Planning matters

Our award winning blog gives a fresh perspective on the latest trends in planning and development.

Beyond matchday: the rise of the UK sports and entertainment district
With the 2026 FIFA World Cup now underway across Canada, Mexico and the United States, the economic power of sport is again on global display. The tournament is the largest FIFA World Cup to date, with 48 teams and 104 matches. FIFA and the World Trade Organisation have estimated that the tournament could help drive up to $40.9bn in global GDP, deliver $8.28bn in social benefits and support nearly 824,000 full-time equivalent jobs globally. [1] [2]
For clubs, investors, developers and operators, the wider message is clear: sporting and entertainment assets have the potential to generate huge value across places, supply chains and local economies.
In the UK, that local economic effect is increasingly visible. Barclays’ analysis of the 2024/25 Premier League and Barclays Women’s Super League seasons estimated that top-flight football matchdays generated £2.3bn of consumer spending in local economies. Spending within 1km of stadiums rose by an average of 4.1% on matchdays compared with non-matchdays, with fans turning fixtures into fuller days out across travel, food and drink, entertainment, shopping and post-match activity. [3]
That is the core logic behind the rise of the sports and entertainment district. The venue creates footfall and identity. The surrounding district captures value. The two are designed to reinforce each other.
Across the UK, major venue projects are increasingly being conceived as anchors for wider mixed-use districts. Sport, live entertainment, food and beverage, hospitality, hotels, workspace, public realm and community uses are being combined into all-day, every-day, year-round destinations. For clubs, investors, developers and operators, this creates a significant opportunity. It rewards projects where the venue strategy, real estate proposition, economic benefits case and planning approach are integrated from the outset.
The scale of the opportunity is significant. DCMS estimates that in 2024 the sport sector contributed around £20.6bn in GVA to the UK economy, with the cultural sector contributing around £40.3bn and tourism directly contributing around £64.3bn. UK Music’s latest This Is Music report records that the UK music industry contributed £8bn in GVA in 2024 and supported 220,000 full-time equivalent jobs. [4] [5]
Sports and entertainment districts sit at the intersection of these sectors. At their best, they can create new revenue streams, attract private investment, support local jobs, generate visitor spending, strengthen supply chains, create community value and support places that work throughout the week and across the year.
 

From venue to destination

 

The traditional stadium model was heavily event-led, with revenue concentrated around matchdays or a limited calendar of major events. The newer model is more diverse. It asks a different question: how can the asset work every day, not just when the turnstiles are open?
Tottenham Hotspur Stadium is one of the clearest UK examples. The club’s socio-economic impact study reported that Tottenham Hotspur’s activity generated £344m in GVA and supported more than 3,700 jobs across Haringey, Enfield and Waltham Forest in 2021/22. Across Greater London, the reported impact was £478m in GVA and 5,100 jobs. [6]
The Tottenham example matters because the venue was designed to support a wider events strategy, including NFL, concerts, rugby, boxing and other major events. That creates a different operating proposition from a football only stadium. A broader events calendar supports more regular footfall, a wider visitor economy impact and a stronger basis for surrounding leisure, food and beverage, hospitality and commercial uses.
Wembley Park shows the same principle at a larger urban scale. Quintain’s case study material records around 500,000 sq. ft of retail and leisure and around 10,000 residents at Wembley Park, with the area now operating as a long-term, mixed-use neighbourhood around the stadium and arena. [7]
This shows that a major venue can become the anchor for a broader place strategy where event day activity, everyday uses, public realm and local connectivity reinforce one another.
At Craven Cottage, Fulham Pier - a project Lichfields has advised Fulham FC on for many years - provides a more compact but highly relevant example. On matchdays it is a football stand with extensive fan and hospitality facilities; on non-matchdays it is a riverside destination, with food and beverage, events, hospitality and use of the public realm designed to broaden the role of the stadium beyond matchday.

Image credit: Populous

The direction of travel is clear: stadium-led place creation is becoming an increasingly important part of the UK venue market.
 

Arenas are part of the same story

 

Arenas are increasingly central to the same discussion about entertainment-led investment, visitor economy growth and city competitiveness. Utilising the same infrastructure, stadia and arenas are obvious bedfellows.
Co-op Live in Manchester is the most topical example, situated next to the Etihad Stadium. An economic impact report prepared by Lichfields, covering the period from construction through to the arena’s first year of operation in May 2025, reported more than £1.3bn in total turnover and around £785m in GVA to the UK economy. In its first year of operation, Co-op Live reported around £852m in turnover, £455m in GVA, 105 events and 1.5m fans. [8]

Image credit: iStock

The Manchester impact extends beyond the arena itself. Co-op Live reports that £313.4m of the total GVA generated since building began was contributed to the Manchester economy, including visitor spending across hotels, restaurants, pubs and bars. The venue also demonstrates how major entertainment infrastructure can act as an economic and civic anchor, supporting jobs, visitor activity and wider engagement with the city. [8]
For operators and investors, this matters because the most compelling projects are increasingly judged on how well the venue supports a broader destination, how it extends dwell time, how it diversifies revenue and how it contributes to the surrounding economy.
 

