Emerging local plans – fair game or folly?

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

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.

Sheffield

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.