Consultation outcome

Government response to the proposed plan-making reforms: consultation on implementation

Updated 27 February 2025

Introduction

1. The consultation set out the previous government’s proposals and direction of travel for the implementation of certain key aspects of a new plan-making system. It sought views on our proposals to implement parts of the Levelling-up and Regeneration Act 2023 (“LURA”) which relate to plan-making, to make local plans and minerals and waste plans simpler, faster to prepare and more accessible.

2. Sustained economic growth is central to the government’s Plan for Change. It is the only way to increase the prosperity of our country and improve the living standards of working people. Reform is critical to delivering this growth and nowhere is it needed more urgently than in our planning system.

3. Alongside amending the National Planning Policy Framework, this government is committed to universal, ambitious local plan coverage. Local plans spell out where development will and will not take place and are the primary means for ensuring communities are able to shape development in their areas, bringing certainty to all users of the planning system. However, currently fewer than one third of local planning authorities have an up-to-date local plan in place. The government remains committed to introducing a new, faster and clearer process for preparing plans. This will be essential to deliver and maintain universal plan coverage across England, supporting the government’s wider commitments to deliver the development the country needs.

4. This response sets out how the government intends to proceed with the proposals included in the previous consultation, to implement the new plan-making system, as provided for by the LURA. Our approach has been shaped by the detailed feedback received through the previous consultation, which was published by the previous government on 25 July 2023, and the priorities and commitments made by this government. This update sets out a response to each of the 43 questions posed in that consultation.

5. The government published a consultation on the National Planning Policy Framework and other changes to the planning system on 30 July 2024.[footnote 1] This response should be read alongside the government’s response to that consultation[footnote 2], which sets out the government’s approach to revising the National Planning Policy Framework to achieve sustainable growth in our planning system. This includes changes to how local planning authorities plan for homes through local plans; a revised approach to releasing land for development; and policy changes to support more effective co-operation on cross boundary and strategic planning matters. Additionally, and of relevance to this update, it provides further clarity of key timings for rolling out the new plan-making system and updates the position on the wider rollout of Spatial Development Strategies across England.

Overview of consultation responses

6. The consultation was published on GOV.UK and open for 12 weeks from 25 July to 18 October 2023. Responses were accepted through an online survey, by email and by written correspondence.

7. The consultation received 490 responses. The table below provides a breakdown of the general consultation responses by type of respondent (Table 1).

Type of respondent Number of responses from each category
Developer 26
Interest group or voluntary organisation 40
Local Planning Authority 207
Neighbourhood Planning Body, Parish or Town Council 26
Other (please specify)* 44
Other private sector organisation 34
Personal view 88
Professional body 25
TOTAL 490

Table 1: Consultation responses by type of respondent

8. This update summarises the responses received. It does not attempt to capture every point made, nor does it address comments on aspects of policy that fall outside the scope of the consultation. It sets out how the government intends to move forward with the proposals and sets out changes the government has made in response to the points raised in the consultation, explaining why suggested changes have been incorporated.

9. We have provided a statistical summary of respondents for each question. However, not all of the questions we asked were in short answer format so the statistical analysis for these has not been provided. For the purposes of the statistical summary of responses to each question, respondents that did not provide an answer to a short form question have been excluded, but any written comments were considered as part of the overall summarisation.

10. In finalising its policies, as set out in this response, the government has had regard to its responsibilities under the Equality Act 2010 and the Environment Act 2021.

Chapter 1: Plan content

Question 1: Do you agree with the core principles for plan content? Do you think there are other principles that could be included?

11. A total of 312 respondents answered this question. Of those, 246 (79%) agreed with the proposals, 20 (6%) did not agree and 46 (15%) were indifferent. This indicates strong support for the proposal.

Key points:

  • There was broad support for plans to be simpler, more accessible, and visual, together with the increased digitalisation of plans.
  • Amongst those who supported the proposals, there was broad consensus around establishing sustainability as a ‘golden thread’ throughout plans, albeit some felt this was already a key element of the current plan-making system.
  • Some considered that the core principles should go further or put forward additional core principles, suggesting that environmental and social sustainability should be given greater prominence. Some suggested more specific consideration of climate change adaption and mitigation; net zero; carbon budgets; circular economy principles; and reuse and refurbishment of existing buildings. A number of respondents also suggested the addition of health as a core principle, noting the importance of health inequalities, wellbeing and the provision of green infrastructure. Others suggested a specific core principle around the importance of public consultation and engagement, including the relationship with neighbourhood plans.
  • A few respondents disagreed with the concept of core principles, expressing concern that they might not allow for local distinctiveness and represented a ‘one size fits all’ approach to plan-making.
  • Respondents generally agreed with the principle of digitalisation (digital and interactive local plans and policies maps), highlighting the perceived benefits. However, some planning authorities expressed concerns over the potential costs associated with developing systems and tools that could deliver this, noting that this may require investment and coordination from government to ensure consistency. A lack of resources and technical skills within the local government sector were noted as another barrier to building and maintaining digital tools and/or services.

Government response

12. The government proposed that new-style local plans and minerals and waste plans should be simpler, shorter, and more visual. They should have a greater focus on locally specific matters, so users can engage more easily with them and understand what is planned in local areas. The LURA sets out clear parameters for the content of a new-style local plan. In support of this approach, we proposed to set out through policy, and supported by guidance, a series of core principles around the content that plans should contain. The intention was to ensure plans are focused on the right things and users are able to understand clearly the ‘story’ of how the planning authority’s area will develop.

13. Noting the strong support for the proposals to establish core principles to give greater clarity to plan-makers, and the general support for most of the principles themselves, the government intends to proceed with the proposal to establish clearer principles for the preparation of plans in national policy and guidance. In continuing to refine the principles, we will explore how to successfully embed clear principles for the preparation of plans into national policy without creating unnecessary duplication, noting comments raised about the overlap with existing policies (for example, sustainability).

14. To provide greater clarity, we will also set out, in guidance, further detail for the expectations of plan-makers in the preparation and presentation of key “components” of plans described in the principles, such as the key diagram, spatial strategy or site allocations. Noting the feedback received through the consultation and recognising the need for local plans to be locally responsive, the focus of such guidance will be on helping plan-makers to progress plans more quickly and with greater confidence, without being overly prescriptive or restrictive.

15. Additionally, we intend to make changes to the focus of some of the principles to reflect feedback received through the consultation and more closely align with key changes to the National Planning Policy Framework. For example, we will replace the reference to “beautiful places” with “well designed places”. We will also continue to explore whether, through the principles, greater emphasis should be given to the role of plans in adapting to and mitigating climate change (beyond the existing requirement established in the LURA), and promoting healthy communities, linked to the recent consultation on changes to the National Planning Policy Framework. Any further changes to national policies to enable this would be subject to further consultation.

Question 2: Do you agree that plans should contain a vision, and with our proposed principles for preparing the vision? Do you think there are other principles that could be included?

16. A total of 311 respondents answered this question. Of those, 266 (86%) agreed with the above proposal, 11 (4%) did not agree and 34 (11%) were indifferent. This indicates strong support for the proposal.

Key Points:

  • There was much broad agreement with the rationale for the proposals, especially amongst planning authority respondents, who also recognised the main challenges identified with visions in the current system. Many felt that the proposals closely reflected existing best practice in plan-making, indicating a strong case for embedding them more formally into the new plan-making system.
  • There was much support for templates for visions, with those supporting highlighting that these should not be prescribed too tightly, to enable visions to respond to local circumstances. The focus on community engagement was also welcomed, although some felt that other themes should be acknowledged as part of the principles for vision preparation, including health and wellbeing, and promoting biodiversity.
  • There was support for visions to contain measurable outcomes. Some went further to suggest that these should be based on SMART objectives.
  • There was support for links to other strategies, however there was some concern around encouraging links to other corporate strategies, particularly where the local plan period would not align with those strategies. Some also highlighted the potential for conflict with the expressed aim for visions to be community-led.
  • Despite the strong support in general, some highlighted the risk of misalignment between locally distinct visions and the aims of national policy. Some others identified the risk of locally prepared visions simply repeating national policies, given the emphasis of their intended content.
  • Furthermore, some respondents highlighted that it may be difficult to represent all aspects of a vision on a map or a key diagram. Therefore, there was concern that non-spatial elements of a vision could be excluded or deprioritised.

Government response

17. The government recognises that visions are already a core component of plans in the current system. Whilst they can be an important means of setting wider context and detailing the planning authority’s key aims and priorities, there is broad recognition that they tend to be too long, generic and high level, and do not sufficiently capture the uniqueness of the places they describe or the views of the communities that they serve.

18. Recognising their potential as a tool to give communities a much stronger voice in the plan-making process, the consultation proposed strengthening the role of local plan visions, ensuring they are more focused and specific than those in the current system. They should be genuinely shaped by the views of communities on how their place should evolve, and be informed by baseline information and inputs from other stakeholders garnered through early participation. We proposed to use regulations to require the inclusion of a vision within a local plan, and proposed a series of principles which would underpin their preparation.