The US influence – adapting the model for the UK

 

The 2026 World Cup also provides a natural moment to look at the North American market. Many of the tournament’s matches are being staged in a region where the sports and entertainment district has matured into a distinct real estate and operating proposition.
The Battery Atlanta has become one of the most closely watched examples. Located next to Truist Park, home of Major League Baseball’s Atlanta Braves, it demonstrates how a major sports venue can be paired with a wider mix of commercial, leisure, hospitality and residential uses. Atlanta Braves Holdings reported that, in 2025, its mixed-use development revenue grew by 45% to $97m, alongside baseball revenue of $635m. [9]

Image credit: Erin Doering

More broadly, a 2025 Klutch Sports study for Royal Bank of Canada, focused on the North American market, estimated that sports-anchored, mixed-use districts could attract more than $100bn of investment over the next 15 years, underlining the scale of investor interest in the model. [10]
That influence is now visible in the UK market. Co-op Live was developed by Oak View Group in partnership with City Football Group and Harry Styles, bringing a major US-based venue developer and operator into one of the UK’s leading music and entertainment cities.
In Birmingham, the proposed Sports Quarter represents a more direct example of US-backed sports-led regeneration, with proposals including a 62,000-capacity new stadium, sports campus, training facilities, academy, community pitches, and leisure, commercial and residential development. [11]
The UK is adapting the strategic logic of sports and entertainment districts to its own delivery environment. Land ownership, planning policy, community expectations, local government finance and public transport provision all shape how these projects come forward in the UK. The opportunity is to adapt the commercial logic of the venue-anchored district to those conditions, creating projects that are investable, deliverable, rooted in their local context and planned as integrated place propositions from the outset.
 

What this means for UK delivery

 

Venues need to work harder across the week and across the year. Food and beverage, hospitality, conferences, hotels, fan experiences, leisure uses, membership products and cultural programming can extend activity beyond core event days and create more resilient income streams.
The UK delivery environment makes the integration of planning, economics and operations particularly important.
First, the project needs a credible year-round operating model. The strongest cases explain how the venue and surrounding uses will operate in ordinary weeks, shoulder periods and non-event windows, as well as during major events.
Second, the local economic case needs to be specific. Barclays’ matchday spending analysis shows the scale of expenditure that can occur around stadiums when fans turn fixtures into full-day experiences. For venue-led districts, the question is how that spend can be supported and captured through the right mix of food and beverage, hospitality, public realm, movement routes, local business links and post-event activity. [3]
Third, the community benefits case needs to be specific. Construction jobs, operational roles, hospitality and events staffing, apprenticeships, local procurement, community access and grassroots sport can all form part of the wider value created by sports and entertainment districts. The most persuasive cases explain what benefits are created, where they arise, and how local people, businesses and community organisations can access them.
Fourth, public realm and connectivity need to be central to the proposition. The modern visitor experience starts before arrival and continues after the final whistle or encore. Transport, wayfinding, walking and cycling routes, public spaces, safety, servicing and crowd management all shape whether a venue becomes part of a successful district.
Finally, the benefits case should be developed early. A well constructed economic impact assessment does more than support a planning application. It provides the evidence base for engaging local authorities as partners, attracting anchor occupiers, supporting naming rights and sponsorship discussions, and demonstrating long-term operating credibility to funders and communities.
This is where planning, economics and commercial strategy need to work together. Developed early, the benefits case can help shape the project, strengthen the planning strategy and support the wider investment proposition.
 

A UK opportunity

 

The UK is well placed to benefit from this next generation of venue-led investment. It has globally recognised sports brands, a deep live music market, major visitor destinations, strong city identities and a growing appetite for experience-led development.
The opportunity also extends beyond the largest clubs and biggest cities. There is a spectrum of viable models: major urban entertainment districts, arena-led regeneration projects, stadium-adjacent leisure quarters, waterfront destinations, training ground campuses and mixed-use developments anchored around sport and culture.
The commercial logic of the sports and entertainment district is now well established. The economic case is increasingly evidenced. The investor interest is real. The strongest projects translate ambition into a deliverable, fundable and consentable proposition.
For investors and developers entering or expanding in the UK market, this means engaging planning, economics and operations early. Land ownership structures, community expectations, Green Belt policy, heritage constraints, transport impact requirements and Environmental Impact Assessment requirements can all influence the shape, programme and viability of a project.
The next generation of UK sports and entertainment districts will be defined by the discipline with which vision, investment, planning, economics and operations are brought together. For clubs, investors and operators, the opportunity is substantial: to create destinations that generate activity beyond event days, support local economies, strengthen long term revenues and deliver places that work for communities as well as visitors.
The strongest projects will be those that treat the venue, the district and the benefits case as one integrated proposition from the outset.

