11th Jan 2018



As regular readers of this blog will be aware, I have concerns about the limitations of the data used in planning applications.

This also now appears to be shared by Mark Avery.


What are limitations? A planning application is a bunch of documents that look at the range of possible effects from a proposed development. As well as the standard issues about overlooking, light, access etc that exercise most people, applications will often (and should) include details about possible biodiversity impacts. Limitations are the bit of an assessment that say there were problems in doing some of the surveys, and perhaps (perhaps not) they will have affected- or limited- the interpretation of the data. Potentially, this is a rather important entry in an application. If the limitations are important, you can't say there will be no impact.


To discuss impacts requires good, reliable data. This is harder to provide than it seems, apparently. I'm working on a data check from 30+ site applications and looking at the quality of the data used. As almost no surveys met the precepts set out in the methods supposedly followed- holes due to timing, weather, cows destroying bat recorders etc- you'd expect a lot of lengthy limitation sections in ecological submissions. Oddly, or not, they are often missing. 46% lacked limitations sections at all. Those that had them were poorly explained, and none- in spite of glaring holes- seemed to think limitations mattered. No tests were made, and no credible reasons were given. Most resorted to that old saw: professional judgement. As the professional judgement defence requires reasoned data and validation, and these were missing, this was underwhelming.


I'll update the story in a blog or two soon. In the meantime, the only limitation to planning limitations is the lack of limitations in the documents......