Local Plans - the impossible dream - 12 weeks of Planning (episode 2)

By Paddy Kent, Account Director at Newington Communications

Each week during the 12 week consultation, the Newington team will be analysing an aspect of the proposals in the ‘Planning for the Future’ proposals. 

Read our latest analysis below to understand how the proposed planning changes will affect your future projects.

Following on from our initial analysis of the Planning White Paper last week, Newington will be taking each of the next 11 weeks (the consultation period) to consider an aspect of the Planning for the Future proposals in more detail. 
 
As we know, the Government proposes that Local Plans designate areas for Growth, Renewal and Protection.

They want these Local Plans to be produced within 30 months with a clear timetable for councils to follow. Maps not words are the fashion, which is why the government reckons the average plan's content will be reduced by two-thirds.
 
So Local Plans need to be shorter and faster. Sounds good! Without the changes, Local Plans apparently typically take seven years. The government has even broken down the timetable into baby steps, so the children can keep themselves on track. That would be quite an ask in itself, but they also make two more significant asks, with consequences for authorities, developers and the public.

Firstly, as the areas marked for Growth will automatically have outline consent granted upon the LPs’ adoption, the LPs must include masterplans. So even promoting a site within a LP looks like it will now require a masterplan - SUDS, LEAPs and LVIA. You name it. Employment forecasting, environmental impact assessments, traffic modelling. That’s going to be a lot of work for developers and officers are surely going to be deluged, but this time, with tight deadlines to work to.

The second ask follows as a consequence of the first. With outline consent now the reward for an allocated growth site, the government is stating that Local Plans include much more community consultation. Within the government’s 30-month timetable (summarised below) you can see where they think the consultation will occur:

Stage 1 (6 months):  
First consultation – where growth should go.

Stage 2 (12 months): 
Officers produce plan.

Stage 3 (6 weeks):   
Second consultation – public can comment on draft plan.

Stage 4 (9 months):   
Inspector refers plan and considers public comments.

Stage 5 (6 weeks):     
Plan finalised.

 
A 6-week expectation at Stage 5 looks the most questionable of this timetable, but that’s a discussion for another time. The government has said that comments at Stage 3 must focus on how the plan should change and why. This will mean that all representations at this stage have a razor sharp focus (in theory!). Remember though this is the point where the public could be asked to comment on (say) 10 proposed masterplans of 1,000 homes each, granting outline consent without further consultation. Is allowing just six weeks at Stage 3 enough time? Residents associations and stakeholders are certainly going to have to be on their game.
 
I want to make a slightly off-piste comment about one change we’ll see if these changes come off. Site capacities are likely to become ‘fixed’ at a much earlier stage. If we think about how the current system leads to masterplaning, at LP stage concept plans are drawn up with indicative capacities. Once adopted, developers then draw up a masterplan and submit an application for outline or full permission. Things can get tricky when this planning application doubles the number of homes in the site allocation. I've helped many developers explain this in a variety of ways but we are all familiar with the cries of ‘greed’ from local newspapers. As masterplans would be required when promoting sites and outline consent granted to those that are successful, this might give developers less room for manoeuvre, but may be positive for the public perception of the industry.  Although of course, I can’t see that under the new system (as now), developers would be prohibited from submitting new outline or full applications that could increase capacity, but doing so might become politically more challenging.
 
Back to the issue of shorter, faster and more consultative plans - it’s actually only at that first stage that consultation can occur that genuinely seeks views from the community on growth and development in their area. Is six months adequate? Well yes, actually, I think it’s a big window of time, but especially with digital tools, a lot can be done. Here at Newington the vast majority of our work is for developers, but I’d like to think that if we were tasked with designing and running a six month engagement programme seeking views of the public, businesses and stakeholders on the next Local Plan, we’d be up to it. And we’d do a great job!
 
I asked at the start whether the government’s ambition for smaller, faster yet more consultative Local plans was impossible. Not at all - it’s possible. Developers are going to need to develop masterplans sooner, and as I’ve mentioned above, just one effect of this will be to establish capacity at an earlier stage. This will also impact the land acquisition and options process, as the allocations phase will become much more expensive and riskier - will this reduce the competition for sites (and the developers who are going to wager larger sums on the allocation gamble) or will it just reduce the number of sites submitted to the LP process?

But the real challenge will be for local authorities to provide the resourcing to process, analyse and respond to developers’ submissions of masterplans, not to mention meaningfully processing the volume of feedback they’ll receive.
 
If these proposals come true, things are about to get seriously shaken up!

You can catch up with previous weeks here:

Week 1 - Phil Briscoe reviews the Planning White Paper