 

Footnotes

 

[1] FIFA World Cup 2026™

[2] FIFA-WTO study estimates USD 47 billion economic output from FIFA Club World Cup™ and FIFA World Cup™ in the US

[3] Premier League and Barclays Women’s Super League matches generate an estimated £2.3bn of consumer spending each season - A1 Retail Magazine

[4] DCMS Sectors Economic Estimates Gross Value Added 2024 (provisional) - GOV.UK

[5] This Is Music 2025 - UK Music

[6] Club releases analysis of its socio-economic contribution to the local area

[7] Case Study - Solar – Quintain Ltd

[8] Co-op Live Contributes Over £1.3 Billion Turnover to UK Economy Since Inception | Co-op Live

[9] Atlanta Braves Holdings Reports Fourth Quarter and Year End 2025 Financial Results :: Atlanta Braves Holdings, Inc. (BATRA)

[10] Royal Bank of Canada hires Klutch Sports for mixed-use district study

[11] Birmingham Sports Quarter - what you need to know - BBC News

CONTINUE READING

Manchester City Centre’s billion-pound year and the future of regional city centres
Manchester City Centre generated more than £1 billion in consumer spend and attracted over 40 million visits in 2025.[1] A notable achievement, this milestone shows how regional city centres can continue to thrive and succeed by proactively rethinking town centres rather than waiting for a return of pre-pandemic or pre-digital activity.
Through previous Insights, Lichfields has explored how town and city centres are responding to change through diversification, reuse, repurposing and the introduction of a broader mix on the high street[2]. Manchester is one of the clearest examples of that shift in practice. Rather than treating change as a temporary disruption, the city centre has increasingly promoted dynamic change as a model to drive interest and maintain activity.
 

Adapting from retail dominance

 

For many centres, the decline of traditional ‘bricks and mortar’ retail is still framed as a problem to be solved. In Manchester, however, it is increasingly clear that the city has already adapted to this shift by using diversification as an effective model across the city centre.
Traditional retail however still remains an important part of Manchester’s offer, with high profile openings such as Arc’teryx, Alo, and Represent, alongside the expansion of JD Sports unit in the Arndale Centre showing that there is still demand for well positioned physical retail. However, retail is no longer the sole organising principle of the city centre. Instead, Manchester now functions as a genuinely mixed use environment in which leisure, food and drink, culture, employment and residential uses all contribute to footfall, spend and vitality.
This shift is not accidental. It reflects a broader trend that we have tracked through our work at Lichfields, particularly in our Out with the old, in with the new Insight.[3] The contraction in traditional retail demand appears structural rather than cyclical with online shopping, changing consumer expectations and new patterns of living and working redefining what town and city centres are for.
Manchester’s strength, therefore, lies not simply in outperforming the market, but in recognising how the market has changed and responding to that change more effectively than many other places.
 

Repurposing: from fallback to first choice

 

One of the most significant aspects of Manchester’s recent evolution is the extent to which repurposing is commonplace.
Former department stores and large retail units are no longer simply left vacant in the hope that demand will return. Instead, they are being rethought, subdivided and repositioned to attract new uses. Mixed-use redevelopment, change of use and reconfiguration have become active strategies rather than a last resort. Where major retail anchors such as Debenhams have fallen away, new combinations of office space, leisure and active ground-floor uses are beginning to redefine what prime city centre space can support. 
On a smaller scale, our blogs on high street rental auctions have illustrated that individual units can attract the same flexibility, in principle whether for meanwhile uses or otherwise to keep units occupied and the high streets dynamic rather than vacant. Whilst not a feature in Manchester, the principle applies whereby the question is not how to recreate the past, but how to unlock a more viable future for underused space.
The growth of the experience economy is the clearest expression of the changing environment. Manchester City Centre no longer serves only the traditional shopping trips but functions as a destination for local, regional and increasingly wider visitor markets. Large former retail units have been repurposed for leisure and entertainment uses, including cinemas, bowling and other evening economy attractions, broadening the city centre’s appeal beyond conventional retail hours. Combined with the city’s wider strengths in sport, music and culture, this has helped to create a more diverse visitor economy that supports activity throughout the day and into the evening.
 

No Quarter

 

Manchester also benefits from having a series of recognisable and distinct city-centre districts, each with its own role and audience. The Arndale Centre and main shopping streets serve high street retail along with the growing leisure-led market. Areas such as Northern Quarter attract second-hand shops, record stores, cafes and bars, whilst Deansgate remains the epicentre of the city’s evening economy as well as an office hotspot attracting daytime footfall. Together, they create a centre with multiple identities rather than a homogeneous offer, fostering spatial diversification but also an agility to respond to trends and the preferences of varying consumers.
Variety and distinct quarters help to attract different visitor groups, supports more experimental forms of retail and leisure and contribute to the greater dynamism that sets Manchester apart from many competing centres. Manchester’s Core Strategy 2012 to 2027 (Policy CC1) has specifically sought to encourage and support defined areas of the City Centre and its fringes through planning policy.
Whilst many of these areas have evolved organically over time, effective and active town centre management is also key to growth. Manchester City Centre Business Improvement District, led by CityCo and Manchester City Council, provides a practical example of town centre management in action with businesses collectively investing in additional services and initiatives focused on attracting and welcoming visitors, as well as improving the street environment. A regular programme of curated events throughout the year, including major seasonal and family-focused attractions such as Halloween in the City, the Manchester Christmas Parade and the Christmas Markets, all of which help generate repeat visits and sustain city centre footfall beyond routine shopping trips.

Mike Peel (www.mikepeel.net)

The creation of a dynamic centre with strong identities to attract a range of consumers throughout the year is essential but when realised through effective private and public investment.
 