19. Given the strong support for the proposals consulted on, the government will legislate to require a vision to be included in plans. It will also set out some clear principles in policy which planning authorities will need to have regard to when preparing a vision, drawing on the feedback received. With the positive feedback for visions to be anchored in measurable outcomes, and given this is key to creating tangible and locally specific visions that can be monitored, we will strengthen the requirement in regulations that visions are supported by no more than ten measurable outcomes.

20. Noting the considerable feedback around templates, we will work with the sector to prepare guidance to support planning authorities with drafting concise, locally specific, and measurable visions, incorporating a flexible template that can respond to local circumstances. We intend that this guidance will outline the purpose and benefits of having a distinct local vision, and set out how planning authorities can capture the views and needs of the community through early engagement, as a key input into the vision. Effective visions will support plans to achieve high quality development in line with the overarching aims of the planning reforms, with measurable outcomes that are locally specific.

21. Noting the challenges identified with including links to wider corporate strategies, we will make it clear in any guidance that absolute conformity between a vision and those strategies will not be essential to a sound plan. While we recognise that alignment with such strategies would be desirable, those strategies may be prepared on different timeframes and might not always recognise current community priorities and views.

Question 3: Do you agree with the proposed framework for local development management policies?

22. A total of 298 respondents answered this question. Of those, 192 (64%) agreed with the above proposal, 29 (10%) did not agree and 77 (26%) were indifferent. This indicates considerable support for the proposal.

Key points:

  • There was general recognition that the principles, which clearly distinguish between the role and focus of national development management policies (NDMPs) and local development management policies (LDMPs), would reduce repetition in policy at the local level. Additionally, it was felt that the proposed approach to LDMPs could streamline the local plan production process and reduce the number of policies planning authorities must prepare.
  • Those who supported the proposals also recommend establishing robust monitoring mechanisms for LDMPs to ensure they are meeting objectives. Success will depend on adequate planning authority engagement, consultation window participation and appropriate expertise from the gateway assessor.
  • Several respondents also acknowledged and appreciated the consistency that NDMPs would provide. Streamlining local plans and harmonising wider environmental policies and standards is also supported.
  • Respondents that did not agree with the proposals expressed concern that the proposed framework would unduly restrict local planning authorities from reflecting local distinctiveness in their local plan. They sought greater clarity on:
    • whether local planning authorities would be able to use LDMPs to exceed policy requirements / standards established in NDMPs, for example in relation to net zero carbon targets;
    • what process would apply should an planning authority wish to deviate from an NDMP and what justification or evidence would be needed to do so;
    • and, what would constitute “appropriate justification” to establish an LDMP for a particular topic the planning authority may consider relevant to their area.

Government response

23. The government is fully committed to implementing a suite of national policies for decision making with a view to streamlining local plans, enabling plan-makers to focus on matters that are genuinely local, and supporting consistent local decisions. We are considering how best to take forward national policies for decision making and intend to consult on this in spring 2025, noting the challenge for planning authorities in setting out a firm direction of travel for their plans while the nature and content of these policies is still under development.

24. When it comes to local policies for decision making, the government has carefully considered the responses submitted in relation to this matter, particularly those comments expressing support for a more focused approach to preparing policies in plans and for guiding principles to support their preparation alongside national policies for decision making.

25. The government will continue to consider how local policies for decision making might be implemented alongside national policies in a way that avoids duplication and aids effective decision making. As part of that exercise, we will seek to address practical challenges identified by respondents, including defining “appropriate justification” for the creation of local policies for decision making and ensuring that the relationship between national and local decision-making policies is complementary. Further details will be set out alongside the consultation on national policies for decision making in spring 2025.

Question 4: Would templates make it easier for local planning authorities to prepare local plans? Which parts of the local plan would benefit from consistency?

26. A total of 306 respondents answered this question. Of those, 229 (75%) agreed with the above proposal, 20 (7%) did not agree and 57 (19%) were indifferent. This indicates strong support for the proposal.

Key points:

  • There was broad support for the proposed use of templates in plan-making, with recognition that the introduction of templates could result in benefits such as speeding up plan-making; simplifying and increasing familiarity across plans and supporting documents; reducing repetition; and enabling easier and faster comparison between different planning authority areas. However, feedback emphasised the need for templates to be flexible to allow for local circumstances, and for templates to be published, consulted on and amended accordingly.
  • The most common areas where templates are supported are for housing trajectories, site allocations and annual monitoring. There was also wide support for standardisation of policies maps. It was stressed that any compulsory templates should be free to access.
  • Some respondents felt that template use should not be mandatory and could be one of multiple tools available to local planning authorities to speed up the plan-making process, whereas some felt only certain policy types and areas should be templated.
  • Those who supported the principle of using templates also referred to the length of local plans and the need for clarity on an appropriate length. Some respondents called for a restriction on the length of plans and others felt national guidance on the required contents would prevent overly excessive plan content.
  • For those who did not agree with the introduction of templates, the general position was that they would be too restrictive, would stifle innovation and that a nationally derived template could not accommodate for unique local scenarios across all council areas with their own geographic constraints. Some suggested that highlighting best practice policies would be a more useful alternative approach to producing templates. Some considered that the time taken to address adherence issues or seek permission to deviate from templates would cause delays in plan production.

Government response

27. Currently, plans lack standardisation and consistency. The structure, terminology, and specific components such as supporting text within plans varies significantly between different plans. Plans also have different approaches to policies maps, using different systems, colours and symbologies. Consequently, it can be challenging for users to navigate and engage with plans across different authorities to understand what matters to them, resulting in wasted time and effort. The consultation proposed that government would produce a series of templates for specific parts of plans, with an expectation that local planning authorities should use them to draft and present their local plan.

28. Following the consultation, while noting the concerns raised, the government believes the strong support for these proposals indicates there is a powerful case for greater templating of key components of plans. We will continue to work closely with the sector to identify where templates can offer the most support to plan-makers in speeding up the plan preparation process and to support completion of administrative processes more quickly and easily. In particular, this will build upon the components of plans where templating and greater standardisation were most commonly supported, such as policies maps and elements such as site allocations, and housing targets and trajectories. At present templates are expected to be provided for:

a. The notice to commence
b. Local plan timetables
c. Project Initiation Documents (PIDs)
d. Reports associated with gateway assessments (including self-assessment forms for the first gateway)
e. Annual Monitoring Reports

29. The government is exploring a range of further templates which could be provided to help streamline the local plan process, alongside data standards. Some templates will be designed for use in conjunction with a mandated data standard, whilst others will form part of an optional toolkit which will support planning authorities to prepare their plan. The optional use of templates recognises the need to reflect local distinctiveness and enable innovation, allowing planning authorities to adapt them to suit their needs. For example, to support planning authorities in preparing concise, locally distinctive visions, we are exploring how we can set out a best practice example vision in guidance, together with templated consultation questions to seek quality input from stakeholders on the direction and content of the vision.

Question 5: Do you think templates for new style minerals and waste plans would need to differ from local plans? If so, how?

30. A total of 199 respondents answered this question. Of those, 70 (35%) thought templates for new style minerals and waste plans would need to differ to that for local plans, 33 (17%) thought they would not and 96 (48%) were unsure.

Key points:

  • Respondents who suggested templates for a minerals and waste plan would need to differ indicated that a specific minerals and waste template will help to account for the difference in plan content. Respondents in this group commented that the plans will cover a larger geographical area compared to local plans, and many authorities may need to be involved. Therefore, the template will need to be flexible enough to allow issues to be considered at a variety of spatial scales and take into account local factors.
  • Respondents in this group also suggested various issues that will need to be covered in a minerals and waste plan template, including monitoring indicators, safeguarding, site restoration, how need for waste capacity for different waste types is assessed, and the waste hierarchy.
  • Respondents who did not think templates for new style minerals and waste plans would need to differ suggested this was the case providing the template for local plans incorporated enough flexibility to ensure minerals and waste specific issues can be covered.
  • Some respondents who were unsure or did not answer the yes/no question explained that they need more detail on what would be included in the template or an example before they are able to comment. Minerals and waste experts should be consulted on any draft templates.
  • Other respondents in this group suggested that the layout of the template could be the same as that of local plans, but that the content would need to be different.
  • Respondents in this group emphasised that consistency between local plans and minerals and waste plans is needed.

Government response

31. Following the consultation, we will adopt a similar approach to templating across both local plans and minerals and waste plans. However, we will use the issues raised in response to this consultation to inform the development of templates to ensure these are flexible enough to cover issues specific to minerals and waste plans.

Chapter 2: The new 30 month plan timeframe

Question 6: Do you agree with the proposal to set out in policy that planning authorities should adopt their plan, at the latest, 30 months after the plan preparation process begins?

