The national planning framework is to be reopened four years ahead of schedule, in response to population change that ministers have described as “materially different from the evidence base”.
The existing framework sets the strategic direction that every local development plan must align with. Those plans run on a ten-year cycle. Nineteen of the thirty-two authorities are mid-cycle, and four adopted their plans in the last eighteen months at a combined cost of £31m.
What councils have been told
Guidance issued alongside the announcement instructs authorities to continue applying the current framework until its replacement is adopted, while also taking “reasonable account of emerging policy direction”.
Planning officers have pointed out that the emerging policy direction has not been written, and that applying it is therefore difficult in the way that applying a blank page is difficult.
“I have to determine an application on Thursday against a plan that is being replaced, using a framework that does not exist, and defend it at appeal in two years against whichever of the two is by then in force.”
A development management officer in a Highland authority
The appeal risk
The practical consequence is arriving already. Applicants refused under the current plan are appealing on the basis that the framework it derives from has been publicly declared out of date by the government that made it.
Reporters have upheld four such appeals since April. Councils have no obvious defence, because the premise is broadly true.
The position
- Framework reopened: 4 years early
- Local plans mid-cycle: 19 of 32
- Adopted in the last 18 months: 4, at a combined £31m
- Expected adoption of the replacement: 2029
- Period in which both documents are arguably in force: approximately 3 years
Nobody thinks the review is wrong
It should be said that almost nobody in the profession opposes reopening it. The evidence base genuinely is out of date, and continuing to allocate housing on 2019 projections in districts that have grown 40% since would be worse.
The objection is to the interval. For three years, thirty-two authorities will determine applications against a document everyone agrees is wrong, and no mechanism exists to bridge that.
One officer summarised the guidance more briefly than the guidance does: “The plan has changed. The plan we have has not.”