Housing and employment are reinforcing city centre vitality

 

The city centre’s performance is also reinforced by sustained demand for both housing and office space. The everchanging Manchester’s skyline speaks for itself but its gains are felt at street level. By directing significant and strategic growth into the city centre, the city supports a larger resident and worker population whose presence underpins everyday spending, footfall and demand for services.
Manchester City Council’s State of the City Report establishes that the city centre population was now approaching 100,000 in 2023,[4] reinforcing Lichfields’ emphasis on the marked rise of city-centre living has risen markedly over the past decade across England’s larger urban centres.[5]
Supported through its Core Strategy to deliver a minimum of 16,500 new units in the City Centre by 2027, Manchester City Council was an early mover in embracing large-scale city centre residential development and is now seeing the benefits of that model in supporting both retail and entertainment throughout the week.
The city also benefits from one of Europe’s largest student populations, fuelling further demand for housing, food and drink, leisure and helping to ultimately animate the centre through the day and evening.
In that sense, Manchester is not simply delivering homes and is building the critical mass of a population that many successful centres now depend upon. Resilient centres are not sustained by visitors alone but are strengthened by people who live and work there.
 

But how can the wider region respond?

 

Manchester should not be treated as an isolated success story. It is better understood as a case study in how regional city centres can respond to structural change. Therefore, the question is not whether other places can or should replicate Manchester but which of its underlying principles can be adapted to different local contexts.
Not all centres will be able to attract the same scale of investment, density or leisure offer or serve the same role as Manchester, but that does not dismiss the relevance of its trends. The key lesson is to apply the same broad principles of adaptation, diversification and proactive intervention, as reflected in our Revitalise toolkit:
  1. Support the traditional retail market where there is still demand but do so in a way that responds to local need, changing consumer behaviour and the wider role of the centre.
     
  2. Encourage the introduction of new high street uses, including food halls, leisure, health and other service-based activities that broaden the function of the centre.
     
  3. Embrace the repurposing of redundant retail space, including department stores and shopping centres, for housing, hotels, student accommodation, workspace or other viable long term uses and boost footfall.
     
  4. Use planning policy and public intervention proactively to shape regeneration and investment, whether through strategic frameworks, targeted town centre strategies or top down tools such as High Street Rental Auctions.
     
  5. Support growth through local identity and distinctiveness to diversify the offering of centres.

  6. Fostering a town and city centre population to support regular spending, footfall and demand for services.
Manchester’s billion pound year is not an outlier, but a clear demonstration of successful adaptation. Successful centres rarely evolve by accident and should be underpinned by planning policy that enables housing, offices, leisure, public realm and infrastructure improvements to come forward together, rather than as a purely retail destination. While few centres will match its scale, the real lesson lies in its approach in a willingness to diversify, repurpose and proactively redefine the role of the city centre for a changing future.
Footnotes

CONTINUE READING

Delegation default: power to the Chief Planner

Delegation default: power to the Chief Planner

Jennie Baker & Sean Farrissey 11 Jun 2026
The Government has laid the draft regulations necessary to bring the national scheme of delegation into effect, for approval of both houses of Parliament. The intended commencement date is 31 October 2026. This is 20 weeks away, so some applications already in the system will be affected. However, local authorities will need to start preparing for the change immediately.
In this blog we:
 
  • explain the changes made to the draft regulations following consultation;

  • provide a table showing the categories of decision making that different planning applications will fall into; and

  • set out some key points in the guidance, including on the operation of the application of the Gateway test for deciding whether or not an application goes to committee for decision.

The regulations will not apply to development corporations, Homes and Communities Agency, National Park Authorities or the Broads Authority, because they are not “relevant planning authorities”[1]. Therefore, these authorities will not need to amend their constitutions, committee sizes or decision-making processes by the end of October. Throughout this blog we refer to local planning authorities (LPAs), but this should be read as excluding the authorities listed above.

 

Draft legislation and summary of consultation outcome

 

The Government has published its response[2] to the consultation on planning committee reform, including the proposed ‘national scheme of delegation’ for England. The consultation, which ran from 26 March to 23 April 2026, sought views on the technical detail and drafting of the regulations and guidance. Analysis of the proposals can be found in this Lichfields blog.
Also published is the statutory guidance[3] for LPAs in England, which they are required to follow when implementing planning committee reform and when otherwise applying the (currently draft) Town and Country Planning (Discharge of Local Planning Authority Functions) (England) Regulations 2026 (‘the draft regulations’)[4][5].  The guidance is clear that even if an application is in the Schedule of application types that may be taken to committee, applications being referred to committee should be for exceptional cases only.
A total of 611 responses were received to the consultation, over half being from individuals. A quarter of responses, 156, were from LPAs, which means that just under half of LPAs responded.
The government response notes that the same key themes were raised by all categories of respondent. These include views on which Schedule applications should fall into (explained below), seeking the ability for members to call-in applications, concerns about committee size limits being limited especially given local government reorganisation and concerns about defining which applications are linked to officers, members or the authority.
Individual respondents[6] expressed strong opposition to a national scheme of delegation, based on concerns that democratic oversight through consideration at planning committee would be lost. Not all those in the category of individual respondent will have made that objection, but individuals made up more than half of all respondents in a number (333) – coincidentally almost equal to the number of LPAs in England (337). While the government has not rolled back its plans to introduce a national scheme of delegation, the changes to the draft regulations since their last iteration include:

