The DCO, digitised.
A Development Consent Order is how Britain says yes to nationally significant infrastructure — energy, transport, water. The time to win one has risen by almost two-thirds in a decade, yet almost none of that delay sits in the six-month Examination. It hides in the paper — a draft Order whose truth is reconstructed by diffing yesterday’s PDF against today’s, a Book of Reference no one can query. The Planning and Infrastructure Act 2025 has cleared the statutory ground; the paper era of consenting is over.
Sister manifesto to Digital EIA (opens in a new tab) — the same fight, one regime upstream.
What we file, and what it costs us
The DCO is the single consent everything orbits — drafted, tracked, re-issued at every deadline until the Secretary of State signs it. Credited with cutting consent times to around four years, against the eight Heathrow Terminal 5 took, the process has since drifted back toward the timescales it was meant to fix. Almost none of the slowdown sits in the fixed six-month Examination. It hides in the paper — and the evidence is the government’s own.
In government’s own words, DCO documentation now “runs to tens of thousands of pages” (MHCLG), with some applications exceeding 90,000 (NSIP Action Plan) — every page a PDF submitted deadline-by-deadline into the Examination Library, a volume government associates with slower decisions, more litigation and added cost.
The bottleneck was never the Examination. Statutory pre-application almost doubled, from 14 months in 2013 to 27 in 2021 — the drudgery the statutory clocks never touched. The National Infrastructure Commission found uncertainty over consultation volume stretched it from three years at Hinkley Point C to seven at Sizewell C.
There is no single live draft Order. Advice Note Fifteen requires each revised draft accompanied by a tracked-changes version and a supporting explanatory document of proposed changes; in practice applicants file a clean draft, a tracked draft and a standalone Schedule of Changes. The “truth” is reconstructed by diffing across versions — and a stray un-tracked edit can slip through.
National Highways told the Banner Review that legal challenges add this much per scheme (para 52). The cost is rarely the loss — of around thirty challenges to a granted DCO, only four were ever quashed. The cost is the delay.
The statutory ground has been cleared
Digital DCO is not a forecast. The regime is being rebuilt in law, government has staked a Parliament’s worth of targets on clearing the consenting bottleneck, and the Inspectorate itself has named the destination: a shift from documents to data — all inside a handful of years.
A regime built for speed
The Planning Act 2008 creates the DCO out of the eight-year Heathrow Terminal 5 inquiry — a single consent with a tight statutory clock, decisions targeted within roughly 17 months of application. The regime goes live in March 2010; since then it has consented over 130 projects at a ~95% approval rate (MHCLG). Certainty of process was always the promise.
The slowdown
Average consenting time reaches 4.2 years, a 65% rise from 2.6 in 2012, with pre-application almost doubled to 27 months. All four DCO quashings to date — A303 Stonehenge, Manston, A38 Derby, Norfolk Vanguard — fall in a single unprecedented run this year. The six-month Examination clock is still met every time; the slippage hides upstream and downstream of it.
Documents to data, in writing
The NSIP Action Plan commits to a deliberate “shift over time from documents to data” to enable “simpler and faster analysis and interrogation” — the clearest official endorsement of the Digital DCO premise, with PINS tasked to deliver it. The same year, Lower Thames Crossing is examined as the UK’s longest-ever planning application, over 63,000 pages in the application alone.
The law is rewritten
The Planning and Infrastructure Act 2025 receives Royal Assent on 18 December — scrapping statutory pre-application consultation, a leading driver of the slowdown, for a saving government puts at up to 12 months and over £1bn across the pipeline (subject to commencement); cutting hopeless judicial reviews to one attempt rather than three; and mandating five-yearly review of every National Policy Statement.
A target that demands it
Government has pledged decisions on at least 150 NSIPs by the end of this Parliament (no later than July 2029) — almost tripling the 57 decisions of the previous Parliament. By 30 January 2026 only 38 were decided, leaving 112 to go, with independent analysis rating the pledge behind schedule. A faster, queryable DCO process is now a necessity, not a nicety.
The Inspectorate names the future
PINS sets out a database-driven future, away from “line by line, standalone, long form” documents toward structured data — yet, as of early 2026, DCO applications are still uploaded to a SharePoint site and remain predominantly long-form standalone documents, effectively PDFs, with a purpose-built portal still in design. One recent grid-connection project drew around 6,500 registered parties. The gap is the opportunity.
