to keep examinations focused on the most important matters.

 

In my earlier research I found that the statutory stages once applications were submitted were relatively predictable, typically taking around 16–18 months. The government now wants to make these stages even more effective by sharpening the tools used within them. Strengthened IAPIs are intended to give examinations clearer focus from the outset, helping the Examining Authority identify the key issues early and structure hearings and written questions around them. This reflects the government’s recognition that there is scope to tighten parts of the DCO process after submission, not just pre-application.
 
Upside
  • Clearer focus on what matters most to the Examining Authority. 
  • Reduced scattergun questioning and diversions.
Watchpoints
  • Overlooked issues missed at the IAPI stage may resurface later.
  • A sharper focus may require more evidence upfront, shifting some costs into pre-application.

       

(ii) Making Consultees Part of the Solution (Roles of Public Bodies)
 
  • The Draft Bill: Places clearer duties on statutory consultees and relevant local authorities.
  • Consultation: Seeks views on guidance clarifying expectations, timing, and resourcing.
 
Public body consultees are vital but can be a source of delay. Late interventions or shifting positions create uncertainty for promoters. The draft Bill would require consultees to engage earlier and more predictably, and the consultation seeks views on how this would work in practice. In theory, this should streamline examinations and help applicants avoid last-minute surprises.
 
Upside
  •           More timely and constructive contributions.
  •           Fewer last-minute surprises.
Watchpoints
  •           Many consultees face resourcing challenges. Duties without funding risk being ineffective.
  •           Operators in regulated sectors need confidence that scrutiny remains rigorous.

  

(iii) Compulsory Acquisition and Examination Procedures
 
  • The Draft Bill: Provides scope to update regulations governing how compulsory acquisition (CA) is considered during examinations.
  • Consultation: Seeks views on making CA processes more flexible, so that changes to schemes only trigger CA requirements where genuinely necessary, while ensuring fairness and statutory protections remain intact.
 
CA is one of the most sensitive elements of any DCO. At present, even modest changes to a scheme can trigger new CA requirements, adding complexity and delay. The government is consulting on whether the regulations could be reformed to make CA procedures more proportionate and consistent, while still protecting the rights of affected landowners. These proposals underline that the drive for efficiency extends into the examination itself, not just the earlier stages of the DCO process.
 
Upside
  •         Greater flexibility could reduce unnecessary process when schemes evolve.
  •          Clearer and more proportionate treatment of CA issues may help keep examinations within the six-month window.
Watchpoints
  •           CA remains highly sensitive; reforms must strike a balance between efficiency and fairness.
  •           Applicants may still need to prepare robust evidence earlier to justify why CA powers are or are not engaged.

 

Theme 3: Delivering Faster – Priority Projects and Fast-Track Routes

 

(i) Acceleration That Works (Fast-Track and Pre-Application Services)
 
  • The Draft Bill: Provides for a redesigned fast-track route and enhanced pre-application services.
  • Consultation: Explores eligibility, costs, and how these services should be designed.

 

A fast-track option already exists but has seen little use. The draft Bill creates the framework for a redesigned fast-track. The consultation asks how it should be structured to provide genuine value to applicants. The challenge is to ensure that the new model offers speed without sacrificing robustness. Promoters will only use it if they can be confident that consents remain robust and defensible in court.
 
Upside
  •  A more accessible fast-track could significantly shorten delivery timeline
  • Structured pre-application engagement with PINS could identify and resolve issues early.
Watchpoints
  •           Criteria must be transparent and not unduly restrictive.
  •           Promoters need clarity on costs and whether services represent value.
  •          Operators may worry about reduced scrutiny increasing the risk of legal challenge.

 

(ii) Unlocking Onshore Wind While Avoiding Conflict 
 
  • The Draft Bill: Removes certain statutory pre-application consultation requirements for onshore wind projects under the Town and Country Planning Act 1990.
  • Consultation: Seeks views on how that exemption should be applied in practice, including what replacement engagement requirements might look like and how to balance speed with community involvement.
 