 

  • the implementation date has been delayed from 30 September 2026 to 31 October 2026 to give LPAs time to make the necessary arrangements;

  • ‘large outline planning application’, a new definition (see below),  will determine the Schedule a reserved matters application (RMA) falls within – rather than whether or not the RMA relates to a phased outline planning permission, as was consulted on;

  • Section 73 applications will now be in the same Schedule as the ‘original’ application;

  • ‘Own-interest applications’ is the term for applications where an authority is itself or any of its members or officers are the applicant, or are considered to have an interest in the application - these were consulted on as ‘linked person applications’, with a slightly different definition; and

  • clarifying that ‘minor residential applications’ includes only dwellings and development for purposes incidental to the enjoyment of dwellings.
The forthcoming national scheme of delegation and controls on committee size are among other new or emerging ‘fail safes’ on local decision making. Since 31 March, where a LPA intends to refuse planning permission for a housing scheme of 150 dwellings or more, they must consult the Secretary of State to enable Ministers to decide whether to use their existing powers to call in that planning application. The Government has consulted on the same requirement applying where LPAs are minded to refuse planning permission for commercial development with a floorspace of 15,000sqm or more (see this blog).

 

The Schedules applying to reserved matters approval applications

 

The Government previously proposed that only reserved matters applications relating to non-phased outline permissions were included in Schedule 1 of the regulations. This was to address previously expressed concerns that reserved matters applications can relate to large scale phased development taking place over many years in a changing context and can represent substantial major development, requiring examination at committee. This now dropped approach to reserved matters applications drew a “mixed” consultation response.
The Government has decided to change its approach and has introduced a size-based criteria for determining the applicable Schedule.
The regulations introduce a new definition:
““large outline permission” means an outline planning permission which permits development involving either or both of—

(a) the provision of 500 or more dwellings;

(b) the provision of a building or buildings where the floorspace to be created by the development is 50,000 square metres or more;”

The definition is provided because Schedule 2 includes “A reserved matters approval application in respect of a large outline permission”.
Only reserved matters applications relating to a large outline planning permission will fall into Schedule 2. Reserved matters approval applications relating to smaller outline planning permissions will fall into Schedule 1 and be determined by officers. The statutory guidance refers to a “large outline phase permission”, but this may be corrected in due course, as there are no longer references to phasing in the draft Regulations.
This suggests that, where the outline permission permits up to 500 homes, the reserved matters application would fall within Schedule 2, even if the final phase shows that less than 500 homes will be built.
This will mean that the proposals within an outline planning permission that do not constitute floorspace, such as caravan bases, will not be relevant to whether the permission is a ‘large outline’ and thus whether a related RMA falls within Schedule 1 or Schedule 2.
However, the key point in this context is the intention that in all cases the referral to committee should be exceptional, regardless of which Schedule an application falls into.

 

 

Schedules and own-interest applications

 

Category
Delegated to officers?
Application type
Schedule 1
Always
Householder application
Minor commercial application
Minor residential application[7]
Reserved matters application other than those made in respect of a “large outline permission”
Application for s96A non-material amendments
Section 73 application where the original/previous application was in Schedule 1, unless it relates to a listed building consent or variation of
Application made for approvals in a relation to a planning condition
Application for approval of the Biodiversity Net Gain (BNG) Plan
Application for prior approval or a determination as to whether it is required (related to permitted development rights)
Lawful Development Certificate application
Certificates of Appropriate Alternative Development application
Application for Permission in Principle
Application to modify or discharge a s106 obligation, where it is connected to a Schedule 1 approval
Schedule 2
By default, unless the Chief Planner and Chair of Committee decide it should go to Committee based on meeting statutory criteria ‘the Gateway Test’
Application for planning permission that is not a householderMinor Commercial or minor residential[8] application
Reserved matters approval application in respect of a large outline permission (at least 500 dwellings and/or at least 50,000sqm floorspace created)
Section 73 application where the original/previous application was in Schedule 2
Section 73A (retrospective) application
Application to modify or discharge a s106 obligation, where it is connected to a Schedule 2 approval
Application for listed building consent, application to vary or discharge a listed building consent condition and any planning application that the LPA considers is connected with these consent types
Advertisement consent application
Tree preservation order applications
Review of mineral planning conditions
Own-interest applications
Can be determined by officers. Alternatively, the nominated member and nominated officer may refer it to a committee
An application made, whether jointly with another person or not, to an authority to which the Regulations apply, by or on behalf of that authority, or a member or officer of that authority or if in the view of the nominated member and the nominated officer, the authority or any of its members or officers otherwise has an interest in the application made.
The national scheme of delegation does not apply to development corporations, Homes and Communities Agency, National Park Authorities and the Broads Authority.
There is no reference to hybrid planning applications, probably because they don’t exist in planning legislation. In our view, when establishing whether or not a reserved matters application relating to the outline part of a hybrid permission falls within Schedule 1 or 2, only the housing or floorspace proposed in the outline part of the permission would be counted towards the 500 unit/50,000sqm threshold for Schedule 2.
The guidance doesn’t explain which Schedule section 73 (s73) applications relating to applications determined prior to the new system will fall into, so it seems likely that if the original application was determined by planning committee then the s73 will fall within Schedule 2.
The guidance confirms:
“Where a planning function is not listed in either Schedule 1 or 2, it is for the local planning authority to decide whether it should be delegated to an officer or referred to a committee or sub-committee for a decision (as part of its local constitution)”.
Where an application falls to be determined by an officer, the LPA must not make arrangements that limit the officer’s discretion as to how to determine that application.

