Statement of common ground

A draft statement of common ground (SoCG) is a written statement containing factual information about the proposal which is the subject of the appeal that the appellant reasonably considers will not be disputed by the local planning authority.

An agreed statement of common ground is essential to ensure that the evidence considered at a hearing or an inquiry focuses on the material differences between the appellant and the local planning authority. It will provide a commonly understood basis for the appellant and the local planning authority and provide context to inform the statements of case and, for an inquiry, the subsequent production of proofs of evidence.

SoCG can be extremely valuable to inspectors and can improve the effectiveness and efficiency of the process. The guidance is intended to assist all professional representatives and expert witnesses in compliance with their duty to assist the inspector.

In November 2024, the Planning Inspectorate published updated guidance on Statements of Common Ground for appeals

The revised guidance provides a comprehensive overview of SoCGs, including:

• a detailed explanation of legislative requirements and relevant procedure rules
• the introduction of ‘topic-specific SoCGs’ to supplement the main SoCG
• clear timelines for submitting SoCGs, emphasising the importance of meeting deadlines
• guidance on collaboration between parties, including potential involvement of Rule 6 parties
• recommendations for format and presentation, encouraging the use of searchable documents, tables, and diagrams
• information on the legal weight of SoCGs and potential consequences of unreasonable conduct

The guidance is available at: https://www.gov.uk/government/news/updated-guidance-on-statements-of-common-ground-for-appeals

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