Local Plans Explained

Central Government requires that all Planning Authorities have a Local Plan which must include proposals for meeting the local housing need for a minimum of 15 years. The process is laid down in legislation and comprises several stages involving public consultation by the local authority. When this is at an end, the plan is submitted to the Planning Inspectorate for approval.  They review the proposals and third-party submissions, and conduct a public examination.  If the Local Plan is found ‘sound’, the Local authority adopts the plan and it becomes the main document in controlling development, like housing, in the area.

According to the National Planning Policy Framework (NPPF), plans are ‘sound’ if they are:

• Positively prepared: providing a strategy which as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
• Justified: an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;Effective: deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
• Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, ‘where relevant’.

Not having a Local Plan, or one that is not up-to-date, by dint of other paragraphs in the NPPF, means that any application to develop is almost certain to be approved whether planned or not. Already there is an increase in applications to develop land not identified in the proposed Plans. Some development companies may try and take advantage of there being no up-to-date plans.  These opportunities will cease as and when a plan is adopted by a Local Authority.

Calculating an area’s objectively assessed need (OAN).

In the past each local authority calculated its own housing need but since 2018 the OAN has been narrowly defined in the NPPF and is called the Standard Method.  This has led to a widely held interpretation of soundness test (a); namely, a plan catering for anything less than the Standard Method number, will be rejected at Examination.  The projections for each planning authority are enhanced by a multiplier (the affordability factor) based on the ratio between average earnings and house prices, in the area.  The more expensive the houses the greater the OAN.

The result is an annual figure that applies to each year of the plan. They were last revised in December 2024 and are shown in the table below together with the annual delivery over the last three years.

When viewed over 15 years the unrealistic provenance of the figures is evident; across the West of England the Standard Method asserts that 122,000 new dwellings are required.  Considering that the existing estate numbers approximately 500,000, the demand is set to be one new house for every four existing.  The drive comes from Westminster and is fixated on a figure for England of 300,000 per year, which has survived at least 4 administrations in the UK.  Successive Select Committees of the House of Commons, have sought an explanation as to its provenance, none have been given.

CPRE continues to try and persuade Government that the policy is in error but until the way of calculating the Standard method is changed, dissuading the Councils from basing their plans on the Standard Method will require convincing proof that a plan catering for any lesser number will not be judged unsound.

Building in the Green Belt

Apart from Bristol, our Local Authority areas include much designated as Green Belt and AONB. Additionally, two contain the Severn Flood plain where development is effectively prohibited. Catering for the Standard Number will entail either building in the Green Belt with access to the employment and services of Bristol and Bath, or beyond on green field, in what will be dormitory settlements.

It is a common misconception that the NPPF protects the Green Belt, as it requires that ‘exceptional circumstances’ are necessary for its removal.  Unfortunately, it stops short of defining what they are, and as the courts have confirmed, it is not a difficult obstacle for a developer to overcome.

In December 2019, hearing a High Court challenge to Guildford’s Local Plan which de-allocated three major sites from the town’s green belt, the judge, Sir Duncan Ouseley, concluded that exceptional circumstances applied. Christopher Young QC, who represented one of the developers, added: ‘You don’t need to show that there is a pressing need or an acute need. A council can decide that it wants to meet its housing need so it will put houses in the green belt and that is absolutely fine’.  This is what North Somerset and South Gloucestershire have done and BANES if it has to cater for the Standard Number, is likely to propose.

Can a member of the public influence Local Plans?

Each Local Plan in this area – BANES; North Somerset; Bristol and South Gloucestershire, is in a different state of preparedness and consequently the opportunity to influence the outcome is peculiar to each.  The process starts with a call for sites and then moves through a number of phases under what is known as Regulation 18 during which the Planning Authority publishes its thoughts and invites comment. Whilst under Regulation 18, the local authority can make changes. In the final phase the planning authority publishes its proposals under Regulation 19; six weeks are then allowed for consultation on whether or not the proposals are legal and sound, after which, the un-amended plan and all comments are passed to the Planning Inspectorate who take control, appoint inspectors and set a date for the examination in public.

The most impactful topic is the Standard Method quantum; unfortunately, as explained above in the OAN paragraph, the dilemma for our Unitary Authorities is dare they run the risk of catering for fewer than the Standard Method?  The major developers that control the supply, have frequently been accused of deliberately slowing build out to maintain a sellers’ market. This was noted in the Letwin Report of 2018, but Governments have ignored his conclusion that measures were needed to offset the manipulation of the market; instead, they blame the planning process.  Another requirement is that councils have to demonstrate a five-year supply of housing, and failure results in even more land being zoned for development.  Slow build out exacerbates the problem.

So where are we now?

BRISTOL has a 15 year Local Plan and is the most advanced.  It is being examined under the previous iteration of the NPPF which, in terms of numbers, is more demanding than that which currently applies.  The plan caters for 1,900 dwellings per year, Bristol argued that although this is less than its need it is the maximum that can be built due to the limited area of available land. Bristol has asked its three adjoining authorities to assist in providing the extra dwellings it needs.

SOUTH GLOUCESTERSHIRE has a 15 year Local Plan and consultation is at an advanced stage such that it can be judged under the interim measures laid down in the December 2024 NPPF, which permits a 20% reduction in the Standard Number.  It proposes significant loss of Green Belt land and will be examined in Spring 2026.

NORTH SOMERSET has a 15 year plan currently in Regulation 18 consultation cycle, expected to be published under Regulation 19 in the Autumn, submitted to the Planning Inspectorate towards the year end and examined in Summer 2026. It proposes to cater for the Standard Number and build extensively in the Green Belt.

BATH AND NORTH EAST SOMERSET are working on an 18 year plan.  It is the least advanced in preparation and in Regulation 18, the number of dwellings and the locations have yet to be decided.  The Council citing the unique circumstances of Bath’s World Heritage status, have written to the Secretary of State seeking exemption from the Standard Method.  If they are not successful, development on this scale will either lead to loss of Green Belt or development remote from services and existing infrastructure.

To summarise…

Government legislation and the new requirements to build 1.5 million new homes within four years is putting great pressure on local communities and the Planning Inspectorate.  CPRE will continue to argue to protect Green Belt sites, where possible and question the numbers and the method by which the need for housing has been arrived at.

We need changes to the Planning and Infrastructure Bill to maintain local planning influence and remove the five year supply imposition that currently can negate a legitimate plan. CPRE is also gathering evidence for input to the Planning Reform Working Paper; we want to speed up build out, penalizing land banking and no extension of the planning exemptions based on a site’s threshold.  CPRE continues to lobby the Government and individual Members of Parliament on these documents and encourage individual members to contact their MPs in support.

Locally, CPRE Avon and Bristol appreciates the dilemma facing local planning authorities and continues to engage with them to mitigate the damage.  We have an interest and view on where to develop to cause the least harm and make the best use of existing infrastructure, appropriate housing densities and the percentage of affordable houses. These topics are mostly independent of central government and therefore within the remit of Local Councillors and Officers.