32. A total of 298 respondents answered this question. Of those, 100 (34%) agreed with the above proposal, 123 (41%) did not agree and 75 (25%) were indifferent. This indicates about a third of respondents support the proposal.

Key points:

  • Only a very small number of respondents fully agreed with the proposal for a 30 month requirement, with a few suggesting that penalties and interventions and/or incentives should be imposed in cases of failure, and that the proposed 30-months should be set out in regulations.
  • There was more support for the proposals to speed up plan-making and implement a specific timeframe in principle, specifically amongst developers, interest groups and other private sector organisations.
  • In contrast, most planning authorities did not support the specific proposal and felt that the challenges in achieving it were so significant that they could not even support the principle of introducing a fixed timeframe for plan-making.
  • A range of challenges in achieving local plans in 30 months were cited across both respondents that agreed and disagreed with the proposal, including:
    • The need for planning authority and Planning Inspectorate resources to deliver in such short timeframes
    • The length of time taken to process representations
    • Lengthy political decision-making timeframes
    • Procurement timeframes
    • General complexity of preparing plans, in particular relating to identifying and selecting sites and dealing with cross-boundary matters
  • For respondents that were unsure about the proposal, the general feeling was that 30 months could be achievable if the government directs more clearly how potentially contentious issues (e.g. housing need and requirement) should be addressed; for example, some suggested that housing need could be allocated at a sub-regional or regional level.

Government response

33. The government recognises that progress and adoption of a local plan takes on average 7 years to produce, with only around one third of local planning authorities having adopted a local plan in the last 5 years. Of the two thirds of local planning authorities that have not adopted a local plan in the last 5 years, only about 5% have published a new plan and only about 10% have submitted one for examination. Slow progress in their preparation means local plans are at greater risk of being out-of-date upon adoption, creating uncertainty for communities and holding back development where it is needed.

34. The previous government proposed setting out an expectation in policy that plans should be prepared and adopted in 30 months, to increase speed and efficiency in the process and create more certainty for key stakeholders. There are recent examples of planning authorities preparing a plan in just over 30 months within the current system. It was therefore considered that a 30 month timeframe struck the appropriate balance between needing plans to be prepared more quickly and kept up to date more effectively, with a realistic view of what is deemed achievable. Through a wider package of plan-making and other planning system reforms to achieve efficiencies and streamlining, there was a strong belief that a 30 month timeframe could be widely achieved.

35. The government has carefully considered these responses and notes the strong sentiment expressed around these proposals. While this government recognises the challenges faced by authorities in preparing plans at pace, we remain committed to accelerating the process. Plans are at the heart of our proposals to get Britain building. Therefore, in support of our aim to ensure universal plan coverage across England, we maintain that planning authorities and other stakeholders should focus energy and resources on working with the government to deliver the ambition of local plans and minerals and waste plans that are routinely prepared and adopted in 30 months.

36. The wide ranging plan-making reforms – such as the introduction of gateways; shorter, simpler and more standardised content focused on the core principles of plan-making; and a series of digital transformation initiatives – will support this aim. But we recognise that this alone will not be enough to deliver the transformative change needed, especially in light of the comments around the complexities of preparing plans.

37. We are therefore committed working closely with the sector to develop a more comprehensive suite of guidance, tools and templates, which will be accessible via a new consolidated home for plan-making products on GOV.UK. This will set out clearer expectations for plan-making and provide much more support than under the current system, with a particular focus on addressing the most significant barriers to producing plans more quickly. We will also work with our partners, including the Planning Advisory Service, to put in place the support that plan-makers need at the outset of plan preparation, with a greater focus on project setup, management and governance processes. This will be supported through our intention to introduce a template for Project Initiation Documents (PIDs). More broadly, the government is providing funding to foster a pipeline of planners for the future by recruiting an additional 300 planners, to assist planning authorities with additional capacity to adapt to new ways of working and can focus resources on plan-making.

Question 7: Do you agree that a Project Initiation Document will help define the scope of the plan and be a useful tool throughout the plan making process?

38. A total of 307 respondents answered this question. Of those, 242 (79%) agreed with the above proposal, 16 (5%) did not agree and 49 (16%) were indifferent. This indicates strong support for the proposal.

Key points:

  • Respondents broadly recognised the value of Project Initiation Documents (PIDs), (as well as a project management focused approach in general), to help manage risks and budgets and improve transparency at the outset of the plan-making process. Some saw the value in templating the PID in such a way that it could be quickly adapted to local circumstances, with the ability to update it during plan-making and enable multiple authors to collaborate in real time on workflows, tasks, assess progress and manage content.
  • To maximise the value of PIDs as a project management tool, some respondents (particularly planning authorities and developers) suggested that key substantive issues relating to the plan should be outlined at the outset so they can be considered up-front during the first gateway. They suggested that these could include objectives and options relating to housing needs, affordable housing, strategic employment matters and infrastructure needs.
  • Amongst those who supported the proposals, some were concerned that some evidence could only be completed once site-specific details were known and questioned the value of consulting with statutory bodies and others on the PID. Furthermore, some noted that many planning authorities already employ PIDs but felt they had made little difference to how quickly the plan was prepared, reflecting the complex nature of plan-making.
  • Those respondents who disagreed with the proposal considered that defining the scope of a plan is likely to be more complex and take longer than the proposals suggest. They also sought greater clarity of whether consultation during the scoping stage to inform the PID would be a requirement or not.
  • Those respondents who were unsure of the proposal stated that the project management of local plans should be a matter for local discretion and not controlled by central government. Some planning authorities have their own internal project management processes and it was felt that a templated PID should not be mandatory.
  • There was broad consensus on the need for government to set out clear guidance around the scope of PIDs and how they should be updated.

Government response

39. Through the consultation we proposed that planning authorities should prepare a PID during the scoping stage, to help define the scope of the plan and serve as a ‘live’ tool throughout the plan-making process. Prior to the 30 month process commencing, in preparing a PID a planning authority would define the scope of the plan, identify the time and resources needed to support its preparation, and establish support from elected Members on the main messages that will shape the strategy. The PID could be used as a tool to prepare for and evidence progress towards the first gateway assessment.

40. Government continues to see a vital role for quality project planning as part of the scoping phase of plan preparation. We will therefore proceed with our proposal to set out, in guidance, that planning authorities should prepare a PID to support their first gateway assessment, supported by a template made available by government. However, noting the feedback received through the consultation, we will ensure that templates are sufficiently flexible to suit different contexts and can dovetail with existing internal processes already employed successfully by planning authorities.

41. Drawing on the feedback received, we will work closely with our partners the Planning Advisory Service, and more broadly the local government sector, to design and publish a toolkit of guides, best practice examples and templates that all planning authorities may use to successfully develop their own PIDs. We want the PID to be a genuinely useful tool that planning authorities can use to plan, support decision-making and track progress; we see it as a product that planning authorities can continue to iterate and build on throughout the plan-making process, not just an onerous document that is created once and not revisited.

42. While we do not intend to specify any requirements around how plan-makers consult on PIDs, we envisage that they would be used (wholly or partially) to anchor successful conversations both internally within the council, and with key external stakeholders, to secure buy-in for the development of the plan and the proposed scope, approach and resourcing.

Chapter 3: Digital plans

Question 8: What information produced during plan-making do you think would most benefit from data standardisation, and/or being openly published?

43. A total of 317 respondents responded to this question.

Key points:

  • The majority of respondents voiced their support for greater standardisation of data to support local plans. Complex areas with large amounts of information (e.g. local plan evidence), were identified as areas which could benefit the most from standardisation.
  • There was general agreement across all groups on making data open and more easily accessible. It was noted that open publication of local plan data should be the responsibility of the data ‘owners’, so as not to place unreasonable burdens on planning authorities.
  • Respondents noted the importance of locally specific data and the need for a degree of local discretion and flexibility when identifying areas for standardisation, to ensure that valuable areas outside of the more ‘common’ datasets are considered.
  • The need for additional training and resourcing to upskill planning authorities was flagged as important for the successful adoption of data standards.

Government response

44. The government has committed to reducing the time it takes to produce a local plan, from an average of 7 years to 30 months. Data standardisation is essential for ensuring that valuable information within local plans is easier to find, use and trust. With standardisation, data can also be used to create new tools and services which help those involved in the plan-making process to work more openly and efficiently.

45. There was general support for the implementation of data standards, with respondents recognising the value of taking a more consistent approach to the way in which data within the plan-making process is processed and published. Policies maps, evidence base, site allocations, infrastructure requirements and monitoring were identified as areas which would most benefit from data standards.

46. Whilst there was general support for the introduction of data standards in the plan-making process, many felt that it was important to have alternative approaches and methods which cater to the varying levels of capability and resource across planning authorities. They also recognised the need for consideration of different accessibility requirements for those engaging with the plan-making process. Further to this, templates and standard methodologies were identified as additional areas which could support the broader ambition of a more standardised approach for local plans.

