LOCAL PLAN SIMPLIFICATION CONSULTATION RESPONSE FROM THE HOUSING FORUM

The Housing Forum has responded to the Government’s consultation on the way in which local authorities make Local Plans. Our membership base across the entire of the housing sector sees the benefit of Local Plans and we support the Government’s efforts to make the plan-making process simpler and faster. The move to greater standardisation where practical is welcomed.

We also welcome the ambition of improving engagement in the plan-making process, and the use of digital tools to assist this. Local communities need support to recognise the value in engaging at this early stage, creating a smoother process downstream of granting applications that are in line with the Local Plan.

We have also raised some concerns that we feel the Government needs to address to realise its ambitions:

– Firstly, it is vital that the current situation where only a minority of local authorities have an up to date adopted plan is addressed. This has happened in a situation of chronic under-funding of local authorities and lack of incentives to bring forward plans. The reforms to NPPF which were proposed in December 2022 were expected in ‘spring 2023’ but have not yet been published. This is left local authorities in greenbelt areas, or where there is political division over new housebuilding numbers stuck and unable to progress because they are waiting for clarity. It is vital that the move to a new system of plan-making recognises this reality and does not exacerbate it by creating an additional incentive to stall.

– Secondly, the Government needs to assess and addresses the costs of Local Plans. Currently, it averages between £6 million to £7 million to produce a Local Plan, and these costs are escalating due to skill and capacity shortages in the professional and specialist fields contributing to the Local Plan. In the current financial climate, producing a Local Plan can become seen as a luxury. Removing the requirement for Local Planning Authorities (LPAs) to pay the Planning Inspectorate’s costs in reviewing local plans (and increasing the Inspectorate’s resources to match) would create better incentives to bring forward Local Plans as well as helping alleviate pressure on local authority finances.

– We are concerned that we are being asked to comment on proposals for greater use of standardised templates, when the details have not yet been published. It is vital to get the distinction between national and local policies right.

– Finally, we are concerned with the suggestion that LPAs with an up to date Local Plan could no longer have to demonstrate a 5 year land supply. This could reduce the supply of land coming forward for much-needed new housing, because there is no mechanism to ensure that the delivery of housing is matching the plan. We have suggested some alternative ways to incentivise Local Plans being up to date.