As we enter prime ‘game season’, Nexus Planning’s Jack Dickinson and Matt Dugdale have been tracking some potential targets across the Midlands and the North.

There’s been plenty of movement in the valleys and on the moors of late, with Leeds launching a Local Plan Update and Sheffield releasing a Publication Draft Local Plan. This follows a hive of activity on the plains and in the forests, where there are forthcoming consultations in Central Lancashire and Greater Nottingham.

Against the backdrop of uncertainty and rumoured changes to the assessment of local housing need (‘LHN’), we’ve been taking stock of the approaches these authorities are taking to meet their objectively assessed needs in line with paragraph 61 of the National Planning Policy Framework (‘NPPF’), published July 2021. Currently this should be calculated using the standard method in national planning guidance (including a 35% uplift for the urban centres of Leeds, Nottingham and Sheffield), unless exceptional circumstances justify an alternative approach. In addition, any unmet needs from neighbouring areas should also be taken into account.

We compare the approaches below:

Authorities Adopted Plan Requirement Standard Method Figure (LHN) Emerging Plan Requirement +/- vs LHN
Central Lancashire
(Chorley, Preston, South Ribble)
1,341 dpa 989 dpa 1,334 dpa +345
Greater Nottingham
(Broxtowe, Gedling, Nottingham City and Rushcliffe)
2,571 dpa 3,282 dpa 3,119 dpa -163
Leeds 3,247 dpa 4,044 dpa N/A -797
Sheffield 1,352 dpa 3,018 dpa 2,100 dpa -918

Both Sheffield and Greater Nottingham argue that ‘exceptional circumstances’ exist and thus take a capacity-led approach to delivering housing through their emerging plans. In both cases, that capacity is below – Sheffield, -30% and Greater Nottingham, -5% – their LHN figures. In other words, they plan to feed off sites in the existing urban area, instead of hunting for those prosperous catches in the countryside and Green Belt.

Meanwhile, Leeds are not reviewing their adopted housing requirement in their ongoing partial review, despite it being 20% below their LHN figure.

The only ones bucking the trend are Central Lancashire, where an ‘increase’ of 35% has been suggested. This is despite Central Lancashire not being included in the top 20 urban centres where a 35% uplift has been added to the standard method.

We look at each authority in more detail below.

Central Lancashire (Chorley, Preston and South Ribble)

In September 2022, the three authorities hosted a Developer Forum where they gave the industry a scent of the housing evidence sitting behind their emerging Joint Local Plan.

On the face of it, Central Lancs appear to show some lofty ambition. They have, in principle, set out an approach which exceeds their LHN figure of 988 dwellings per annum (‘dpa’), by pursuing a housing requirement of 1,334 dpa.

However, when you consider this in context, the scale of growth is broadly in line with their existing adopted Core Strategy housing requirement (1,341 dpa) which dates from 2012. That figure is one which the authorities have aspired to, but haven’t managed to achieve over the past decade as evidenced by numerous appeals.

Despite this, the justification for ‘increasing’ the housing requirement stems from their disagreement with the use of the 2014 household projections underpinning the standard method. They argue that recent high levels of completions, coupled with the lower growth experienced during the time the projections were made, indicate a clear backdrop against which to depart from a ‘top down’ set LHN (notwithstanding any rumoured changes at the national level).

Central Lancs also shared their ‘Preferred Distribution’, or a stepped housing requirement, which is they say is aligned with land availability (although it is unclear at this stage whether this equates to urban sites or the release of Green Belt and/or safeguarded land). However, it does reveal that Preston is expected to deliver proportionately more units early in the plan period, while South Ribble and Chorley will be more relied upon in later years. We expect this strategy to be hotly contested as the new plan progresses.

Consultation on ‘Preferred Options’ (Regulation 18) is expected to launch in December 2022 or January 2023.