47. Noting this feedback, we will undertake targeted engagement and testing with planning authorities for the scoping and analysis of the potential for data standardisation as part of the data design process. This will ensure that locally specific or data licensing considerations are considered at the beginning of the process. Following the data design process and prior to their implementation, we will also test the data standards to assist with the development of tools, templates and guidance that may be needed to support planning authorities and others involved with their implementation.

Question 9: Do you recognise and agree that these are some of the challenges faced as part of plan preparation which could benefit from digitalisation? Are there any others you would like to add and tell us about?

48. A total of 283 respondents answered this question. Of those, the majority 220 (78%) agreed and recognised the challenges set out, 21 (7%) did not agree and 42 (15%) were unsure.

Key points:

  • The majority of respondents, agreed with and recognised the challenges of plan preparation set out. The highest level of agreement was with the need for templates, standard formats and terminology, particularly in relation to evidence and consultation.
  • Many also took the opportunity to share additional challenges, the most common being in relation to consultations and the need for inclusiveness: that a digital first approach should not be digital only. Many flagged the distinctiveness of plan areas and their circumstances, and the need to accommodate this.
  • Many planning authorities noted that a lack of skills and resources to support plan-making was a significant issue. Many identified a need for additional funding to assist with forthcoming reforms. Planning authorities identified changing national policy as an issue and requested greater levels of stability and certainty going forward.
  • There was consensus that data is key to reducing complexity for the evidence base and to unlocking the potential of digital local plans. Data accuracy, access, sharing (particularly from public bodies) and security were detailed as specific challenges.

Question 10: Do you agree with the opportunities identified? Can you tell us about other examples of digital innovation or best practice that should also be considered?

49. A total of 283 respondents answered this question. Of those, the majority 220 (81%) agreed with the opportunities identified for digital tools and products, 40 (15%) were unsure and 13 (5%) did not agree.

Key points:

  • The majority agreed with the opportunities identified. The highest level of agreement focused on the introduction of templates, checklists and step-by-step guides to provide greater clarity and efficiencies, along with the standardisation of data for consistency, access and use. This was followed by the presentation and visualisation of plans, policies and spatial data.
  • Respondents also shared additional opportunities, with many highlighting standardisation of planning tools and processes, evidence, collating and processing of responses to consultations and plan assessment. Many referred to automation and AI, however opinion was divided between these being an opportunity or point of concern regarding accuracy.
  • Whilst noting the benefit of digital approaches, many also raised the need for caution regarding accessibility requirements. As per the response to question 9, they felt that digital first should not be a digital only approach and that flexibility would be needed to reflect local circumstances and distinctiveness.
  • Many planning authorities highlighted the need for funding for digital capacity and capability (including staffing, training and IT infrastructure) to address current barriers to implementation and to maximise the opportunities from digital tools and innovations.

Question 11: What innovations or changes would you like to see prioritised to deliver efficiencies in how plans are prepared and used, both now and in the future?

50. A total of 304 respondents answered this question.

Key points:

  • Respondents most commonly suggested data standardisation; templates; toolkits and checklists; greater clarity in guidance; better search tools and sharing of best practice as priorities. Many also considered that the digital presentation of plans, along with interactive digital maps and visualisations, should be prioritised.
  • The consultation process was considered by many as presenting a significant opportunity for efficiencies, particularly in the processing of responses. A number of these respondents also identified the potential of AI, while some also noted concerns about how this was used.

Government response to questions 9, 10 and 11

51. Questions 9, 10 and 11 asked about digitalisation and opportunities for digital innovation. Step-by-step guidance and tools will be provided, together with greater clarity and consistency in the expectations for plan-making, to help planning authorities to pass through key plan-making stages and speed up the preparation of plans. The government will bring this useful information together in one place on GOV.UK, when we publish our creating or updating a local plan pages. Reflecting feedback from the consultation, the government notes the desire of planning authorities for plan content to continue to reflect local distinctiveness.

52. Given the support for greater standards and consistency of formats and data, combined with clarity sought for the requirements when preparing plans, we are working to provide this. We have started by prioritising the evidence required for site selection; how plan policies are visualised through policies maps; and how representations are managed. These are areas we know are challenges for planning authorities. Accessibility and inclusion considerations have been part of this work. We hope to publish these imminently. We will continue to develop and test guidance and tools to support the delivery of plans faster, that all planning authorities can use and access.

53. We recognise that respondents expressed concerns about resource and skills gaps within planning authorities, as well as the cost of implementing and supporting digital tools and services. The consultation referenced the support provided by the government through the Digital Planning Programme, including the PropTech Innovation Fund and Open Digital Planning community. Over 100 planning authorities have been supported to progress digital planning initiatives, adopt modern planning practices and deliver efficiencies through digital tools. We will continue to share best practice, guidance, and case studies from funded projects.

54. It remains our ambition to bring plan-making into the digital age. We will continue to take a user-centred approach, based on the needs of plan makers and those involved in the plan-making process. New digital tools and approaches will be delivered incrementally, with a commitment to a partnership approach to the modernisation of the planning system.

Chapter 4: The local plan timetable

Question 12: Do you agree with our proposals on the milestones to be reported on in the local plan timetable and minerals and waste timetable, and our proposals surrounding when timetables must be updated?

55. A total of 280 respondents answered this question. Of those, 209 (75%) agreed with the above proposal, 23 (8%) did not agree and 48 (17%) were indifferent. This indicates strong support for the proposal.

Key points:

  • Respondents were supportive of the principle of simplifying the requirement to produce a local plan timetable and there was generally broad support for the proposed milestones to be reported on.
  • While there was support for the proposal that the local plan timetable would not need to be subject to full council sign-off each time it is revised, some felt that, in practice, council members would still need to be involved in any decision to revise the timetable. This would especially be the case for more outward facing milestones such as consultation or the examination in public, and this process could lead to delays.
  • There was some support for the proposed requirement for updates to the timetable to be made at specific milestones or every 6 months as a fallback, and for the timetable to be presented consistently and available as data (rather than a PDF). However, some respondents suggested that government should be clearer about the consequences for planning authorities where milestones are missed.
  • On a practical level, some raised concerns about level of detail needed when reporting dates against the various milestones, noting the challenge in pinpointing these accurately further in advance. Government Response

56. In the consultation we proposed, in addition to the measures in the LURA, to introduce a standard way for planning authorities to report against key milestones in a local plan timetable. The list of local plan timetable milestones will be expanded to reflect the end-to-end process of preparing a local plan, providing greater clarity to the public and stakeholders of current and future progress. Additionally, planning authorities will be required to make relevant data publicly available in a prescribed digital format.

57. Reflecting on the feedback received, the government will implement the measures as proposed in the consultation, working closely with planning authorities to develop a data standard for local plan timetables that will meet user needs. To allow changes to be tracked by interested parties and ensure the position is always transparent, we will set out an expectation in guidance that planning authorities should provide a schedule of amendments when the timetable is updated. The response to the way planning authorities will be required to keep their local plan timetable up to date is set out in Question 13.

Question 13: Are there any key milestones that you think should automatically trigger a review of the local plan timetable and/or minerals and waste plan timetable?

58. A total of 228 respondents responded to this question.

Key points:

  • While there was general support for government to introduce a more explicit requirement for planning authorities to review the local plan timetable when there is a significant change in local circumstances, there were mixed views about how far such a requirement should go and how explicit government should be in defining this. For example, some suggested this could include a situation where there is a change in local political leadership, or even where a planning authority’s housing delivery falls below that agreed through the examination.
  • Many respondents suggested gateway assessments as a natural point at which a review should be undertaken, and several also suggested the proposed mandatory consultation windows.

Government response

74. As proposed in the consultation, the government will require planning authorities to revise their timetable at set milestones and regular intervals. Reflecting on the feedback received, we will require planning authorities to update their timetable upon completing the first gateway assessment and no later than one month after any other defined milestone has been reached or missed. Noting the mixed views expressed, as a fallback, we also intend to require planning authorities to revise their timetable at least once every 6 months if, upon reviewing it, the authority determines that it requires updating. On balance we believe this represents a reasonable, simple backstop to ensure the timetable is regularly maintained.

Chapter 5: Evidence and the tests of soundness

Question 14: Do you think this direction of travel for national policy and guidance set out in this chapter would provide more clarity on what evidence is expected? Are there other changes you would like to see?

75. A total of 296 respondents answered this question. Of those, 181 (61%) agreed with the direction of travel set out in this chapter, 38 (13%) did not agree and 77 (26%) were indifferent. This indicates considerable support for the direction of travel.