Onshore wind has had a complex planning journey. Since 2015, projects have often been effectively blocked by restrictive policy tests, particularly the requirement for “community backing.” The government now wants to reverse that trend by creating a clearer and potentially faster route for schemes to secure consent. The draft Bill proposes stripping out some of the statutory pre-application requirements that can hold projects up, while the consultation confirms that applications would instead be assessed against the National Planning Policy Framework (NPPF) in the same way as other TCPA projects. In practice, this means safeguards on engagement and policy alignment will flow through the NPPF, rather than additional statutory steps.

 

Upside
  • A faster, more predictable route for a technology central to achieving net zero.
  • A clear national signal that government policy supports onshore wind deployment.
Watchpoints
  •  Community opposition remains a challenge. Strong engagement will still be necessary.
  • Consents must give promoters clarity and certainty to move into delivery with confidence.

 

Why This Consultation Matters for Promoters and Operators

 
The government’s ambition is bold: accelerate 150 major decisions before the end of this Parliament. For promoters and operators, that ambition can translate into:
  • A Reduced risk of prolonged uncertainty.
  • A Stronger business cases that support financing.
  • A Better alignment with national priorities in energy, housing, and other growth.
In practice, these benefits will only materialise if the consultation translates into workable guidance, clear expectations, and a well-resourced Planning Inspectorate. Without that, legislative changes alone will not deliver the pace or certainty required.
 

Points to Watch as the System Evolves

 

  • How will the quality of pre-application consultation be defined and assessed at the Acceptance stage?
  • Will projects already in the pipeline face transition limbo?     
  • Can public body consultees realistically meet new duties without extra resources?  
  • Will fast-track criteria unlock benefits for many, or only a few?
  

Conclusion: A Rare Chance to Shape the Future

 
Looking back at my younger, bright-eyed self hunched over spreadsheets of DCO timetables, it’s striking how little has changed. Pre-application was the pinch point then, and it remains the pinch point now. The government’s own data confirms the direction of travel: timetables are lengthening, not shortening. Taken together, the draft Bill and consultation are a recognition that the system cannot rely on unpredictable front-end timetables if we want to deliver national infrastructure at pace. They also acknowledge there is scope to tighten the DCO process once an application has been submitted.
 
That’s why this consultation matters. It’s not just about tidying up processes — it’s about fixing the stage that has always defined whether a project succeeds or stalls.
 
For promoters and operators, the opportunity is clear: engage now, share real-world insights, and help shape a planning system that delivers the infrastructure Britain needs — faster, fairer, and more predictably.
 
If you’d like to discuss how these reforms could affect your projects, or need support in preparing a consultation response, please get in touch.

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Planning for the Modern Economy: Unlocking the Potential of the UK Life Sciences Sector
As someone very involved in the life sciences planning and development sector, I was pleased to join Charles Russell Speechlys for a recent podcast exploring how planning intersects with the UK Government’s recently published Industrial Strategy and associated Life Sciences Sector Plan. This conversation followed on from my blog published last year and offered an opportunity to reflect on the ambitions of the Plan and the role planning must play in helping the UK become a global leader in life sciences. I have provided a summary of the key discussion points below.

 

A Vision for Global Leadership
The government’s Life Sciences Sector Plan sets out a bold vision: to position the UK among the top three life sciences economies globally by 2035. Backed by £2 billion in funding, the plan is built around three core pillars:
  1. Enabling world-class research and development;
  2. Making the UK an outstanding place to start, grow, scale and invest; and
  3. Driving health innovation and NHS reform.
From a planning perspective, the government acknowledges the need to fast-track development of critical infrastructure - including labs, gigafactories, and data centres – through the planning system by allowing them to be categorised as Nationally Significant Infrastructure Projects (NSIP’s). While this could offer speed and certainty, it’s not without challenges. The NSIP process, as it stands, involves extensive consultation and may not suit every project so it is unclear whether it offers any real advantage.

