Last month, members of the RSUA Armagh City, Banbridge and Craigavon Local Group met with Damian Mulligan, Head of Planning for that area’s Borough Council, to discuss issues and concerns related to the planning process.
Damian was joined by Planning Manager Sinead McAvoy, Principal Planning Officer Helen Stoops and Tom Lavery, the Council’s Head of Building Control.
Local Development Plan
The Council is currently working on its Draft Plan Strategy to be ready for public consultation by November 2025 and eventual implementation in 2027.
The Plan Strategy will set the strategic direction of the Local Development Plan, providing a level of certainty on which to base key development decisions within the area up to 2035.
It will also establish the necessary framework for preparing the Local Policies Plan. The Strategy will outline the aims, objectives, overall growth strategy and associated strategic policies for the plan area.
RSUA members asked that the Council notify them of policy changes well in advance of the publication of the Strategy so that applications submitted in the interim are not invalidated after its implementation.
The Council agreed and raised the option of discussing this at Pre-Application Discussion stage.
Allocation of affordable housing
RSUA members raised that the current Area Plan does not sufficiently define where affordable housing is required and that this should be rectified in the new draft.
The perceived issue is that housing is being developed in areas that are not necessarily priority areas for Housing Associations while other developments are being stalled as a result.
The Council agreed to explore possible solutions to this challenge.
Planning Application Validation Checklist
In April 2025, the Council brought forward its statutory Planning Application Validation Checklist. While the new checklist is similar in concept to the previous version, a key difference is that the additional information requirements are now mandatory.
At the meeting, RSUA members emphasised that the Council should avoid requesting all information requirements at the outset if doing so is unrealistic.
As this approach relates to Biodiversity Checklists, we warned that it risks the validity of environmental surveys timing out due to delays occurring beyond architects’ control – for example, the overall shortage of ecological consultants.
The Council stated that it is exploring how it might lobby the Department of Agriculture, Environment and Rural Affairs and the Northern Ireland Environment Agency to address the current shortage of these consultants.
The Council also recommended that all concerns architects have with the operation of the Checklist should be reported to them so that these can help inform the Northern Ireland-wide Planning Improvement Programme.
Planning performance update
The Council reported that major applications are being processed within 18 weeks, and 80% of enforcement cases are being handled on time. Although the Council is currently missing its target for local applications, it noted ongoing improvement in performance.
Staffing levels and continuity of personnel were said to remain ongoing challenges. There are approximately 800 live applications with the Council at present.
RSUA members responded that they are noticing an improvement in processing times in the area.
Pre-Application Advice delays
One member raised concerns about significant delays in the Council’s response to Pre-Application Advice submissions. Although official guidance states that a reply should be issued within 10 working days, responses are currently taking a minimum of 10 weeks.
The Council agreed to review this issue.
Contacting the planning department
Another member questioned why the planning section cannot be contacted via the Council’s main telephone system and continues to use an external system instead.
The Council agreed this was suboptimal and said it was happy to take the issue up with NI Direct.
Post-submission procedure for amended drawings
Although the Northern Ireland Planning Portal now allows agents to upload additional or amended drawings directly, one member raised concerns that the process following submission remains unclear.
They reported delays to applications as planning officers are not always aware that changes have been submitted.
The Council agreed to investigate this matter further.
Procedure for following up on consultation responses
A member also asked whether the Council could clarify its procedures for following up on statutory consultation responses. They reported that some responses are taking up to a year and expressed concern that the Council is not following up with sufficient urgency.
The Council again raised its resource challenges but said it was actively working with statutory consultees to improve communication.
If you have any questions or comments about this meeting, or would like to join the RSUA Armagh City, Banbridge and Craigavon Local Group, please contact Curtis Large, RSUA Policy and Public Affairs Officer, at curtis@rsua.org.uk