 

The statutory criteria for referral to Committee ‘the Gateway Test’

 

The criteria for referral of applications to committee, known as the Gateway Test, has been criticised, including in consultation responses, as being too broad and open to interpretation. The Government has decided that these concerns should be addressed in guidance and they have expanded the statutory guidance published alongside the draft regulations. The Planning Advisory Service (PAS) will continue to work with government to develop good practice advice to support LPAs in applying the reforms.
The updated guidance clarifies that it is not a requirement of the national scheme of delegation that nominated officers and nominated members consider all Schedule 2 applications or all own-interest applications for potential referral to committee. It will be up to LPAs to determine which applications should be considered for referral and Schedule 2 applications can be determined by officers.
It will be for LPAs to determine their own arrangements for triaging Schedule 2 applications in terms of how they are taken through the Gateway Test and deciding the route that they should follow[9]. The guidance is clear that LPAs are under no obligation to establish a triaging system but may follow this route if they wish. Own interest applications can be taken to committee without needing to pass the Gateway Test.
The guidance notes that the “overriding presumption” should be that applications are determined by officers and determined by committee as an exception.
At least one of the statutory criteria must be met for a Schedule 2 application[10] to be referred to committee for decision. The statutory criteria (a) and (b) are set out in the Regulations and in the statutory guidance (A and B). Regulation 5 says that the nominated member and nominated officer, having had regarding to the statutory guidance, “may agree to refer a Schedule 2 application to a committee if in their view it raises—
(a) one or more issues of economic, social or environmental significance to the local area, or
(b) one or more significant planning matters having regard to the development plan and any other material considerations”.
If they decide not to refer to the Committee, then an officer must determine that application.
The statutory guidance lists the below three potential examples of what may constitute a significant issue to the local area under criterion A[11], while noting that there will be local variations:

 

“an application for outline planning permission for a large multi-phase residential development allocated in the local plan

an application for planning permission for change of use of a community shop in a rural area

an application for planning permission or listed building consent for changes to a notable listed building in a town centre”
For criterion B, the guidance says that the following circumstances are unlikely to raise a significant planning matter:
"where the application for development broadly complies with a detailed site allocation and other relevant policies set out in a local or neighbourhood plan and national decision making policies set out in the National Planning Policy Framework. Significant planning matters may arise if new material considerations are raised by the application
where a specific planning matter (e.g. highways or flood risk) was initially raised by a statutory consultee as a concern, but the development proposal has been modified to make it acceptable in the view of the statutory consultee (unless the nominated officer has compelling reasons to consider otherwise)."
These examples, in paragraphs 23 and 24 of the guidance[12], are the same as those consulted on, and of very limited use. It will be much more helpful to discuss interpretations of ‘significant’ directly with local officers and to monitor emerging patterns. Local knowledge will be increasingly important in this regard. The record that should be kept of cases that the nominated officer and member have considered, setting out their reasons for the determination route decided, will be important too. The consultation response says that the Government will work with the PAS to see if greater clarity on how the gateway process should operate and advice on interpreting the gateway criteria might be incorporated into the good practice advice PAS is developing to support local authorities.

 

Delegation default

 

The diagram below aims to capture what we understand about the new decision-making procedures. It draws out how many opportunities there are in the process for a Schedule 2 application to be decided by officers, reflecting the policy ambition.

View Planning decision making procedures diagram
 
  

Refer or not refer – who decides?

 

The regulations say that “the nominated member and nominated officer may agree to refer a Schedule 2 application to a committee” if it raises a Criteria A or B concern. Similarly, the draft regulations say that “The nominated member and nominated officer may agree to refer an own-interest application to a committee”. The draft regulations do not provide a process for situations where the officer and member do not agree on whether an application should go to Committee.
However, para 15 of the statutory guidance says (our emphasis):
“Nominated officers and nominated members should make every effort to reach agreement on which cases should be referred to committee. However, where agreement is not possible, the case must be determined by officers in accordance with regulation 5(2) or regulation 6(3)”.
Regulation 5(2) says that Schedule 2 applications not referred must be decided by an officer. Regulation 6(3) says the same for own-interest applications. Therefore, the statutory guidance is key – and some members will push hard against this. Political reasons to take an application to committee with the intention of approving it would include the press coverage of a popular approval. But, on the whole, a key driver for a councillor will be either to vote for refusal of an application, to seek additional conditions, or to be seen to be objecting to an application. Planning is about people and many councillors are likely to question and then be frustrated by the casting vote of the chief planner, particularly as the system beds in.
Our diagram emphasises that this isn’t a straightforward system and it may be that it results in more applications being considered at Planning Committee, particularly where councils revisit schemes of delegation. This may be the case particularly where councils are under new leadership and/or have no overall control.
As one would expect, the Planning Officers’ Society has published detailed analysis of the decision-making procedures, within its ‘Good Practice Guidance Note - National Scheme of Delegation’[13]. This includes guidance on approaches to triage and templates of the documents that need to be updated.