 

Regional Health Innovation Zones: A Promising Concept
One of the most exciting elements of the Plan is the creation of Regional Health Innovation Zones. These zones aim to harness the economic potential of existing and emerging clusters, with initial ‘trailblazer’ regions to be announced. This approach could offer much-needed certainty for investors and developers, particularly in high-growth corridors like the Oxford-Cambridge Arc.
At Lichfields, we’re already seeing this clustering in action. Our work with Oxford Airport on its R&D Tech Park is a prime example - adjacent to Oxford Technology Park, 19,000 sqm of high-value employment space designed to meet Oxford’s growing demand for dry lab R&D accommodation as well as for aviation-related tenants. The flexibility built into the design, including multi-tenant configurations and airside access, reflects the sector’s unique needs.

 

Planning as a Tool, Not a Barrier
Historically, planning has generally been seen as a barrier to growth, perceived as slow, costly, and complex. But if the Government is keen to lead in life sciences globally, planning must become a strategic enabler. The sector plan rightly identifies this, but more detail is needed. For example, whilst the plan references infrastructure projects like HS2 and East West Rail, there is little detail on how these will be delivered and integrated with life sciences growth.
We also need to see planning policy evolve to support flexible, mixed-use developments. Life sciences facilities often have specific industry-driven requirements compared to typical office developments, but enabling multiple tenants to share high-spec lab space is also key to viability. National planning policy will need to reflect this reality.

 

Looking Ahead: What’s Next for Planning and Life Sciences?
The Sector Plan will be updated in 2030, but the real test lies in implementation. Will national planning reforms - such as the delayed National Development Management Policies (NDMPs) - incorporate the sector’s needs? Will local authorities and regional governments align with the plan’s ambitions?
One area I’m particularly interested in is the potential role of AI in planning. Could it help streamline public consultations or accelerate decision-making? It’s early days, but it could make a real difference.

 

Final Thoughts
The Government’s commitment to life sciences is clear, and the Sector Plan is a step in the right direction. However, coordinated action will be critical across multiple parties including local Councils, infrastructure and utility companies and other key industry stakeholders. Planning will have a major role in supporting the innovation and growth of the industry in the future.
 
As we continue to work with key clients in the industry, our focus at Lichfields will be to help them navigate the evolving planning landscape and unlock opportunities in this dynamic sector.
If you’d like to discuss any of the themes raised here or explore how Lichfields can support your life sciences project, please do get in touch.
For further information listen to the full podcast recording below
You can also find the podcast on Podbean, Apple podcasts and Spotify

 

Image credit: GSK Ware, Simons Design

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Life after UNESCO: Liverpool’s Approach to Heritage
Liverpool’s historic waterfront is one of the most recognisable in the world. Once a powerhouse of global trade, its docks and warehouses are steeped in industrial and maritime heritage. The City is second only to London in the number of Grade I listed buildings it contains. But it is also a place that continues to evolve, and in recent years, not without tension. The loss of Liverpool’s World Heritage Site status in 2021 was a high-profile moment, raising questions about how cities manage growth in a heritage context.
 In the years since, there has been a noticeable uptick in urban development activity - from residential-led schemes in the Baltic Triangle, to holistic masterplanning of the North Docks, and, most recently, proposals for the city’s tallest building at King Edward Triangle. Liverpool City Council has responded with a renewed focus on how best to understand, protect and shape its historic environment. The draft Historic Environment Supplementary Planning Document (SPD), now out for consultation, is a key part of that response. It provides detailed guidance on how the city’s planning policies should be applied to developments affecting heritage assets, helping applicants and decision-makers navigate what can often be seen as a complex part of the planning process.
While many of its core messages reflect established national and local policy, the SPD stands out for its broad scope, and its level of practical detail on issues that regularly arise in heritage decision-making. It embraces the current direction of travel for the sector in terms of climate adaptation and retrofit.
For developers or owners of heritage buildings, or for authorities facing similar pressures around change in historic places, Liverpool’s SPD is likely to be of interest.

 

A clear and comprehensive framework
The SPD brings together a wide range of planning policy, legislation, guidance and good practice into a single accessible framework. It advocates all the core principles you would expect; early engagement, establishing an understanding of significance, and using this to shape a contextually appropriate design response.
However, it provides a level of detail that goes beyond broad policy interpretation. It also includes a characterisation of different parts of the city, providing context for understanding how Liverpool’s historic areas have developed over time.
It covers all types of heritage asset, including non-designated assets, and provides detailed practical advice on matters such as shopfront design, often the subject of their own separate SPD.

