The Local Plans Expert Group (LPEG) is reviewing ways to speed up and simplify the local plan process in England. Some of the key issues they identified include a lack of clarity around calculating housing need, lengthy and complex local plans and evidence bases, difficulties cooperating across boundaries, and challenges ensuring timely plan preparation and housing delivery. The LPEG is considering recommendations to address these issues through measures such as clearer guidance on assessing housing need, streamlining plan content, improving joint working on strategic issues, and enhancing plan implementation.

1. THE WORK OF THE LOCAL PLANS
EXPERT GROUP (LPEG)
PINS ANNUAL STAKEHOLDER CONFERENCE
8 March, 2016
DEREK STEBBING - LPEG MEMBER

2. TERMS OF REFERENCE
• Review the content of Local Plans and supporting evidence
• Consider measures to speed up and simplify the setting of housing numbers
• Examine whether there are advantages in alternative approaches
for settling strategic and cross-boundary issues
• Consider whether ‘tests of soundness’ should be reformed
• Consider at a high level the way in which local plans address the link between
development and infrastructure
• Look at whether there are unnecessary or excessive procedural requirements
• Consider best practice or other mechanisms which could help to ensure the
timely preparation of plans
• Suggest template Plan policies which could be included in plans to avoid
duplication of effort

3. ADDRESSING THE PROBLEMS
• Call for Evidence – over 160 submissions from all sectors,
including members of the public
• Direct engagement with key stakeholders, e.g. PINS, HBF
• Questionnaire to cross-section of local authorities
• Identify good practice and exemplars
• Focus on key workstreams – e.g. OAN, Process, Content,
Implementation, Accessibility - with specialist assistance from a
small team of advisors
• Identifying potential solutions and Recommendations

4. LPEG believes that :
• only 25% of LPAs have a sound, post-NPPF Local Plan, of which only half
contain site allocations
 33% of ongoing Examinations have been suspended, sometimes for a year
 post-NPPF plans provide an average of 15% less than OAN and little or no
‘overspill’
 Plans are slowing down and taking longer to prepare and Examine
CURRENT POSITION

5. LPEG believes that the following major issues are impacting on the preparation of
Local Plans :-
 lack of clarity - particularly OAN, SHMA, etc.
 lack of support - resources, central support, exemplars
 Duty to Co-operate
 too many changes - continually going back to square one
 lack of compulsion - it is easier not to plan
THE MAJOR ISSUES

6.  Housing Market Areas – no definitive list
 SHMAs – no definitive guidance, disputed best practice and alleged lack of
consistency
 Kate Barker - SHMAs are too long, unclear, out of date, political, gamed and
inconsistent
 Savills - only 54% of LPAs have a SHMA produced post-March 2012
 Disincentives to produce SHMAs
STRATEGIC HOUSING MARKET
ASSESSMENTS (SHMAs)

7. ISSUES WITH PLAN-MAKING
• Plans are getting longer
• Plans are taking longer to progress through the Examination stage to
adoption
• There is no single definitive guide for plan-makers
• There is no mandatory, or even advisory, timetable for Plan preparation
• Many plans repeat NPPF policy guidance
• Evidence base work is often over-engineered, with SA/SEA work being a
particular issue – resourcing issues (££) for local authorities
• Much of the work has become obscure and inaccessible to
communities – many web-sites are almost impenetrable to the public
• Communities feel disengaged

9. LOCAL PLAN HOUSING
TARGETS AS A
PERCENTAGE OF
HOUSEHOLD
PROJECTIONS

10. AFFORDABILITY
OF HOUSING,
2013

11. CALCULATING OAN - 1
• Identified in our Call for Evidence as the biggest factor in delaying plan
preparation
• It is a NPPF requirement (para. 159) to prepare a SHMA to assess full
housing needs, working with neighbouring authorities where HMAs cross
administrative boundaries
• But, no pre-set definition of HMAs or definitive guidance on the way in
which to prepare a SHMA
• Lack of boundary co-ordination with LEPs, County Councils, Health
Authorities, etc.
• Kate Barker – Hertfordshire : 10 authorities drawing their housing needs
assessments from different SHMAs with different approaches to the
adjustments in the Guidance, e.g. market signals

12. CALCULATING OAN – 2
We have looked in detail at how this process could be rationalised and simplified, to
bring greater clarity :-
• clarity on data sources, e.g. which set of household projections
• clarity on whether or not employment forecasts should be considered, which are
notoriously unreliable
• clarity on the approach to be taken with market signals adjustments
• clarity on adjustments to address affordable housing needs

13. LOCAL PLAN CONTENT
• We have sought to understand why plans have been getting longer, and
whether there is scope to reduce their content.
• But, without compromising the purpose of a Local Plan to “provide a
framework within which local people ….can produce their own distinctive
local and neighbourhood plans, which reflect the needs and priorities of their
communities” .
• We have considered how Local Plans can be re-focused on the strategic
priorities set for them in the NPPF, allowing Neighbourhood Plans or other
Local Plan documents to deal with more detailed issues.
• Can smaller-scale site allocations be “devolved” to other Local Plan
documents and Neighbourhood Plans ?
• A concise suite of Development Management policies

14. WORKING ACROSS BOUNDARIES
• The Duty to Co-operate is not providing a mechanism for dealing with
strategic requirements across local authority areas
• Unmet housing need is not being addressed, e.g. Brighton and Hove =
17,000 homes
• Needs a new approach to joint strategic planning across HMAs or other
suitable geography, to address housing, economic and infrastructure
requirements

15. LOCAL PLAN PROCESS
• We have undertaken a thorough review of each stage of the
Local Plan making process
• Current Local Plan Regulations do not allow a local authority to
amend a plan after Reg. 19 (Pre-Submission) consultation –
leading to lengthier Examinations and additional work for PINS
• Reg. 18 (Issues & Options and Preferred Options) is not well
formed – it requires only the notification of certain specified
bodies that a plan is in preparation, and does not frontload
community engagement at the initial stages of plan preparation
• There is no timetable for the different stages of plan
preparation

16. IMPLEMENTATION AND DELIVERY
Issues
• The identification of land for housing is a key requirement of Local Plans
• Local authorities need to demonstrate a five year supply of land for housing
(although the NPPF requirement in para. 47 does not apply specifically to Local
Plans)
• Debate over the five year supply of housing land is taking up significant amounts
of time at Examinations and Appeals – with adverse impacts on delivery
• The data is often out of date almost as soon as a Plan is adopted
We have explored :-
• how to establish a more effective and resilient approach to housing land supply in
Local Plans
• the potential role for Authority Monitoring Reports in identifying the five year
supply of land

17. PRESENTATION, ACCESS AND STYLE
Kate Barker on Hertfordshire Local Plans
“An initial observation is that the local plan itself is not that prominent on most
of the websites and nor is it always crystal clear what the latest state of play is”
We have explored :-
• Better use of visual material and graphic presentation, particularly in areas
where change is envisaged – such as “propositional planning” approaches
• Improved on-line presence
• A “Three Click Test”
• Improved formatting of documents
• Interactive mapping

18. NEXT STEPS
• Recommendations now being formulated
• Final Report to be drafted
• Timetable for publication not yet confirmed