 

Maximum committee size – and training in the future

 
From 31 October, the maximum number of members on a planning committee will be 13, which is unchanged from the consultation. Again, the limit on committee size only applies to “relevant planning authorities”. The guidance says:
“This is a maximum figure to accommodate local planning authorities where members are from multiple political parties. Local planning authorities should consider whether a smaller number of members would be more appropriate in their area to support effective decision making”.
In a recent PAS and MHCLG seminar[14], MHCLG’s Deputy Director of Planning confirmed that the focus for now is on the scheme of delegation, with legislation and guidance on councillor training to follow. The Government intends to carry out “further sector engagement to get the correct approach”. It is worth noting PAS research regarding member training here:
“The PAS planning committee survey 2025 identified that 81 per cent of planning committees in England made it a mandatory requirement for councillors to be trained if they wish to sit on the planning committee”[15].
Therefore, less than a fifth of planning committees (and perhaps considerably less), have no training requirement at present. The quote is taken from the PAS ‘Planning committee best practice self-assessment toolkit’[16] which notes that Councils not training planning committee members, even ahead of it being a national requirement, may be at risk of challenge.
While the vast majority have a training requirement, current training standards may vary and PAS advises Councils to “check progress on national changes before reviewing your own council’s schedule of training”.

 

Potential impact

 

The draft Impact Assessment (IA) of the draft Regulations sets out how the national scheme of delegation is likely to affect decision making and appeals, based on past trends and data.
The IA refers to Lichfields research[17] that looked at 640 planning appeals for developments including at least 50 residential units in England from January 2021 to August 2024 and found that 33% arose from a refusal by planning committee contrary to officer recommendation. The draft IA assumes, in the absence of additional data, that the Lichfields 33% figure is appropriate to apply to all appeals relating to major applications (both residential and commercial).
The Government's data and analysis was used to assume that 3% of minor appeals arising from committee's refusing against officer recommendation. MHCLG officials' own analysis found that 40% of major appeals related to applications that had been refused by a planning committee, despite being included in a local plan. The analysis assumes that these applications would now all be approved, but acknowledges that risks overstating the impact. Instead 20% is used as the likely reduction in appeals (with a sensitivity testing range of 5%-40%). Taking into account these factors and others set out in the IA, the authors expect the average annual number of appeals to be reduced by 85 (of which 5 reductions would be major commercial appeals)[18].
Use of Lichfields research has informed an estimate that up to 485 additional homes will be delivered annually this Parliament, as a result of the national scheme of delegation, based on the Office for Budgetary Responsibility (OBR) trajectory of new homes.

 

Regulation review

 

There will be a duty in the regulations in the Secretary of State to undertake and publish a review of the regulations by 31 October 2028, providing an opportunity to assess the effectiveness of the reforms after two years in operation and make any necessary changes.

 

Practical implementation consequences

 

The final regulations are due to be made in July and are scheduled to come into force on 31 October 2026. The guidance expressly notes that if a planning committee makes a decision on or after 31 October, which the Regulations require that only an officer should make, that decision may be subject to judicial review by an aggrieved party, which could lead to the decision being quashed. In practice this situation is unlikely to arise, but it serves as a written warning to frustrated councillors who might conclude that they have less and less control on decision-making - particularly those with an out of date local plan.
As noted at the start of the blog, local authorities will already be thinking about the administration of these changes. Beyond the changes to constitutions and member/councillor protocols, perhaps whether or not to triage Schedule 2 applications will be given particular consideration by planning teams and councillors. With the recent significant changes in leadership of local authorities across England and the new planning committees just bedding in, in many places there will be no existing working relationship between the planning committee chair and the chief planner or equivalents. Against that backdrop, it will be interesting to see which LPAs decide that the planning committee chair will review every Schedule 2 application, which decide solely the Chief Planner will lead on it and, where there is a formalised triage approach, as to whether or not a Schedule 2 discussion is needed.
Given that the chief planner has the casting Gateway Test vote on whether an application is referred to Committee, a triage might only happen where there are truly engaged and collaborative officer/member relationships – or where officers and members want to build them.
There will be much work for officers to do in terms of considering what might be a significant issue or matter in their area, when considering the Gateway Test criteria, in order to derive consistency when making or not making referrals. Consistency will be apparent from the record of discussion that should be kept. Officers will need to liaise with the chair of the planning committee or other nominated member and may also liaise with Councillors more widely on their intended approach.
At this year’s Haymarket Planning Summit[19], concerns were raised about the additional pressure the national scheme of delegation will put on nominated officers, both in terms of discussions with councillors and the public focus on who ultimately made the planning decision. Referring to her attendance at the Summit, albeit not those concerns specifically, Baroness Taylor, Lords Minister for Housing and Local Government, said in Parliament[20]:
“I was with a group of planning officers this morning. If ever a group of council officers suffer this kind of harassment, it is our planning officers. That has to stop. They need to be able to do their job and their consultations without risking harassment and intimidation and be able to make decisions according to law and their professional expertise without fear of harassment”.
Notwithstanding potential alternative approaches to implementation, it is clear that chief planners will wield significantly more control in decision making from Monday 2 November.
 
