The plan-making policies

Chapter 2 sets out the government's commitment to the plan-led approach as the foundation of the planning system, arguing that up-to-date local plans are the best means by which communities can shape development, protect the environment and deliver housing.

It signals ongoing legislative reforms to accelerate plan production and improve cross-boundary planning, and explains that the chapter is structured around three areas:

1. Role of each type of plan.
2. Process of preparing plans.
3. Approach to examining them.

Spatial development strategies

Policy PM1 introduces spatial development strategies as high-level documents focused on strategic, cross-boundary issues, leaving detailed policy to other plan types. 

It covers their role, content and relationship to the wider development plan hierarchy, as well as when they should be updated. The government notes it is particularly keen to receive views on this policy, as it has not previously consulted on it.

Question 6: Do you agree with the role, purpose and content of spatial development strategies (SDSs) set out in policy PM1?

Strongly agree with the role, purpose and content of SDSs. However, we have concerns regarding the areas that will be covered as to whether they’ll be large enough to be genuinely strategic. 

It will either apply in a mayoral combined authority area or, as a minimum, it could apply just to one unitary authority. A city council may only have a SDS for its own area rather than neighbouring local authorities, which are often part of the city conurbation. However, we recognise that this situation will evolve with the proposals for local government organisation. 

SDSs should also set out the contributions, in broad terms, expected from developers towards strategic infrastructure. This will further manage expectations and aligns with proposed policy DM5 that assumes proposals that accord with up-to-date plan policies will be assumed to be viable. 

Question 7: Do you agree that alterations should be made to SDSs at least every five years to reflect any changes to housing requirements for the local planning authorities in the strategy area?

The idea of the SDS is to provide a long-term vision. There needs to be some certainty with this document, especially considering the huge resource burden involved with updating local plans. 

We agree with suggestion in A) because more frequent changes will be an unnecessary drain on resource and wouldn’t alter the strategic purpose of the plan. 

Question 8: If spatial development strategies are not altered every five years, should related policy on the requirements used in five year housing land supply and housing delivery test policies be updated to allow housing requirement figures from SDSs to continue to be applied after five years, so long as there has not been a significant change in that area’s local housing need?

Agree on the basis that these plans don’t need to be micromanaged and are there to provide a broader strategic purpose, provided the initial targets are set an appropriate level, regularly changing the underlying assumptions in relation to housing targets and five-year housing supply creates uncertainty and cost risk for developers. It’s important that planning moves away from being overly bureaucratic and focuses on delivery.

Local plans

Policy PM2 sets out the role of local plans in guiding development and environmental improvement at a local level, including their required content and their relationship to spatial development strategies. 

It establishes a 30-month target for adoption and a requirement to commence the next plan within five years. Early revision may be triggered in certain circumstances, such as a significantly higher housing requirement arising from a new spatial development strategy. 

The policy currently requires plans to cover at least 15 years from adoption, though the government is consulting on whether a minimum 10-year period may be more appropriate given the expectation of faster and more frequent plan production.

Question 9: Do you agree with the role, purpose and content of local plans set out in policy PM2?

Agree. Local plans are essential as they set out the details that developers need to make informed decisions as to where exactly development should be brought forward and in what form. They also allow planning officers to make co-ordinated decisions and allow for forward planning of necessary infrastructure. 

Question 10: Do you think that local plans should cover a period of at least 15 years from the point of adoption of the plan? 

Local plans shouldn’t be made unnecessarily difficult to approve and therefore a shorter period should be allowed, especially if this enables a plan to be made more easily. It’s noted that a longer-term vision exceeding 10-15 years is contained within the SDS, which should therefore support the certainty required for everyone involved in development. In our view, a period of at least 10 years would be sensible, albeit with some encouragement for plan making authorities to plan for a long-term period that aligns with the SDS for that area, where possible. This will help facilitate the alignment of local plans and SDSs, whilst allowing some flexibility for local plan delivery where there are local challenges in preparing an local plan for a longer period. 

In respect of Policy PM5, we would recommend that it be made clear that neighbourhood plans do not conflict with local plans or SDS policies and should be focused on housing and infrastructure delivery at a neighbourhood level and not used to frustrate development that otherwise aligns with local planpolicies. 

General principles for plan-making 

Policy PM6 replaces paragraph 16 of the current NPPF, setting general principles for all plan types: relevance, environmental assessment where required, stakeholder engagement, accessible formats, and compliance with data standards. 

Plans must not replicate national decision-making policies unless directed to do so, a principle reinforced through the examination process and forming part of the tests of soundness for relevant plan types.

Question 11: Do you agree with the principles set out in policy PM6(1c), including its provisions for preventing duplication of national decision-making policies? 

Strongly agree that local plans not duplicating national policies is in everyone’s interest. Multiple variations of essentially the same policy are unhelpful. We have worked with local authorities and the Welsh Government in relation to the planning system in Wales and find the system of national policies to be well understood and effective. 

Identifying land for development

Policy PM9 requires development plans to be informed by an assessment of land available to meet development needs. For plans that allocate specific sites, such as local plans, it establishes procedural principles for identifying, assessing and selecting sites, with the aim of making that process faster, more consistent and more transparent.

Question 14: Do you agree with the approach to identifying land for development in PM9? 

Strongly agree. One of the key purposes of local plans is the identification of potential land for development. The sites need to be suitable, viable and potentially with at least some prospect of being forward for development. 

Sufficient sites need to be allocated to both give options for developers and make it easier for planners to grant sufficient planning consents to allow their housing targets to be met. 

We would also welcome emphasis being placed on allocated sites being represented clearly on a map at the front and centre of the local plan, not buried behind lots of policy wording. Local plans should be more visual and easily understood by developers, planners and members of the public alike. 

Maintaining and demonstrating cooperation between plan-making authorities

Policies PM10 and PM11 replace the current NPPF’s provisions on effective co-operation, strengthening expectations for proactive engagement between authorities on cross-boundary issues. 

Key changes include clearer duties to engage, alignment with the new spatial development strategies system (avoiding duplication where issues have already been addressed at that level), and more explicit requirements to demonstrate co-operation through statements of common ground. 

Question 15: Do you agree with the policies on maintaining and demonstrating crossboundary cooperation set out in policy PM10 and policy PM11? 

Partly agree. It’s important that planning isn’t limited to arbitrary local authority boundaries until a more holistic longer-term approach is taken. It’s for this reason that SDS are so important. However, there have been examples in the past year of these principles being used to block the approval of what would otherwise be a sound local plan. 

Accordingly, it’s important that local authorities remain in control of their own destiny when it comes to setting their own local plan. The plan-making process is inevitably highly political and it’s important the co-operation requirements don’t lead to avoidable delays. 

There should also be greater clarity regarding the benefits to one local authority that meets unmet need from another neighbouring area. The incentive to work together on this is currently relatively low and taking on additional unmet need is always likely to be highly controversial within one local area. A one-sided duty has the potential for significant delays.