System 13 · Consultee reform consulted on, January 2026

Sightline

Statutory consultee advice, and what happened to it

Active Travel England advised on 2,045 planning applications covering 521,000 homes last year. It published none of it. Government is reforming statutory consultees using almost no data on what they achieve.

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The problem

Certain expert bodies must be consulted on planning applications. They give advice, councils decide, and almost none of that advice is published as data.

Active Travel England became a statutory consultee in 2023. In 2025-26 it responded to 2,045 consultations covering more than 521,000 homes and recommended improvements on applications comprising 191,000 homes. It holds every one of these in a casework system. Of its 79 publications, exactly two are transparency releases and both concern funding. Even its council capability ratings are published as a PDF.

Its own independent reviewer recommended creating a framework to record outcomes — meaning the body was not systematically tracking what happened to its advice, let alone publishing it.

The Environment Agency shows the other failure mode. It does publish flood objections at application level — 23,336 records across 426 authorities, including 633 where permission was granted against its advice, covering 347,425 homes. But the file carries no location of any kind, and for 7,011 records the Agency does not know what the council decided. Published and unmappable.

Meanwhile government consulted through January 2026 on cutting statutory consultee involvement by around 40%. A reform premised on consultee burden, conducted with essentially no public data on consultee outcomes.

2,045
Active Travel England consultations last year, none published as data
521,000
Homes covered by that advice
7,011
Flood objections where the Agency does not know the outcome
~40%
Proposed reduction in consultee involvement, consulted on with no outcome data

The system

Sightline builds the outcome layer for statutory consultee advice: what was advised, what was decided, and what was built.

It starts with the Environment Agency data because it is already published and needs only resolution — the objections become mappable, the unknown outcomes get recovered, and the compliance picture becomes checkable rather than asserted.

It then extends the same template to Active Travel England. The casework exists in a structured system; the ask is publication, not creation. A working demonstration on flood data is the strongest possible argument for it.

And it gives the consultee reform an evidence base. If the case for cutting consultee involvement is that it delays development without improving it, that is a testable claim — and nobody can currently test it.


Worked examples

Two situations this system answers

EXAMPLE 1
The problem

Active Travel England advised on planning applications covering 521,000 homes in a single year and published none of it. Government is now cutting consultee involvement by around 40%, with no data on what that advice achieved.

What Sightline does

Sightline records what was advised, what was decided and what got built — so the change can be judged on evidence rather than assumption.

EXAMPLE 2
The problem

A council overrides expert advice on a development. Residents want to know whether that is unusual. No published source can tell them.

What Sightline does

Sightline publishes how often each council overrules expert advice, with the context — including that the rate has actually been flat for nine years, even though the raw numbers rose.


Data foundation

Every dataset below is open, or its access constraint is stated

DatasetPublisherWhat it provides
Flood risk objectionsEnvironment Agency23,336 records, 426 authorities, open licence. No spatial reference. Outcome unknown for 30%.
Water quality objectionsEnvironment AgencyA second, smaller sheet in the same file with an objection reason field — largely untouched.
Active Travel England caseworkATEOver 2,000 responses a year covering 521,000 homes. Held in a structured system, published nowhere.
Planning applicationsMHCLG and authority portalsThe decisions that consultee advice was given on.
Flood zonesEnvironment AgencyOpen geospatial services with no key required — the layer objections need joining to.
New-build energy certificatesMHCLGWhether advised-against development was actually completed and occupied.

Capabilities

01
Advice-to-outcome chain
Consultee advice resolved to a site, joined to the decision, and followed through to completion.
02
Outcome recovery
The 7,011 cases where the Environment Agency does not know what the council decided.
03
Override analysis
Which authorities grant against expert advice, in what circumstances, and with what context — housing pressure, viability, defence status.
04
Reform evidence
Whether consultee involvement changes outcomes, which is the premise of the reform now under way.
05
Publication template
A worked demonstration of what a consultee outcome dataset looks like, usable by any consultee body.
06
Versioned archive
Each annual release preserved, since the source silently restates history and the reform may break the series entirely.
07
Coverage metric
Resolution coverage published rather than assumed.

Benefits

For government

  • Gives the consultee reform the evidence base it currently lacks, before the reform is enacted.
  • Lets consultee bodies demonstrate their own value, which they presently cannot.
  • Supplies the Environment Agency with the outcome data its own sampling approach cannot produce.
  • Creates a reusable publication template for every statutory consultee, not just two.

For the public

  • Communities can see whether expert advice about a development near them was followed.
  • The trade-off between development speed and expert scrutiny becomes measurable rather than asserted.
  • Bodies giving advice on public safety become accountable for whether it lands.

Delivery

Likely sponsor
Environment Agency, Active Travel England, MHCLG Planning, Defra
Procurement route
SBRI for resolution and recovery, then DOS7 for the service

Phasing

1
Flood objections
4 months
Resolve, map and archive the already-published dataset. Publish the recovered compliance figure.
2
Outcome recovery
4 months
Close the unknown-outcome gap and report the corrected national position.
3
Template and advocacy
4 months
Publish the consultee outcome specification and take it to Active Travel England.
4
Second consultee
6 months
Extend to active travel casework, subject to publication being agreed.

Risks & mitigations

Publication is a decision, not a build

The active travel half depends on a body agreeing to publish. The flood half does not, which is why it comes first and carries the argument.

The series may break

Consultee reform proposes removing objections in some circumstances, which would discontinue the only national indicator. The archive makes that break visible rather than invisible.

Contested framing

Authorities will object to being ranked on overrides. Context is reported alongside, and the finding that the override rate has been flat for nine years is published as prominently as the rising counts.


Sources

All sources checked in August 2026. Figures carry the reference period of their source, which may differ from publication date. Where a figure could not be verified against a primary source it is not used.