Key points:

  • There was general support for the aim of streamlining evidence requirements and a recognition that evidence base demands have increased over time. Respondents that supported the proposals felt that guidance on proportionality would help to reduce the evidence burden and reduce the time taken to prepare a local plan.
  • Some respondents felt that national policy should establish, as a minimum, the evidence required for satisfying the tests of soundness, and that government should set out standard methodologies or stipulate the form and content of this evidence.
  • There was some support for a ‘statement of compliance with legislation and national policy’, but other respondents expressed concern about this becoming too onerous and queried how this would relate to the topic papers that planning authorities routinely prepare currently.
  • Some felt that further clarity would be needed on how the distinction would be made between evidence submitted as ‘information only’ versus evidence that should be submitted to demonstrate soundness. While there was some support for limiting the issues that can be raised at examination, others were concerned that this would lead to important not being fully tested or opened up to discussion.
  • Some respondents, especially local authorities, supported exploring changes to the ‘effective’ element of the tests of soundness, but others were concerned that this could lead to deliverability issues, which might affect delivery of homes.

Government response

80. The consultation set out various proposed changes which, taken together, would reduce the amount of evidence required to prepare a plan and defend it at examination, while ensuring delivery of quality plans. These include:

  • Clearer expectations for preparing evidence set out in national policy and guidance
  • Increased standardisation of key evidence and data
  • Freezing data or evidence at particular points of plan-making
  • Streamlined, focused new style plans
  • Support on evidence requirements provided through gateway assessments

81. Recognising the considerable support for the aims set out in the consultation and the need for interventions to provide greater clarity around local plan evidence, the government will work closely with the sector to continue to refine and develop its proposals.

82. However, following the consultation we confirm that we will no longer be proceeding with the proposal to make a distinction between evidence submitted as ‘information only’ versus evidence that should be submitted for the soundness test. This is because we believe, on balance, that this distinction would vary depending on specific circumstances, making a definitive definition of ‘information only’ challenging. In turn, this could lead to additional discussion and challenge at examination. The rationale for this proposal was to both reduce the amount of material that is scrutinised at examination, and to better reflect the purpose of examination to consider soundness; we have concluded that it is possible to meet these objectives through other changes. (This proposal also related to a separate proposal to require planning authorities to submit only supporting documents that are related to the soundness of the plan. We are also no longer proceeding with this proposal – see the response to Question 17 for further details.)

Question 15: Do you support the standardisation of evidence requirements for certain topics? What evidence topics do you think would be particularly important or beneficial to standardise and/or have more readily available baseline data?

83. A total of 293 respondents answered this question. Of those, 235 (80%) agreed with the above proposal, 11 (4%) did not agree and 47 (16%) were indifferent. This indicates strong support for the proposal.

Key points:

  • Overall, there was strong support for the standardisation of evidence. It was felt that this would help reduce the time taken by planning authorities to consider different methodologies; to improve consistency of evidence; reduce the time taken to prepare evidence, with the effect of improving cost efficiency, and putting planning authorities in a stronger position to resist challenge at examination.
  • Respondents listed several areas which would benefit from standardisation including, but not limited to, site assessment and selection; transport assessments; and strategic flood risk assessments. Furthermore, it was recognising that digitalisation would help with standardisation.
  • Respondents broadly noted that standardisation would be especially beneficial at the start of the process to avoid early abortive work, with bespoke evidence or data mainly produced later on in the process as and when required. Throughout the responses, it was often mentioned that standardisation should not be a requirement, but rather planning authorities should have the flexibility to draw on standardised approaches where helpful, and elsewhere take bespoke approaches to account for local circumstances.
  • Respondents recognised that baseline data that is particularly relevant to plan-making includes flood risk data from the Environment Agency data and population and household data from the Office of National Statistics and the Ministry of Housing, Communities and Local Government. They acknowledged the challenge in co-ordinating open, transparent, and useable data sourced from multiple government bodies and agencies.
  • Amongst the small number of respondents that did not agree with the proposal, it was mentioned that it would be difficult to standardise and maintain flexibility to reflect the unique characteristics of local areas, and that standardisation risks reducing the detail and robustness of evidence to inform proposals.

Government response

84. The government recognise that undertaking work to standardise elements of the evidence base is particularly complex. Previous engagement with the sector indicated that standardisation of evidence would help provide greater clarity on what is expected and reduce discussions around specific methodologies at examination. It is considered that standardisation also presents opportunities to make better use of data and digital processes and tools. More readily available data could also help planning authorities create a consistent and quality baseline of evidence.

85. As a result of the views expressed through the consultation, the government will set out clearer national approaches to key evidence topics through national policy and guidance, continuing to develop its proposals in line with those set out in the consultation. This will include a clearer, end-to-end approach to site identification, assessment and selection, and additional guidance on the evidence that is expected to demonstrate that a plan is sound. The government will work with the sector to take forward national approaches to key evidence.

Question 16: Do you support the freezing of data or evidence at certain points of the process? If so which approach(es) do you favour?

86. A total of 299 respondents answered this question. Of those, 222 (74%) agreed with the above proposal, 24 (8%) did not agree and 53 (18%) were indifferent. This indicates considerable support for the proposal.

Key points:

  • Many respondents agreed that freezing evidence would play a crucial role in local planning authorities achieving the 30-month timeframe; notably to support faster examination of plans, minimising costs and reducing the risk of challenge.
  • Some of those respondents who agreed with the proposals also suggested that evidence should be frozen early, at the first mandatory consultation window or at the first gateway assessment, whilst the majority agreed that this would be most beneficial from the point of publication of the plan up until its submission for examination. Many agreed that freezing evidence during this period would allow sufficient flexibility for local planning authorities to prepare their evidence, in addition to considering any new data which may become available.
  • In addition, some respondents suggested that the proposals should go further; for example, some felt that gateway assessments should be used to ensure that local planning authorities are on the right track, whilst being realistic about how far these can go in providing reassurance. For example, the first gateway could help planning authorities to identify scope of evidence and approach, linked to preparation of a PID, whilst the second and third gateways could ensure that evidence production is on the right track ahead of examination.
  • It was often mentioned that evidence freezing should not impact the overall outcome of the local plan and therefore should be a choice, with the ability for planning authorities to unfreeze evidence if new data became available. As such, evidence freezing should be accompanied by guidance which sets out clear parameters, including which types of evidence can be frozen, when evidence can be frozen, exceptions to freezing and outlining mechanisms for updates. For example, flood risk was an area that many felt should not be frozen as a result of the direct safety and developability-related impacts on sites.
  • Many also suggested that in addition to data inputs being frozen, national policy should also be frozen. It was also suggested that there should be clarity around what constitutes ‘material’ and ‘non-material’ updates to evidence; the former relating to evidence which would need to be dealt with in the present plan cycle, and the latter being evidence which could be resolved and updated with the next update.

Government response

87. The consultation made the case for freezing data or evidence at certain points in the plan-making process – with the aim of reducing iteration and delay. Various options were proposed, including:

  • Freezing of input data, for example, no longer being expected to incorporate or re-consider regularly released data each time they are released, unless the planning authority feels there is an overwhelming reason for doing so.
  • Agreeing the scope of evidence (or certain evidence documents) or the methodology followed earlier in the process, which is then not changed or only changed under limited prescribed circumstances. This might be done through gateway assessments.
  • Freezing evidence at the point of publication of the plan and submission to the Inspector. This would mean setting an expectation that new evidence would not normally be required to be submitted to support examination.

80. As a result of the views expressed through the consultation, we are continuing to explore the opportunity to ‘freeze’ certain types of evidence at particular stages of the process, with clear expectations set out in national policy and guidance. Any future national policy changes to support or enable the freezing of evidence will be consulted on in the normal manner.

Question 17: Do you support this proposal to require local planning authorities to submit only supporting documents that are related to the soundness of the plan?

81. A total of 282 respondents answered this question. Of those, 181 (64%) agreed with the above proposal, 48 (17%) did not agree and 53 (19%) were indifferent. This indicates considerable support for the proposal.

Key points:

  • Those that supported the proposal felt it would reduce the burden on local planning authorities and make it easier for third parties to be involved with the examination process, by streamlining the volume of information down to a smaller number of key documents; some suggested this reflected existing best practice. They felt that it would mean that the public and other stakeholders would be less overwhelmed by the amount of evidence that is published.
  • However, some of these respondents had qualified support for the proposals, and highlighted similar issues to those who did not support the proposals.
  • Respondents that did not agree with the proposal felt that all documents produced by planning authorities are relevant to examination, and that the proposal could reduce transparency and would reduce the ability of the planning authority to tell the “story” behind the plan.
  • Respondents felt that, counterintuitively, it would increase risk for planning authorities as planning inspectors would still be able to request further information – and that for this reason planning authorities would likely submit more evidence, rather than less. Others felt that the element of judgement in the classification of evidence would also encourage local planning authorities to err on the side of caution. Some felt this would open a new area of potential challenge and controversy at examination.
  • Many respondents felt that this change would require clear guidance on the types of evidence that relates to soundness and legal compliance, and that there would need to be a process for planning inspectors to request additional documents or to explain to stakeholders what could be reasonably requested. It was suggested that gateway assessments could play a role in agreeing up-front what should be submitted at examination.

