We need thousands of new homes, but how do we pick the right sites for them? Emma Jones, Manager at Ramboll Environ, and Ben Christian, Senior Planner at Vail Williams, discuss the Local Plans process
Applicants and local authorities regularly face the question of how much time and money to invest into a planning aspiration in order to gain optimal output. Applicants must understand and factor in the cost of drawings, surveys and reports when completing the relevant planning process, while local planning authorities (LPA) must consider the costs of creating Local Plans (LP) to govern decisions.
LPs must be prepared in accordance with the requirements set out in the National Planning Policy Framework (NPPF). The framework identifies the amount and range of work required to evidence a LP and sets out the level of robustness required by the evidence. This article focuses on how best to use limited budgets, and the cost of investigating project deliverables.
Using limited budgets to ensure a robust SA process
Sustainability appraisal/strategic environmental assessment (SA/SEA) has been commonplace for more than 10 years and there are varying views on the effectiveness of the process. Although many of Ramboll’s clients find the process useful, this is certainly not a universal opinion. For example, the Local Plans Expert Group report on LPs states that it is one of the most time-consuming aspects of plan-making and has become a self-serving industry in its own right. While the LPEG’s conclusions are not necessarily correct, there is a case to make that SA is often not as focused on significant issues as it could be. In particular, there are four areas that could arguably be improved:
Scoping
The scoping process is not currently fit for purpose. Large reports are produced and 90% of the information collected is never used. Either the process needs to happen later (possibly at the issues and options assessment stage) or a simpler process (more like EIA scoping) needs to be promoted, or both. In any case, scoping should draw on all of the evidence that has been collected for the plan process, rather than restating it. There is a case for setting a standard scope for Local Plans that authorities may opt into or out of.
Objectives-led approach
A complex system of assessing against objectives has been developed, but this can lead to an inconsistent approach between subjects. A more effective approach could be to have a list of receptors or topics.
Alternatives
Problems can arise if planners feel they need to devise alternatives for every issue. Assessment of alternatives is important but the focus needs to be tighter and we need to get better at integrating SA work with the LPA’s own site selection process.
LPAs have all the knowledge they need to carry out SAs and could do this work in-house with guidance from a consultant if they need it, but they are typically very nervous of legal challenge. More work needs to be done to dispel these fears. As was noted by No5 legal chambers, “provided an LPA instructs professional consultants or officers with sufficient expertise to carry out SEA at all stages, including where necessary an update that is properly consulted upon, even the most sophisticated challenger will struggle to persuade a court to quash the plan on the basis of alleged errors of law in its composition”. However, this is not currently the perception.
The cost of investigating the deliverability of allocated sites
Sites with development potential must be allocated to streamline the planning process towards achieving LP targets. When submitted to the allocations process, the availability and deliverability of sites are assessed by the LPA. This assessment is taken at a high level, with the detail resolved during the planning process.
The Vail Williams Planning consultancy team has observed cases where unsuitable sites have been promoted through Local Plans. For example, a site being identified for development by different departments within the same council, like leisure and planning or waste and planning.
Such cases have created challenges for LPAs to justify the deliverability of LP targets (eg for housing), as applicants of unallocated sites can argue against the deliverability of allocated sites. This makes it more difficult for LPAs to defend their LPs and adds the undue cost of justifying a position against decisions made when the LP was created and accurate information was lacking.
Deliverability is clearly the main question and this can be achieved by building-in flexibility through the provision of buffers, such as allocating more sites and a target requirement. This comes with its own political challenges and, as the NPPF states, “the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence”.
Concluding thoughts
Ultimately, there could be social and environmental costs brought about by inappropriate development because impacts are not necessarily being carefully assessed upfront and effort may not be focused in the correct areas. These costs need to be considered and mitigated by applicants as much as possible using the techniques summarised above.
Emma Jones
Manager
Ramboll Environ
Tel: +44 (0)121 665 4679
Twitter: @ramboll_uk
Ben Christian
Senior Planner
Vail Williams
Tel: +44 (0)23 8082 0900
Twitter: @vailwilliams
