How the government’s planning reforms have ushered in a new age of plan making?
In the first of this 3-part series we will discuss the main principles of plan making, the effect on plan making of recent changes to the planning system and look at the first part of the plan making process, the evidence gathering stage, which normally includes a ‘Call for Sites’ process. We will also examine which local planning authorities within our region are at this stage and how you can promote your site in these early stages.
The planning system in England is “plan-led”, means that local plan and other planning policies should provide the starting point for planning decisions and that sites that are not ‘allocated’ for development (for example housing or commercial development) should not be developed. This provides for a high degree of joined up thinking as well as local democratic accountability and influence. Or so the theory goes. However, plan making is notoriously long winded and challenging in this country and, as a result, many local authorities do not have an up to date Local Plan, leaving the door open for ‘speculative’ applications. The reasons for this are numerous, many related to politics, either at the national level (where the goalposts are constantly moving, particularly when there is a change of government) or at the local level due to changes in the political make-up (and priorities) of councils and councillors.
Nationally, the Labour government elected in July 2024 has adopted a very growth driven agenda over the last 14 months, much of it based on the ambitious aim of building 1.5 million new homes during this parliament. In this regard, there is now a requirement for local authorities to use a standard housing need methodology to inform their housing requirement and the December 2024 National Planning Policy Framework (NPPF) removed the exceptional circumstances justification which allowed many local authorities to adjust their housing calculations downwards. This has led to many local authorities, particularly in rural areas, facing a sudden hike in housing targets, with increases of 60-70% (and sometimes more) not uncommon. There was, however, some relief for local authorities which were part way through the plan making process by March 2025, whereby if a draft plan had reached an advanced (Regulation 19) stage or had been submitted for examination by this date, it would be examined under the provisions of the previous, and generally less onerous, (December 2023) version of the NPPF. These measures are to incentivise plan making and help address the delays, which have affected many authorities in preparing new development plans and they certainly appear to have had the desired effect judging by the amount of plan making work currently going on.
The contents of a Local Plan can vary massively depending on the location, demographics and particular characteristics of an area but in the broadest sense, all plans should provide a vision and framework for future development of an area encompassing housing, the economy, community facilities and infrastructure. Key questions include: How much housing and employment land do we need?; are there any key community facilities and infrastructure requirements?; will it be a ‘Pro-development’ or ‘preserve what we have’ type of plan?; and will there be significant Green Belt development?
First steps
Adopting a Local Plan is a lengthy process which typically takes around 2-3 years from start to finish. According to the gov.uk Planning Practice Guidance (PPG), “…This involves gathering evidence, carrying out a Sustainability Appraisal to inform the preparation of local plans and effective engagement and consultation with local communities, businesses and other interested parties.” A key part of gathering evidence is the Call for Sites exercise. This is an opportunity for any landowner to put their site forward for potential development, to ‘throw their hat into the ring’.
A good Call for Sites submission will typically include the following:
- Site location plan;
- Indicative site plan showing in broad terms how the site might be developed;
- A covering letter or statement extolling the virtues of the site and assessing its suitability against key planning issues such as sustainability of location, impact on neighbouring land uses, landscape impact, highway safety, impact on ecology etc;
- How development of the site would help in meeting the council’s identified needs for housing, employment or community needs.
The council will publish the results of the Call for Sites process in a Strategic Housing Land Availability Assessment (SHLAA) or Strategic Housing and Economic Land Availability Assessment (SHELAA) and should also include a reappraisal of the suitability of previously allocated land. A number of local councils within our region are currently carrying out Call for Sites exercises including the following:
- High Peak Borough Council – Call for Sites currently live, no published deadline
- Derby City Council – Call for Sites completed in 2023/24 but may still be an opportunity to put forward a potential site for development
- Cheshire East Council – Call for Sites completed in July 2024, there will be a further call for sites exercise in the near future
- Staffordshire Moorlands District Council – Call for Sites currently live, no published deadline
- Ashfield District Council – Call for Sites currently live, no published deadline
- East Riding of Yorkshire Council – Call for Sites currently live until 21st November 2025
- North Yorkshire Council – Call for Sites currently live until 30th November 2025
I am often asked the question ‘what are the chances of my site being allocated for development’? Clearly, a lot depends on the location and characteristics of the site itself but the importance of promoting a site should not be underestimated. It shows that a site is available (a key component in any assessment) and allows the landowner to address any potential issues at an early stage, thus putting the site ahead of potential competitor sites where question marks may still remain unanswered. Furthermore, in the current climate where there is an acute need for more housing land in most authorities, even sites which have been rejected in the past (including green belt sites where the new ‘grey belt’ designation may apply) may now be looked upon more favourably. So the message is simple – there may never be a better time to put your site forward for development.
Next month, we will be looking at the formal stages of the plan making process and some of the issues faced by the planning authorities trying to adopt plans in our region and what it all means both for landowners and those considering speculative applications.
Richard Pigott, Director, Chartered Town Planner, Planning & Design Practice Ltd