Government response

82. The consultation proposed amending the existing regulations governing the preparation of plans, establishing a requirement that the planning authority only submits the supporting documents that it considers strictly necessary to demonstrate that the plan is sound. This would also apply to minerals and waste plans.

83. Despite the considerable support for the proposal, considering the practical challenges raised in a number of the responses, we no longer propose this approach. Instead, it will be maintained that planning authorities are required to submit only such supporting documents that in their opinion are relevant to the preparation of the plan. Other parts of our reforms will ensure that the evidence submitted alongside the plan remains proportionate and accessible to stakeholders and communities (see Question 14). We intend to expand the list of specific documents which must be submitted to an examiner to include a statement of compliance with legislation and national policy. The statement will set out the planning authority’s evidence to demonstrate that the plan is sound – this is expected to reduce the number of supporting documents and aid navigation across the evidence base suite.

Chapter 6: Gateway assessments during plan-making

Question 18: Do you agree that these should be the overarching purposes of gateway assessments? Are there other purposes we should consider alongside those set out above?

84. A total of 289 respondents answered this question. Of those, 211 (76%) agreed with the above proposal, 19 (7%) did not agree and 49 (17%) were indifferent. This indicates strong support for the proposal.

Key points:

  • Respondents that agreed with the proposals broadly recognised the benefits that gateways could bring, although there was a widespread view that additional resources would need to be committed to planning authorities and the Planning Inspectorate to ensure they are delivered successfully. Some expressed concern that Gateways 1 and 2 would only be ‘advisory’, noting this might result in plans progressing too far into the process before deficiencies are highlighted – they suggested that each gateway should be binding so that issues do not need to be covered again at examination.
  • A number of respondents suggested that the purpose of gateways should be expanded to explicitly include how the plan is evidenced and how the community has been engaged.
  • Some respondents that disagreed with the proposals expressed concern about the exclusion of third parties, with several suggesting that key technical stakeholders should be represented.
  • Some also expressed concerns that Inspectors might take a different view at examination to the advice received during gateway assessments. However, this concern wasn’t universal, with some recognition that gateways are not intended to be “mini examinations” and that the extent to which they can provide full assurance to planning authorities would be limited by the information and time available to the assessor. Some also perceived that the independence of Inspectors at examination to act without prejudice might be compromised if they had been directly involved in gateway assessments.
  • The inherent challenges and complexities of local plans meant that some respondents found it difficult to see how gateways would operate in practice, indicating a need for flexibility, clear guidance, and careful consideration of logistical and financial challenges.

Government response

85. Given the strong support, the government remains committed to the introduction of gateways as part of the new plan-making system, and we will continue to develop these based on the purposes set out in the consultation. Gateway assessments will be a flexible and supportive process, with advice targeted at those areas of plan preparation which pose the greatest risks to the soundness and legal compliance of the plan. We will work closely with our delivery partners, the Planning Inspectorate, to ensure that gateways are designed to achieve this. Furthermore, the government intends that a suite of guidance, checklists and flexible templates is introduced to support planning authorities in preparing for gateway assessments.

86. Noting the concerns expressed that third parties will not be involved in gateway assessments, we will set out in regulations that where a particular body or organisation is identified in the assessor’s report, the planning authority must notify them and, at the same time as publishing the assessor’s report, send them a copy of this. This will enable quick escalation of any issues identified that third parties may be able to help resolve.

87. In response to concerns around the consistency of advice between gateway assessors and Inspectors at examinations, we will also explore how national policy could be used to achieve consistent decision making throughout the end-to-end plan-making process, noting that there may feasibly be situations where a different approach should be taken (e.g. if a significant new issue comes to light at a late stage).

Question 19: Do you agree with these proposals around the frequency and timing of gateways and who is responsible?

88. A total of 265 respondents answered this question. Of those, 146 (55%) agreed with the above proposal, 41 (15%) did not agree and 78 (29%) were indifferent. This indicates over half support the proposal.

Key points:

  • There was general support for the frequency of gateways proposed and broad support for the Planning Inspectorate to conduct the assessments, but many held the view that the same assessor should carry out each gateway and undertake the examination to ensure consistency of advice. However, if this were not possible, then some suggested performance expectations should be established between the planning authority and gateway assessor to ensure consistency, quality of advice and timely completion of assessments.
  • Some respondents saw a role for other specialists such as the Planning Advisory Service in providing training, templates and guidance, but only a small number suggested they could lead the first gateway and others noted additional risks of using assessors not appointed by the Planning Inspectorate.
  • For respondents that agreed with the frequency and timings of gateways, this support was predicated on the quality and consistency of advice provided at each assessment stage and the availability of suitably qualified persons to undertake the assessments. There was significant and widespread concern around whether the Planning Inspectorate is adequately resourced to deliver gateway assessments in a timely and efficient way, such that it would not affect a planning authority’s ability to meet the 30 month timeframe for plan preparation and adoption.
  • For respondents that did not agree with the frequency and timing of gateways the reasons why were polarised; however, a common theme, especially amongst developers, was that the timings for gateways should be more binding.

Government response

89. The government proposed to introduce, via regulations, a requirement for planning authorities to undertake three gateways:

  • at the beginning of the 30 month process, following work undertaken at the scoping stage
  • part-way through the plan preparation, between the two mandatory consultation windows
  • following the second mandatory consultation window when the planning authority intends to submit the plan for independent examination

90. While the government will implement three gateway assessments, as set out in the consultation, in response to the views expressed we will adjust how these are implemented. The government confirms that it intends to proceed with setting out in regulations a requirement for planning authorities to undertake the second and third gateways in the manner proposed in the consultation document, within the windows specified, and that the Planning Inspectorate will lead on the design and implementation of these assessments. MHCLG is working closely with the Planning Inspectorate to ensure that the aims and purposes are delivered successfully and to ensure key supporting products are delivered in a consistent and coherent manner. The feedback received through the consultation will continue to help shape the design of gateways.

91. We note the view that the first gateway assessment has a distinct role, which will be less focused on emerging soundness and legal compliance, and more focused on ensuring that the right processes and resources are in place to support delivery of the plan. We also note the broad concerns about the risks to plan-making timeframes that three gateways led by assessors would introduce, especially in the context of 30 months. Therefore, the government will not be proceeding with the proposal that the first gateway requires planning authorities to seek observations or advice from an appointed person. Instead, the government intends to introduce a requirement for every planning authority to complete a prescribed self-assessment form, focused on assessing its readiness to start the plan-making process. This would constitute the first gateway.

92. We will prescribe in regulations that the completed self-assessment form must be published. Whether a planning authority has met the policy expectation to prepare and adopt their plan in 30 months will be measured from this starting point. To support planning authorities in undertaking these assessments, we will produce a toolkit of guidance and will also work with our partners the Planning Advisory Service to develop and implement a bespoke diagnostic assessment, that we will strongly encourage planning authorities to take up. Furthermore, we believe these proposals complement our intentions around PIDs (see question 7), and that a PID will be a valuable tool to help planning authorities undertake this self-assessment gateway.

93. We know from our engagement with planning authorities that getting things right during the ‘setup’ phase is critical to delivering high quality local plans quickly. Getting the right governance, project management and procurement arrangements in place from the outset will give planning authorities the best chance of preparing plans in 30 months. Early self-assessments, with a focus on readiness to begin and the ingredients for successful plan-making, will therefore add significant value to the process.

Question 20: Do you agree with our proposals for the gateway assessment process, and the scope of the key topics? Are there any other topics we should consider?

94. A total of 269 respondents answered this question. Of those, 156 (58%) agreed with the above proposal, 39 (14%) did not agree and 74 (28%) were indifferent. This indicates over half support the proposal.

Key points:

  • Most respondents agreed with the concept of gateways as a process but identified the omissions of key topics. For example, some suggested that gateway 1 should include consideration of cross-boundary / sub-regional issues, identification of housing sites and housing targets, including for different tenure types and specialist homes, and green belt assessment. A focus on housing sites was also suggested for gateway 2, as well as explicit consideration of viability. Climate change was another topic that was commonly put forward across the assessments.
  • From a process perspective, there was widespread agreement that all the gateways should be mandatory. However, some raised concerns around the use of a single day workshop and the extent to which these could genuinely resolve issues in such a short timeframe.
  • Those who disagreed with the proposed gateways process more broadly considered the risk of gateways becoming a box ticking exercise. Some suggested that to ensure accountability, third parties should be able to submit representations, which should be considered as part of the assessment process.
  • Amongst this group, it was widely considered that limiting the planning authority to five key issues would be unnecessary and cut across the aims of the gateway process.
  • Some queried how design codes would interact with gateway assessments. Specifically in relation to minerals and waste, some respondents felt that recognition that extraction of minerals and site restoration can be an enabler for the delivery of biodiversity was absent, and that gateways should consider site allocation impact on mineral availability and mineral forecasting.

