Take a scheme through consent with each stage, cost and commitment accounted for
A Development Consent Order brings together hundreds of requirements, dependencies and commitments, made by many parties over several years, and schemes struggle when the deliverables, decisions and commitments are not managed as one system. We help promoters understand the consenting route, size its cost and duration, and keep track of what has been promised, from route selection to compliance once the Order is made.
Why consent is difficult
The statutory steps are well known; the difficulty is everything that has to be decided, produced and promised around them.
A Development Consent Order is how nationally significant infrastructure in England and Wales gets permission, under the Planning Act 2008. It covers roads, rail, ports, airports, power generation including nuclear, power lines, pipelines, reservoirs, water and waste.
The process is well documented, yet it defeats schemes that cannot manage their deliverables or check their submissions before they go in. Technical studies depend on one another, and each commitment made to a landowner, statutory body or community has to be carried into the Order and honoured in construction. Held in separate trackers by separate teams, the gaps appear late, when they are most expensive to close.
Where the time and cost risk sits
The back half of the process runs to statutory time limits, which the Secretary of State can extend. Most of the time and cost risk sits in pre-application, which has none.
What changed in July 2026
On 24 July 2026 the Planning and Infrastructure Act 2025 changed the front end of the DCO regime. Much of what was written about pre-application before then describes rules that no longer apply.
- Six statutory pre-application provisions were omitted (ss.42, 43, 44, 45, 47 and 49), and with them the Statement of Community Consultation and the Consultation Report.
- The acceptance test was rewritten. It now weighs regard to guidance and advice, with the s.46 notification kept as a hard gate.
- A 10% biodiversity net gain requirement applies to relevant schemes in England for applications made on or after 2 November 2026. The application date decides whether it applies; whether the gain is achieved is tested at examination. Habitat surveys are seasonal, so that evidence cannot be gathered at short notice.
The examination timetable, the decision tests and the judicial review window have not moved. The consultation record is now a judgement a promoter may have to defend, and objections that are not dealt with early tend to return at examination or in a challenge to the Order.
How we approach it
We start with the scheme's route and constraints, and then make each duty, dependency and commitment visible and owned by someone.
- Understand the routeAgree the consenting strategy with the promoter's team: the route, the consenting bodies, the land interests and the decisions that must be taken first.
- Size it on evidenceEstimate cost and duration from the scheme's own drivers, with each assumption stated, and test a planned case against a real-world case.
- Structure the workSet out the consenting processes with named owners, so each deliverable, review and decision has someone accountable for it.
- Keep the recordRecord engagement, decisions and the reasons behind them from the start, so the consultation record can be defended if it is challenged.
- Carry it into complianceMap requirements and commitments to the construction activities they control and track each one to discharge.
We work alongside the promoter's planning, legal and environmental advisers, giving their work a shared structure and an evidence base.
What a scheme can draw on
A promoter may need one of these or all four, depending on where the scheme has got to and what is already in place.
What a promoter gets from it
The work gives a promoter a clearer basis for its choices, though it cannot remove the uncertainty that the process itself carries.
Without it
- A budget by recollectionCost and duration taken from memories of earlier schemes, with no published benchmark to test them against.
- Resources spread flatThe examination peak arrives as a surprise to the team carrying it.
- Ownership by memoryDuties and deliverables held by whoever happens to remember them.
- Commitments that driftPromises made in consultation lose their thread before they become requirements.
With it
- A budget that shows its reasoningA cost and duration range in which each coefficient can be seen, questioned and changed.
- A resource plan that fits the processExamination budgeted as the peak it is, rather than spread flat across the programme.
- Clear ownershipEach duty, deliverable and decision with a named owner, and visible dependencies between them.
- Commitments that can be tracedEach promise made during consenting followed to the requirement it became and the activity that discharges it.
The research behind it
Built from public sources and checked against the primary law.
Research
Consenting at speed
The Consenting at speed worked example sets out what the July 2026 reforms changed, checked against the statute and the instruments, and builds an evidence base on how DCOs actually run. It comprises the DCO Explorer, which classifies every published NSIP document and models them as a knowledge graph; the DCO Cost Estimator; a referenced statement of the reforms; and a reference corpus of 252 documents.
Its main finding is that examination is a spike rather than a curve, and that the reforms leave that spike where it was.
The services and software behind it
Strategic and operational advisory covers the consenting strategy, the sequencing of decisions and the resourcing of examination. Systems modelling and simulation sits behind the cost and duration estimate and lets a promoter test scenarios before committing. Process and organisational improvement gives the consenting work a clear structure of owners, handovers and reviews. Data, integration and implementation connects the trackers, document stores and GIS the team already uses.
Common questions
If yours is not here, ask us directly.
The 2026 reforms removed statutory consultation. Do we still need to engage?
Yes. The duty to consult has gone, but engagement still matters. The s.46 notification remains a hard condition for acceptance, subject to a narrow saving for applicants who had already notified, and s.48 publicity survives. The rewritten acceptance test looks at how a promoter followed government guidance and the Inspectorate's advice. That guidance recommends engaging early, and objections that are skipped tend to return at examination.
How reliable is the DCO cost estimate?
Treat it as a structured judgement rather than a quotation. No published benchmark exists for DCO consenting cost, so each coefficient is either derived from public document and duration data or is stated practitioner judgement, and each one can be seen and changed. It shows a planned case and a real-world case with longer pre-application and a heavier examination. Its duration data predates the 2026 reforms, so pre-application figures are historic.
Why budget the examination as a peak?
Because that is how the work arrives. For about six months, a period set in statute, a team answers written questions and attends hearings; then the load falls away.
Does the work stop once the Order is made?
No. Requirements and commitments need the same care as the application. The work maps each requirement to the construction activity it controls, tracks its discharge, and monitors mitigation commitments and secondary consents. It also records lessons and precedent for the next scheme.
Do we have to use Project:OS?
No. The consenting structure can run in Project:OS or be set up in the systems your team already uses. The advice and the estimates do not depend on either.
Talk to us about your scheme
Tell us where the scheme is, what has been decided and what is worrying the team. We can help work out where to begin.
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