Footnotes

 

[1] Town and Country Planning Act 1990, Interpretation of sections 319ZZC to 319ZZE

[5] The draft Explanatory Regulations to the draft 2026 regulations, says that “To facilitate a national scheme of delegation, the government intends to amend the Local Authorities (Functions and Responsibilities) (England) Regulations 2000 to coincide with the coming-into-force of this instrument”.
[6] Individual respondents (333) provided their personal view. The other categories are local authority (156), neighbourhood planning body, parish or town council (49), developer (22), other private sector organisation (11), professional body (7), interest group or voluntary organisation (21), other (12)

[8] As above

[10] That is not an own-interest application
[11] The criterion references are capitalised in the guidance
[16] As above

[18] Based on the assumption that residential applications grow with the Office for Budgetary Responsibility’s (OBR) forecast of UK net additions from the October 2024 Economic and Fiscal Outlook. In the 1.5m aligned trajectory, the draft IA authors expect the average annual number of appeals to be reduced by 121.

CONTINUE READING

A sporting chance… transitioning to a post-consultee world
On 18 November 2025, and as part of the Government’s commitment to 'unleash Britain's potential to build', a consultation was launched seeking views on reducing the involvement of statutory consultees in the decision-making process in England. Citing a failure of consultees to engage in a proactive and proportionate way, nor in a timely manner, with responses often failing to be commensurate with that necessary to consider the planning merits of a development[1].
To this end, development proposals include removing Sport England, The Gardens Trust and The Theatres Trust as Statutory Consultees on planning applications. For Sport England in particular, their current role[2] would be reduced down to the following responsibilities:
  1. They would be retained as a plan-making consultation body (and a prescribed body for new plan making[3]);

  2. Be notified (as an amenity society might) on planning applications that would result in the wholesale or substantial loss of playing fields. Sport England could respond if it chooses;

  3. Inform updated Planning Practice Guidance on consultation and pre-decision matters to ensure relevant issues are considered; and,

  4. Play a role in developing guidance for local authorities to assist with their consideration of applications that affect playing fields.

 

Overall, the Government’s view is that the protection already afforded such facilities in the NPPF, alongside local policy and guidance, will be sufficient to secure the right sport and recreation spaces in the right places – maintaining appropriate levels and quality of facilities for the communities they serve.

 

A streamlined system

 

In general, slimming a system that has grown weightier over the years is no bad ambition. Particularly where resourcing has not allowed consultees to keep up with an increased demand on their time. But if an expert group is removed from the process, a greater pressure will be placed on the decision maker, usually a case officer and/or planning committee, to understand the issues, interpret the evidence and conclude on appropriateness. LPA planning departments are themselves, already severely stretched.
It raises the questions as to whether LPA decisions makers have the time and resourcing to fully explore and work around the nuance of the issue. The introduction of guidance and criteria will help to an extent but as with any intervention, we will have to wait and see whether removing a layer of scrutiny speeds up decision making.
When neither the question nor the answer is binary, specialist experience can be a significant advantage. To this end, the quest for greater speed in decision making will not remove the need for applicants to provide technical information in support of applications – indeed it places greater emphasis on the quality and completeness of the evidence presented.

 

Making the Case

 

Lichfields has supported many of its clients in defining and quantifying the need for sport and leisure facilities in an area. Whether that’s supporting the loss of an existing facility, as was the case at Loomer Road, Newcastle Under Lyme (Client: Cole Waterhouse) where  Lichfields successfully demonstrated a lack of demand as well as an alternative provision better suited to the demographic, to support the loss of a motor sport facility in favour of a 300,000 sqft distribution unit. Or at Barony Campus, East Ayrshire (Client: East Ayrshire Council), where Lichfields calculated and evidenced the requirement for playing pitches as part of the merging of educational sites into one combined higher quality provision.
In both cases Lichfields utilised its bespoke product – Fit for Purpose. The tool combines GIS mapping, demographic analysis, assessment of supply and quantification of need to build a profile of the catchment area and need or otherwise for a specific facility or type of service. Articulating the case for the right development in the right place.
Designed to assist both applicants and LPA's, it can be used to:
  • Promote new sport and leisure development;

  • Support the loss of surplus facilities;

  • Develop policy and guidance;

  • Rationalise existing assets and estates

  • Stress test expansion plans; and/or

  • Appraise purchase opportunities.
As we enter an age where the need to articulate the specialist case will be increasingly critical in helping Local Planning Authorities assess the impacts of development, Lichfields has the experience and products to help. Do get in touch, if you would like to find out more.
 
Footnotes

 

[2] Currently LPAs are required to consult Sport England on development proposals which:
(i) is likely to prejudice the use, or lead to the loss of use, of land being used as a playing field; or
(ii) is on land which has been—

(aa) used as a playing field at any time in the 5 years before the making of the relevant application and which remains undeveloped; or
(bb) allocated for use as a playing field in a development plan or in proposals for such a plan or its alteration or replacement; or

(iii) involves the replacement of the grass surface of a playing pitch on a playing field with an artificial, man-made or composite surface
[3] Levelling Up and Regeneration Act 2023: Section 100: Requirement to assist with certain plan-making

CONTINUE READING