Government response

95. As set out in the responses to questions 18 and 19, we will continue to develop the precise gateway assessment process, working closely with the Planning Inspectorate. Noting the wide-ranging suggestions for additional topics to be considered, we will use regulations to set broad definitions for the observations and advice that planning authorities will be required to seek through gateway 2, enabling assessors to take a reasonably flexible approach that reflects the matters most likely to affect emerging soundness and legal compliance issues. However, reflecting the discrete role of gateway 3 to check whether a plan is ready to be submitted for examination, permissible observations and advice will be more tightly defined in the regulations. Noting the feedback received, we can confirm that ensuring the plan is supported by the right evidence will be a clear part of the gateway assessments, whilst it is anticipated that an authority’s legal obligations relating to early engagement and public consultation will also be considered.

96. We will continue to reflect on the suggestions put forward to assist in the design of the gateway 1 self-assessment form, which will be designed to achieve the overall aim for this gateway to check that an planning authority is ready to start plan preparation and sets off in the right direction.

Question 21: Do you agree with our proposals to charge planning authorities for gateway assessments?

97. A total of 281 respondents answered this question. Of those, 33 (12%) agreed with the above proposal, 173 (62%) did not agree and 75 (27%) were indifferent. This indicates minimal support for the proposal.

Key points:

  • There was minimal support for the proposals to charge planning authorities for gateway assessments, with many citing the significant pressure on already overstretched planning authority budgets and the lack of opportunities to recoup the cost of gateway fees. Many highlighted the risk that funds would need to be diverted away from services directly benefitting communities as well as the day-to-day costs of preparing plans.
  • Some were concerned that any cost saving through reduced production time would be outweighed by the need to employ a dedicated programme officer, increased engagement with communities and stakeholders and digitisation of the process associated with the proposed reforms.
  • Some respondents said they would be open to charges if gateway assessments were to be recognised as a new burden by government, with funding allocated accordingly.
  • Some of the respondents that agreed with the proposal suggested that the costs would need to be considered carefully, taking into account existing planning authority funding constraints, budgeting timeframes, the current cost implications of preparing a plan and the mechanism of charging.
  • For some it was considered that costs should be proportionate to the gateway assessment stage and charged at a fixed price, whereas others felt the cost should be based on the time an inspector needed to spend on each gateway or proportionate to the size of the authority, its available funding and extent of work on the plan required.

Government response

98. The consultation proposed that, to ensure gateways are placed on a sustainable financial footing and to ensure delivery of a quality and consistent approach, the service should be fully funded through cost recovery from planning authorities, with a standard fee for each gateway defined in regulations.

99. The government recognises the financial pressures that the local government sector and its planning services are under and that any new costs could risk further exacerbating this strain. However, we believe that gateway assessments present a vital opportunity to reduce the level of risk, including financial risk, that planning authorities are currently exposed to later in the plan-making process, after most of the costs of plan preparation have been borne. By providing more professional scrutiny and support earlier in the process, time and cost should be saved later in the process when the plan reaches examination.

100. As a result of the changes to the approach set out in the government’s response to question 19, gateway 1 will no longer involve an appointed assessor. As such, in respect of the first gateway, the question of funding this process has fallen away, as there will be no fee due to a third party. Furthermore, subject to securing the appropriate funding, the government intends to initially fund diagnostic assessments to support planning authorities prepare for their self-assessment as part of its ongoing partnership with the Planning Advisory Service. This represents a significant extra benefit that planning authorities will not have to fund and represents a reduction in cost compared to the original proposal. The government will also make a significant investment to design and operate the gateway assessments delivered by the Planning Inspectorate.

101. However, to ensure the Planning Inspectorate can sustainably deliver consistent and quality advice that leads to better outcomes at examination, we currently intend to recover the costs of the second and third gateway assessments from planning authorities. We will, however, continue to explore alternative models for funding gateways that would reduce the cost burden on planning authorities, subject to securing appropriate funding. We will also work closely with the Planning Inspectorate to ensure that they are designed to be efficient, using digital technologies where possible, and based on consistent standards so that they deliver good value for money. They will be monitored closely to ensure that performance expectations are met.

102. More broadly, recognising that sufficient capacity in the planning system is essential to delivering local plans, the government is providing £46 million to provide the resource, skills, and support to deliver a well-resourced, efficient planning system. This funding will foster a pipeline of planners for the future by recruiting an additional 300 planners, to ensure planning authorities have greater capacity to adapt to new ways of working and can focus more resources on plan-making.

103. Reflecting on the feedback received for possible charging approaches, the government intends to set out in regulations a standard daily amount for the second and third gateway assessments. We intend to calculate this amount based on staffing, administration and overhead costs incurred by the Planning Inspectorate in delivering gateways. It is intended that this rate will rise in line with inflation, to ensure it remains sustainable, and that it will be reviewed in future to reflect potential future efficiencies in delivering the gateways. This will ensure that the fees charged by the Planning Inspectorate are fair and proportionate to the issues identified through the gateways and their complexity. The government commits to fully assessing possible new burdens for planning authorities as part of developing these regulations.

Chapter 7: Plan examination

Question 22: Do you agree with our proposals to speed up plan examinations? Are there additional changes that we should be considering to enable faster examinations?

104. A total of 282 respondents answered this question. Of those, 173 (61%) agreed with the proposals, 45 (16%) did not agree and 64 (23%) were indifferent. This indicates considerable support for the proposals.

Key points:

  • Overall, there was considerable support for the proposals to speed up plan examinations, limiting them to 6 months. Respondents that agreed with the proposals emphasised that the principles proposed would result in a significant reduction in the volume of material which need to be processed by the Inspector.
  • Many noted that the ambition for examinations in 6 months would only be achieved if the Planning Inspectorate is resourced adequately.
  • However, there was concern that limiting who could submit a response to an Inspector’s Matters, Issues and Questions (MIQs) would reduce the opportunity for communities and other stakeholders to be heard at examination and risks undermining the “right to be heard”.
  • Some noted that delays can frequently arise at examination as a result of new evidence emerging, or government revising national policies and guidance, and that none of the proposals would address this.
  • For respondents that did not agree with the proposals, there was a general view that only much clearer expectations of plan-makers and a more certain policy environment, set by government, will achieve faster examinations by providing greater certainty earlier in the process. Some felt the ambition would not be achieved without introducing regulations, citing the NSIP regime which has been successful in speeding up the approvals of major infrastructure. Others were clear that speed should not come at the expense of the quality of the work undertaken by Inspectors.

Government response

105. The consultation proposed that examinations of local plans and minerals and waste plans should take no longer than six months, extended by a maximum of three months if a consultation on proposed modifications to the plan is needed. Recognising that some plans can deal with particularly contentious or complex matters and can cover significant geographies, it was not proposed to set this timeframe in regulations. A range of options were proposed that, collectively, could result in time savings during examinations.

106. While at this time no decisions have been taken around whether to implement the specific proposals for improving the procedural efficiency of examinations, the Government confirms its commitment to the timeframes set out in the consultation and will continue to work with the Planning Inspectorate to design a more efficient and consistent examination process, building on the feedback received on the specific proposals set out in the consultation. We remain committed to a fair, open process in line with the Franks principles, which retains the right for third parties to be heard and provides Inspectors adequate time for matters to be scrutinised.

107. The government is clear that process improvements alone will not deliver faster examinations, and that other interventions elsewhere in the process, such as the introduction of gateway assessments and clearer national approaches to key evidence topics, will help to provide more reassurance to councils earlier that they are on the right track, reducing the range of issues which need to be dealt with at examination.

Question 23: Do you agree that six months is an adequate time for the pause period, and with the government’s expectations around how this would operate?

108. A total of 269 respondents answered this question. Of those, 125 (46%) agreed with the above proposal, 65 (24%) did not agree and 79 (29%) were indifferent. This indicates less than half support the proposal.

Key points:

  • For respondents that agreed with the proposal there was a general belief that a six month pause period would generally provide adequate time to undertake most remedial work necessary to address unforeseen circumstances that arise at examination. There was also support for the proposed discretion for Inspectors to shorten the length of the pause period to reflect the actual resource/time needs, tailored to the complexity of the issue. Some mentioned that a ‘line in the sand’ must be drawn somewhere, otherwise there is a risk that plans remain trapped in a “never ending” examination process (more akin to some recent local plan examinations in the current system).
  • Some noted that the introduction of gateway assessments should reduce the need for further work at examination but supported the flexibility of a pause period to be kept in reserve for use by Inspectors as needed.
  • For respondents that did not agree with the proposal, most believed that the maximum pause period should be identified by the Inspector, who is in the best position to identify how long it will take to put a local plan right.
  • There was some general concern that a six month cut-off might result in the failure of more plans at examination, which could represent a false economy when considered against the overall objective of increasing plan coverage. Others suggested that the government should make it clear that a pause should only be offered in defined ‘exceptional circumstances’, otherwise there is a risk that it becomes an integral part of the examination process, regardless of the situation, and that planning authorities assume a pause will be offered by the Inspector by default.