 

Clarity on specific development scenarios
This is a real strength of the document. It goes further than most historic environment SPDs, by providing detailed, practical guidance on a wide range of common development alterations. These include extensions, window replacements, rooftop alterations, boundary treatments, shopfront changes, and public realm schemes. It sets out clear expectations for what is likely to be supported and when listed building consent is required. 
The detailed guidance on what is likely to be acceptable, and the thresholds for listed building consent, should give applicants greater certainty and improve the quality of submissions. The result, in theory, should be more predictable outcomes and a smoother planning process. Whilst similar guidance has been provided by authorities in other jurisdictions, this has occasionally proved too prescriptive. Liverpool's approach appears to strike a better balance, offering clear expectations without being overly rigid.

 

Responding to climate change in historic places
The SPD also addresses climate resilience, sustainability and energy efficiency, embracing Historic England’s recent guidance[1] on retrofitting historic buildings. It provides detailed guidance on interventions such as breathable insulation, secondary glazing, double glazing, heat pumps, solar panels and microgeneration, setting out the circumstances in which these are likely to be appropriate.
 It is encouraging to see the SPD align with this guidance, which in some regards can be seen as quite a progressive stance. This will be particularly important as pressure increases for existing buildings to meet higher environmental standards.

 

Part of a wider toolkit
Although this SPD serves as a city-wide document, it also sits alongside other emerging tools, including the separate draft Waterfront Historic Environment and Design SPD. Taken together, these tools reflect a coordinated and proactive approach to heritage-led planning across Liverpool, providing a foundation for managing change.

 

Final reflections
The draft Historic Environment SPD offers a useful and detailed guide to managing change across Liverpool’s historic environment.
While many of its principles will be familiar to heritage professionals, the way in which the document brings these issues together in one place, particularly its focus on everyday development pressures, makes it a worthwhile reference. It is also notable for its integration of current thinking on sustainability and climate adaptation.
In the context of Liverpool’s loss of World Heritage Site status, the SPD can be seen as a constructive and practical step in reaffirming how the city manages and communicates the value of its historic environment.
For other authorities, the SPD may offer a model for how heritage guidance can be made more accessible and tailored to common issues. For those working in Liverpool, it is a document worth becoming familiar with as it will become a material consideration in planning decisions.
If you would like to comment on the document, the consultation runs until 3rd September 2025. If you are a working with historic buildings in the city and require more tailored, project-specific heritage advice, then please get in touch.
Lichfields has a dedicated team of heritage specialists who appraise historic buildings and places of all periods and condition. We successfully manage change to heritage assets through consideration of their heritage significance and impacts on setting. Our experience encompasses work locally in Liverpool, and nationally on World Heritage Sites, Listed Buildings, Conservation Areas, Scheduled Monuments, Registered Parks and Gardens and Archaeology.
 

 

Footnote
Image credit: Chris Porter from Unsplash

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Reforms to Infrastructure Planning: Insights from the NIPA Annual Conference
At a time of significant proposed changes to infrastructure planning, I was fortunate to attend the National Infrastructure Planning Association (NIPA) Annual Conference on Monday this week. With the Government’s recent announcement of mandatory Biodiversity Net Gain (BNG) for NSIPs from April 2026, and the second reading of the Planning and Infrastructure Bill in the House of Lords now complete, the Conference was a timely opportunity to hear a range of views on these changes. The key question is whether they go far enough to encourage the industry to promote more NSIPs, to enable the Government to meet its ambitious target of making 150 major infrastructure project decisions in this Parliament.
With further guidance promised and consultation on BNG ongoing (The Government’s BNG consultations explained (and why you should care)), this blog sets out key issues and takes a reading of the industry’s response.

