# Application Triage

> Given a UK planning application, work out which material planning considerations are actually engaged and which representation skill(s) to run (ecology, transport, heritage, flood risk, …), in what priority order — or advise that there is no strong ground to object. The router for the planning representation skills. Handles amendment applications (s.73 variations, s.96A non-material amendments) by first rebuilding the original permission and every prior amendment. England-focused. Not legal advice; human review required.

- Skill: `seagulltwo/application-triage` (Agent Skill, multi-file: 6 files)
- Install (CLI): `npx skillmds@latest add seagulltwo/application-triage`
- Raw SKILL.md: https://api.skillmd.com/api/skills/seagulltwo/application-triage/raw
- Safety review: pending
- Works with: Claude Code, Claude.ai, OpenAI Codex
- Category: Coding & Dev Tools
- License: MIT
- Author: SeagullTwo (https://skillmd.com/u/seagulltwo)
- Updated: 2026-09-17
- Page: https://skillmd.com/skills/seagulltwo/application-triage

---


# Planning application triage

Help a member of the public who has an application in front of them but doesn't know **which
grounds are worth pursuing**. This skill reads the application, identifies the material
considerations that are genuinely engaged, ranks them, and routes each to the representation
skill that handles it — or says plainly that there is no strong objection.

It is the **router** for the representation skills, not a drafting skill itself. It answers
"what should I object about, and how strong is each ground?", then hands off.

## When to use

The user has a planning application (a reference + council, or the documents) and asks
something like: "should I object to this?", "what are the grounds?", "what's wrong with this
application?", "which of these is worth raising?" Use it first, before the topic-specific
skills, whenever the grounds aren't already decided.

## What you need first

- The **application reference and council**, or the **documents themselves** — uploaded,
  pasted, or already-downloaded files work directly; the companion
  **planning-document-search** skill is only needed when you don't have them (it
  retrieves them from the reference + council).
- The **proposal description and application type** (full / outline / reserved matters / s73
  / listed building consent / householder …) — this frames everything.
- The **site's planning constraints** — is it in a conservation area, near a listed building,
  in a flood zone, Green Belt, an AONB/National Landscape, greenfield? Public constraint data
  (e.g. `planning.data.gov.uk` for conservation areas, listed buildings, Article 4 directions;
  the Environment Agency "Flood map for planning" for flood zones) tells you this without the
  application documents.
- The **document list itself** — it is the single best signal. The presence of an *Ecological
  Impact Assessment*, *Transport Assessment*, *Heritage Statement* or *Flood Risk Assessment*
  tells you which considerations the applicant themselves thought were engaged.
- The **development plan** for the area — the adopted local plan (and any made neighbourhood
  plan), from the council website. Determination starts here (see Step 2), so the relevant
  policies are needed before grounds can be ranked; the companion
  **policy-compliance-assessment** skill identifies and verifies the adopted plan and assesses
  the proposal against it.
- The **site's planning history** — previous applications and refusals, **appeal decisions on
  the same site**, enforcement history where relevant, extant permissions and their
  conditions, and any s73 variations. Portals list related applications on the detail page; a
  previous Inspector's decision on the same site can be worth more than any generic policy
  argument, and a recent refusal tells you what the LPA already considers unacceptable.
- **If this is an amendment application — the parent permission and every earlier amendment.**
  A non-material amendment (s.96A), a variation or removal of conditions (s.73) or a
  "minor material amendment" is a *delta*, and its documents describe only what is changing.
  You need the original permission's decision notice, conditions, approved plans, officer
  report and any s.106, plus every amendment already made to it, before the change means
  anything. See
  [`references/amendment-applications.md`](references/amendment-applications.md).