A second destination: outcomes, not impact statements
Beyond procedure, the environmental content itself is set to change. The government’s “Roadmap to reform” (March 2026) targets Environmental Outcomes Reports — created by the Levelling-up and Regeneration Act 2023, not the 2025 Act above — to replace EIA for Planning Act 2008 projects by the end of 2027: a shorter, data-led report in place of a multi-thousand-page Environmental Statement. It is a target, not yet law, and is separate from the consenting reforms above; until it commences, DCOs remain under the Infrastructure Planning (EIA) Regulations 2017.
We hold these to be true
Digital DCO is not a new format for the same bundle of PDFs. It is a different way of running a consent — grounded in seven principles, written for anyone who has lived a six-month Examination.
One live draft Order, not diffed PDFs
The draft DCO — articles, Schedules, Requirements — is the artefact everything orbits. It should exist once, as living, version-controlled text, with the tracked changes and the explanatory schedule of changes generated automatically. The audit trail Advice Note Fifteen demands becomes a by-product, not a chore, and no stray un-tracked edit can slip through.
The Book of Reference is data, not a 16,000-page table
Every land interest, plot by plot, sorted into Categories 1, 2 and 3 under s.57 of the Planning Act 2008, belongs in a queryable register kept in sync with the Land Plans — not a PDF no one can search. Capture the diligent inquiry once, get the categories right by construction, and the compulsory-acquisition case is defensible from the outset rather than challenged after.
One source of truth, application to decision
Applicant, Examining Authority, consultees and the public read the same live record — not divergent copies reconciled by email under deadline. The Examination Library becomes a dashboard you search and filter, not a flat list of hundreds of near-identically-named PDFs you read by archaeology.
Common ground tracked, not hand-coloured
Statements of Common Ground and the Statement of Commonality are living data, not a traffic-light matrix re-coloured and re-filed every deadline. Status flows from the parties themselves, so the ExA sees where agreement stands in real time — and an unsigned SoCG at close is a flag, not a surprise.
Representations and questions, threaded to resolution
Written and relevant representations and the ExA’s two rounds of questions are linked, not loose. The same issue raised by fifty parties — or 6,500 — is grouped automatically; every ExQ1 and ExQ2 is threaded to its answer, its follow-up and the precise change to the draft Order — instead of cross-referencing separate PDFs by hand against a tight clock.
Requirements that outlive consent
Consent is not the end. Each Requirement carries a queryable status — drafted, agreed, discharged, pending or in dispute — into the post-consent life of the project. Discharge stops being a PDF-and-email tail tracked in spreadsheets outside the portal, and the named discharging authority works from the same register as the promoter.
Auditable and defensible by construction
Every edit, every assumption, every contributor recorded as it happens — across the draft Order, the Book of Reference and every deadline submission. With 58% of major infrastructure decisions now taken to court and the Banner Review putting the challenge rate around 22%, the answer is not more pages, but a record that is auditable the moment it is made, not reconstructed after the decision.
A consent you can see, query and trust
Picture the whole Examination on a single live board: every deadline, every submission, every party, and the draft Order itself as one version-controlled text rather than a stack of tracked PDFs. The Book of Reference is a register you can filter by plot or category, kept in sync with the Land Plans. Statements of Common Ground update in place as parties agree; the Statement of Commonality colours itself. Every ExQ threads to its answer and the change it sought, and every Requirement carries its discharge status long after the Secretary of State signs.
This is the consent ConsentPath was built to run.
- One live board for the whole Examination, application to decision
- A single version-controlled draft DCO — articles, Schedules and Requirements
- A machine-readable Book of Reference, synced to the Land Plans
- Self-updating SoCGs and a Statement of Commonality that colours itself
- ExQ1 and ExQ2 threaded to answers, representations auto-grouped
- A queryable register of Requirements, tracked through discharge
The DCO is going digital. Help us build it.
If you promote, examine, consent, advise on or live with nationally significant infrastructure — promoter, planning lawyer, consultant, local authority or PINS — this transition needs you. You have lived the deadline-day scramble and the diffed draft Order. Help us make sure the next Examination runs on data, not paper. Sign the manifesto and tell us you would like to participate.
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