 

Implementing DCOs post-consent
Key to the utility of any DCO is its future compatibility with updated technology, and there is increasing recognition of the benefits of using the ‘Rochdale Envelope’ to build in flexibility to a DCO. However, the rapid pace of technological advancement seems to be increasingly incompatible with the current DCO process. It was noted that a high proportion of consented DCOs are now incompatible with the latest technology, meaning many consented projects may not be built at all, or will require a post-consent change application to incorporate updated technology. 
 
The Planning and Infrastructure Bill removes the distinction between non-material and material changes post-consent to streamline this process. This is a welcome amendment that will help to ensure that major infrastructure projects can be built to optimal design.
 
One of the most interesting sessions for me was the talk by Ed McCann of Expedition Engineering on ‘Fit for purpose consents’ looked at key issues in project delivery. As Planners, we are not often involved in the ongoing implementation of major projects, but restrictions agreed to as part of the consent (for example construction working hours) can have severe cost and time implications, undermining project deliverability. Costing impacts must be fully interrogated at the consent stage, and we can hope that a simplified process for post-consent changes may also assist in this area.
 
Another issue requiring a strategic view relates to the use of the Rochdale Envelope. Whilst many developers are making use of opportunities for design optimisation post-consent, protracted pre-application timescales and delayed decisions often see this activity curtailed. It is hoped that time savings through reforms will re-establish opportunities for this refinement.

 

Consultation
Changes to DCO consultation requirements was another key topic of the day. One key message from NIPA’s engagement with members was the need for consultation to focus on outcomes, as a proportionate exercise that is meaningful, open and transparent. This feedback was complemented by the case law update session, with a talk given by Daniel Kozelko on discarded alternatives during consultation. Drawing on case law including Mosely v LB Haringey (2014) and R (Possible (The 10:10 Foundation)) v SST (2025), Kozelko recommended that alternatives should be set out during consultation, relevant to the scope of the consultation. It is best practice to include brief commentary on arguable alternatives, setting out why they were rejected or considered non-viable.
 
Currently, it has been suggested that many developers are ‘gold plating’ consultation to avoid the risk of judicial review. Future guidance must establish clear requirements so that this does not carry over. Clarity on alternatives would be a welcome addition to this guidance, and confirmation of the applicability of these changes to post-consent change applications should also be included.

 

Biodiversity Net Gain for NSIPs
Biodiversity Net Gain (BNG) is set to apply to NSIPs from May 2026. I attended the workshop run by DEFRA on the Government’s ongoing consultation and heard views from delegates on the proposals.
 
The government proposes using the Order Limits to calculate the baseline BNG value and has suggested that it should apply to all NSIP types. Numerous participants raised the significant implications of this for linear projects, especially above ground or underground installations where there would be limited impacts to most of the land, and where wide lateral parameters are often used.
 
It was suggested that a maximum construction footprint should be used in the initial calculation, and the government’s proposal to enable later re-calculations was welcomed. The government is set to produce further guidance on BNG calculations to account for the use of parameters and design flexibility, which will be especially important in light of the increasing need for flexibility.
 
Further details of the consultation can be found on Lichfields’ blog: The Government's BNG consultations explained (and why you should care). The consultation is running until 24th July 2025.
Key takeaways
The government’s recognition of the essential nature of major infrastructure projects to the UK’s growth strategy via the Planning and Infrastructure Bill has brought optimism to the industry, but also a high degree of uncertainty. The industry is keenly awaiting clear guidance on updated consultation requirements, and whilst there is support across the sector for the introduction of BNG for NSIPs, this is tempered by concern that a rigid application of the requirement will undermine project deliverability.
 
DCOs establish essential design flexibility which is of increasing importance in the context of rapid technological advancement. The compatibility of BNG with this process is yet to be confirmed. In this same vein, whilst there was little discussion of the proposed amendments to the post-consent change process, it is clear that this will contribute to better project outcomes: enabling the process to keep pace with technology, rescuing undeliverable projects, and opening up more avenues for post-consent design optimisation.
 
There is reason for optimism. The government is listening to the industry, and if recommendations are taken on board, it is hoped that the package of reforms currently underway will help to improve efficiency, flexibility, and proportionality in the DCO consenting process.

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