## The integrity principle

**Only flag a ground that is genuinely engaged and arguable.** Triage is not a licence to
manufacture objections — if the application is sound, or a consideration is not actually in
play, say so. Two disciplines in particular:

- **Distinguish material from non-material.** Objections must rest on *material planning
  considerations*. Common **non-material** concerns to set aside (or reframe): loss of a
  private view; impact on property values; competition with an existing business; boundary or
  covenant disputes; the identity or motives of the applicant; construction disturbance in
  itself (as opposed to a permanent effect); and moral objections. Tell the user honestly when
  their concern isn't material — and whether it can be reframed as one that is (e.g. "it will
  ruin my view" is not material, but "it is overbearing and harms the character of the street"
  may be).
- **Rank honestly.** Not every engaged ground is a *strong* ground. Say which are decision-
  critical, which are supporting, and which are weak — so the user spends effort where it
  counts.

## Workflow

### Step 1 — Intake
Get the application (reference + council, or documents), the proposal and its **type/stage**,
the **site constraints** (conservation area, listed buildings, flood zone, Green Belt,
AONB, greenfield/brownfield, protected trees), and the **site's planning history** (previous
applications, refusals, appeal decisions, enforcement, extant permissions and conditions,
s73s — see "What you need first"). Retrieve the **document list**.

**If the type is an amendment — stop and rebuild the chain first.** For a s.96A non-material
amendment, a s.73 variation or removal of conditions, or a "minor material amendment", the
application in front of you cannot be triaged on its own documents: it describes the change,
not the thing being changed. Work through
[`references/amendment-applications.md`](references/amendment-applications.md) — retrieve the
parent permission and every earlier amendment, reconstruct what the permission consists of
today, and treat that as the baseline the proposal is read against. Two consequences for
triage:

- the grounds are about **the change and the accumulated changes**, not the principle of the
  development, which the parent permission already settled;
- the route itself may be a ground — a change that is material cannot go through s.96A, and
  one that alters the operative description cannot go through s.73.

### Step 2 — Establish the decision framework (s.38(6))
Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires applications to be
determined **in accordance with the development plan unless material considerations indicate
otherwise** — so the development plan is the starting point, not an afterthought. Before
scanning for grounds, establish:

1. the **adopted development plan** — the local plan (and any joint/minerals/waste plans) and
   any made **neighbourhood plan**;
2. the **relevant policies** for this proposal and site (settlement boundaries, housing,
   design, amenity, and the topic policies for each consideration);
3. any **emerging plan** and the weight it can carry (stage of preparation, unresolved
   objections, compliance with the Framework's plan-making policies);
4. **national policy** (NPPF/PPG) as a material consideration alongside the plan.

Grounds framed as **conflict with named development-plan policies** are the strongest kind an
objector can raise — anchor each finding in Step 3 to a plan policy wherever one exists.

Triage needs only enough of this to route. The companion **policy-compliance-assessment** skill
does the work in full — identifying and verifying the **adopted** plan (adoption dates,
superseded and saved policies, the policies map), assessing the proposal policy by policy, and
scoring accordance from -2 to +2. Hand off to it for the policy foundation; don't attempt the
full assessment here. Remember that the adopted policies are the **local authority's own** and
carry primacy: national policy sits alongside the plan as a material consideration, not above it
(though note Annex A(2) of the August 2026 NPPF, which gives "very limited weight" to plan
policies materially inconsistent with its national decision-making policies — the
national-planning-policy skill carries the rule).

The companion **national-planning-policy** skill holds the current NPPF/PPG edition
register, the verify-before-citing protocol, and the shared decision-making citations
(s.38(6) and plan primacy, the presumption in favour of sustainable development — now the
location-based scheme at policies S3–S6 of the August 2026 coded NPPF, which replaced the old
para 11 "tilted balance" — and emerging-plan weight) — use it for this step, including
establishing whether the site is **within or outside a settlement** (S4 vs S5), which S5
gateway (if any) the applicant could claim, and whether a national refusal-directive policy
overrides the presumption for this site.