Greater Nottingham (Broxtowe, Gedling, Nottingham City and Rushcliffe)

At the end of September, the Greater Notts Joint Planning Advisory Board set out their intention to move away from their LHN figure.

Instead, they account for a ‘capacity-led’ strategy on the basis that Nottingham City’s 35% urban centres uplift (to the standard method) constitutes ‘unevidenced need’, and thus does not amount to the ‘exceptional circumstances’ necessary to justify Green Belt release. Without Green Belt release and without directing unmet need to its neighbours, Nottingham City cannot meet the LHN figure and therefore they propose to rely on identified capacity to set their housing requirement.

The Joint Planning Advisory Board state that the addition of a 10% ‘buffer’ to Broxtowe, Gedling and Rushcliffe’s LHN gets Greater Notts somewhat closer to the total sub-regional LHN figure, and therefore ‘the level of provision is sufficient to meet the vast majority of OAN’. However, they still fall short by 5% overall. We expect the industry and the Planning Inspectorate to push back on this approach at consultation and subsequent examination.

Greater Notts are launching consultation on their ‘Preferred Approach’ (Regulation 18) on 12 December 2022.


Leeds are looking to limit the scope of their update to the Core Strategy (which itself was last amended in September 2019) to exclude any consideration of revising their LHN.

Instead, the Update points to amendments taking account of climate change issues, in response to the City Council declaring a climate change emergency in 2019. Tweaks are proposed to require development to meet the highest standards of sustainability, carbon consumption and water efficiency.

There is also a renewed focus to flush out the sustainability (in terms of location) of new development, with ‘20 minute neighbourhood’ principles being brought into policy. In addition, those who are often held up on the Inner Ring Road will be pleased to hear there is a proposed policy regarding mass transit infrastructure and promoting development which supports it.

However, those looking to challenge Leeds’ housing strategy may draw a blank. Whilst the Update does not directly influence allocations or the supply of housing and employment land, it will be interesting to understand, in time, how the more ‘onerous’ development management policies introduced in response to the climate emergency will affect future delivery and whether this makes other opportunities more biddable.

Consultation on the Local Plan Update (Regulation 19) remains open until 19 December 2022.


At the end of October 2022, Sheffield went public with their Publication Draft Local Plan, which was debated and endorsed at a Transport, Regeneration and Climate Policy Committee in early November 2022.

Like their near neighbours Greater Nottingham, Sheffield are restricted by the Green Belt and claim that releasing land from within it would cause more harm than not meeting their LHN, and therefore they are similarly taking a ‘capacity-led’ approach. By not opting to review Green Belt boundaries, and without working with their neighbours, Sheffield is heavily reliant on the delivery of sites in urban areas.

For example, a large proportion of growth (over half of new homes) is proposed in the ‘Central Sub-Area’, which only just extends beyond the Ring Road into Kelham and Neepsend. Whilst the remaining growth is spread relatively evenly (but thinly) around the rest of the city, the proposed reliance on the Central Sub Area to deliver almost 70% of new allocations has the potential to restrict choice in the market and risks the city centre leaving its suburbs and districts behind.

With Sheffield having found external investment tricky to come by in recent years, it is possible the reliance on the delivery of high density private sector housing will be thoroughly tested by the industry and Planning Inspectorate as the plan progresses further.

Whilst the aspiration to deliver an urban utopia is commendable, especially having regard to both climate change and biodiversity, in reality this could be to the detriment of providing the choice of homes that the market needs, potentially leaving Sheffield some work to do to balance and perhaps realign its delivery expectations.

Consultation on the Draft Sheffield Plan (Regulation 19) is due to launch on 9 January to 20 February 2023.

Getting in touch

Nexus Planning continue to keep Local Plan progress across the Midlands and the North in our sights. Please get in touch to discuss any of the above in more detail or to request a copy of our latest Local Plans tracker.

Authored by

Matt Dugdale, Associate Director

M   07732 687 309


Jack Dickinson, Principal Planner

M   07875 723 488