### Step 3 — Scan for engaged considerations
Work through [`references/material-considerations.md`](references/material-considerations.md).
For each consideration, check the *tells* — the application type, the proposal, the site
constraints, and the presence (or telling *absence*) of the relevant technical document. Note
the evidence for each ground you flag. For each engaged consideration, **locate and read the
matching consultee response** (the consultee map in the reference file says who speaks to
what) — read them before ranking, and note where a consultee objects, seeks conditions, or is
silent.

### Step 4 — Rank
Grade each engaged ground: **decision-critical / supporting / weak**, on the strength of (a)
how clearly the development plan or national policy is engaged, (b) whether the applicant's
evidence looks thin or is missing, and (c) how much weight the consideration typically
carries. Set aside non-material concerns (with a reframe where possible).

Then apply the **"so-what" test**: a list of technically valid criticisms is not itself a
case for refusal. Note for each ground whether it points to **(A)** a demonstrated
unacceptable impact (a refusal reason), **(B)** insufficient evidence for the Council to
reach the necessary conclusion (a "do not determine yet" ask), or **(C)** something a
condition or obligation could secure (a mitigation ask) — and say honestly whether the
grounds, taken together, would plausibly justify refusal under the applicable tests, or
whether the credible representation is one that seeks information and conditions. The
companion **planning-balance** skill runs this test in full once the representation skills
have evidenced the grounds — recommend it as the final step of the chain.

### Step 5 — Route
For each ground worth pursuing, name the representation skill that handles it and hand off:

| Consideration | Skill |
|---|---|
| Ecology / biodiversity / protected species / BNG | **ecological-representation** |
| Transport / highways / access / parking / active travel | **transport-representation** |
| Heritage / listed buildings / conservation areas / archaeology | **heritage-representation** |
| Flood risk / drainage / SuDS | **flood-representation** |
| Other material considerations (design, amenity, Green Belt, landscape, …) | *no dedicated skill yet — see the map for the framework and argue on the documents' own facts* |
| Compliance with the adopted development plan, policy by policy | **policy-compliance-assessment** (the policy foundation — run early; it underpins every ground) |
| Drafting the policy case, in support **or** objection | **policy-representation** (after the policy assessment) |
| Final check — does the assembled case justify the ask? | **planning-balance** (run last, after the representation skills) |

Recommend an order (lead with the decision-critical grounds). Note where two skills should
both run (a scheme often engages several).

### Step 6 — Hand off / summarise
Give the user a summary they can scan, not a paragraph. Present:

- the **grounds worth objecting on** — a ranked list, each ground on its own line with the
  development-plan policies it engages, its A/B/C class, and the skill that will draft it;
- the **non-material concerns to drop**, as a short list with the one-line reason each;
- or — if that's the honest answer — a plain statement that there is no strong ground and an
  objection would not be sustainable.

Any enumeration of three or more items goes in a bulleted or numbered list; never string
grounds, policies or asks through a prose paragraph with semicolons.

## Reference files

- [`references/material-considerations.md`](references/material-considerations.md) — the
  catalogue of material considerations: what each is, the tells that it's engaged, the skill
  or framework that handles it, and the common non-material concerns to exclude.
- [`references/amendment-applications.md`](references/amendment-applications.md) — amendment
  applications (s.96A, s.73, ⏳ s.73B): how to spot one, what each route can and cannot carry,
  how to rebuild the parent-and-amendments chain, what to compare against it, the
  cumulative-drift patterns, and which grounds are available on an amendment.

## Scope and limitations

- **Not legal advice; no warranty; output requires human review.** Triage is a starting
  assessment, provided "as is"; a person must confirm the grounds and the evidence before
  acting.
- **England-focused.** Material considerations are broadly similar across the UK but the
  policy framework differs in the devolved nations — flag when the application is outside
  England.
- **A UK planning representation is public and in the submitter's name** — carry that warning
  through to whichever representation skill drafts the objection.
- **"No strong ground" is a valid, valuable output.** Say it when it's true.