Government response

109. Having reflected on the responses, while it is noted that there was not considerable support, the government will implement the proposals set out in the consultation. We note the view of a number of respondents that the maximum length of the pause should not be defined by government and should be at the discretion of the Inspector. However, the power provided in the LURA is not broad enough to allow for this. While it is recognised that six months might, in some situations, not be sufficient to deal with all issues that arise at examination, we are clear that plans must not be submitted for examination with known major deficiencies and that the pause should generally only be used by Inspectors where a genuinely unforeseen issue emerges. This aligns with Minister of State Matthew Pennycook’s recent letter to the Chief Executive of the Planning Inspectorate, confirming that pragmatism by Inspectors in the current system should only be applied in more limited circumstances and within a timebound period of 6 months.[footnote 3]

110. Gateways assessments will also be introduced in the new plan-making system, so that more issues are addressed prior to examination, therefore the pausing of an examination for further work should be the exception, not the rule.

Chapter 8: Community engagement and consultation

Question 24: Do you agree with our proposal that planning authorities should set out their overall approach to engagement as part of their Project Initiation Document? What should this contain?

111. A total of 298 respondents answered this question. Of those, 243 (82%) agreed with the above proposal, 16 (5%) did not agree and 39 (13%) were indifferent. This indicates strong support for the proposal.

Key points:

  • The proposals for planning authorities to set out the approach to engagement in their Planning Initiation Documents (PID) was broadly welcomed. Respondents who agreed with the proposals considered they could have a positive impact on people with protected characteristics by encouraging broader participation in plan preparation. Some respondents felt that government should provide guidance on how PIDs can be used to encourage the widest possible engagement and saw a wider role for PIDs to help the public understand technical information in a more digestible way.
  • Some respondents suggested that planning authorities should receive additional resources to prepare PIDs, because public participation is extremely important for producing high quality plans.
  • Some respondents questioned how PIDs would be designed to meet the needs of those who are digitally excluded.

Government response

112. The government wants to increase the amount of engagement that takes place during plan-making and the opportunities for communities to influence their plan. We also recognise the continued importance of engaging with seldom-heard groups, including those less represented in the plan-making process. As such, we want to support authorities to reach a broader audience and manage engagement more effectively.

113. The government confirms it will proceed with the proposals set out in the consultation, drawing on the feedback and suggestions received to support the design of PIDs, including the development of guidance and flexible templates (see Question 7). Noting the specific comments raised in relation to the risk of digital exclusion, templates will be designed to be accessible, taking into account differing levels of digital literacy and access, with content made available in different formats as appropriate.

Question 25: Do you support our proposal to require planning authorities to notify relevant persons and/or bodies and invite participation, prior to commencement of the 30 month process?

114. A total of 304 respondents answered this question. Of those, 253 (83%) agreed with the above proposal, 13 (4%) did not agree and 38 (13%) were indifferent. This indicates strong support for the proposal.

Key points:

  • Most respondents agreed with the proposals to require planning authorities to notify and invite participation in the plan prior to the commencement of the 30 month process. For respondents that agreed with the proposal, there was broad consensus that early engagement offered benefits in terms of timescales, planning and ensuring that different views are heard early in the plan-making process.
  • A variety of views were expressed on how early participation should take place and how long it should last, including whether there should be a maximum timeframe for participants to respond within.
  • Other respondents suggested that the proposed ‘notify and invite’ process could result in better quality responses from different consultation bodies, with the earlier notification enabling better resource planning.
  • It was recognised that resource constraints affected the ability of local authorities and consultees to engage in a timely and effective manner.

Government response

115. The government has carefully considered the responses and, noting the strong support, will introduce the notify and invite process as set out in the consultation. The mandatory requirement to carry out a notify and invite process will be balanced by giving planning authorities the discretion to choose what the focus of early participation should be. We also confirm that we are not intending to set any minimum or maximum timescale for this process, although the intention is that it must begin no later than the point at which planning authorities give notice of their intention to commence plan-making, which itself must take place no later than 4 months prior to gateway 1.

116. To address the specific concerns raised by local authorities and stakeholders, the government will develop guidance so that different consultation bodies have a clearer understanding of their role and what is expected of them throughout the plan-making process.

Question 26: Should early participation inform the Project Initiation Document? What sorts of approaches might help to facilitate positive early participation in plan-preparation?

117. A total of 275 respondents answered this question. Of those, 203 (74%) agreed with the above proposal, 20 (7%) did not agree and 52 (19%) were indifferent. This indicates considerable support for the proposal.

Key points:

  • There was considerable support for the proposed inclusion of early participation to inform the development of PIDs, although some respondents suggested guidance would be needed to clarify which parts of the PID should be informed by early engagement.
  • There was a general view that the PID could be a helpful communication tool for distilling the key messages from early engagement, and a tool to manage expectations about what the plan can and cannot achieve.
  • Respondents that did not agree with the proposal considered that the public would not be interested in the PID and there would be little to be gained in undertaking early participation to inform it. They felt this would take time away from producing the plan in a reduced timeframe.

Government response

118. The government proposed that early participation should inform the PID, providing an important opportunity for planning authorities to test how the community would like to be engaged with in the subsequent plan-making process. The outputs of such questions could feed into the overall approach to consultation during the 30 month timeframe, which the planning authority would be expected to include in the PID.

119. In our response to question 6 of the consultation, we confirmed that we will set out, in guidance, that planning authorities should begin preparing their PID ahead of gateway 1, supported by templates made available by government. We also outlined our aim for the PID to be a genuinely useful tool that planning authorities can continue to iterate and build upon throughout the plan-making process, not just a document that is created once and not revisited.

120. While a range of views were expressed in response to this question, the considerable support for the proposal highlights a clear potential role for the PID in collating and disseminating key feedback from communities and statutory bodies collected through early engagement. It will provide an opportunity to show transparently how the early engagement process has shaped scoping activities and the overall direction of the plan. We will use guidance to set out clear expectations for how early engagement should inform the PID, in a way that does not create undue burden for planning authorities.

Question 27: Do you agree with our proposal to define more clearly what the role and purpose of the two mandatory consultation windows should be?

121. A total of 294 respondents answered this question. Of those, 240 (82%) agreed with the above proposal, 17 (6%) did not agree and 37 (13%) were indifferent. This indicates strong support for the proposal.

Key points:

  • Those in support emphasised that both the scope and the topics under discussion for each mandatory consultation should be set out nationally, together with what should be available to comment on at each stage. Some drew parallels with existing public consultation processes under regulation 18 and 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012.
  • There was a desire to avoid ‘tick box’ consultations and clearly define the purpose to help stakeholders’ understanding and increase participation, whilst also managing expectations. Others felt the proposals represented an opportunity to change the narrative around consultations, to help the public better understand the benefits of engaging positively in plan-making, while also understanding their role and purpose more clearly.
  • Some respondents that did not agree with the proposals felt that the proposed first mandatory consultation window fell too early in the process to have anything meaningful to consult on and would therefore discourage engagement, and that the second stage was too late to have any meaningful impact on plan development. Within these comments there were varying opinions on the optimum timing, structure and content of each consultation window.

Government response

122. As a result of the views expressed through the consultation, the government will implement the proposal for two mandatory consultation windows as part of the 30 month plan-making process. In response to comments about the optimum timing of these consultations, whilst the government intends to set out in regulations the order in which gateways and mandatory consultations must be undertaken, planning authorities will have discretion in precisely when these consultations take place. Furthermore, because of this feedback, we will adjust the timings of the consultation windows so that the first consultation will be a minimum of 6 weeks and the second consultation a minimum of 8 weeks. This is to ensure that planning authorities have the time and space to conduct meaningful engagement with communities and key stakeholders on the details of the plan before it is submitted for examination.

123. We confirm our intention to use secondary legislation to identify the minimum documents and information that planning authorities must publish for consultation during the two mandatory consultation windows. In response to feedback from the consultation, this will also be supported by further guidance on the broader role and purpose that government sees for the two windows, and their respective role in the context of our new emphasis on better early engagement.

124. We also intend to set out, in guidance, a strong preference that comments should be submitted in a digital/online format by default. However, this will not be a legal requirement or a blanket rule. This will empower planning authorities to utilise digital tools and methods for collecting consultation feedback with greater confidence, whilst maintaining accessibility for those with particular needs (see Question 28). This will be complemented by wider guidance which highlights the benefits of different engagement methods and best practice.

Question 28: Do you agree with our proposal to use templates to guide the form in which representations are submitted?

125. A total of 295 respondents answered this question. Of those, 228 (77%) agreed with the above proposal, 24 (8%) did not agree and 43 (15%) were indifferent. This indicates strong support for the proposal.

Key points:

  • For respondents that agreed with the proposals, there was wide recognition that moving to a more templated, digital-first approach for handling representations could simplify the way in which they are submitted and processed.
  • Some even suggested government should go further, advocating for a national portal which would allow access for both planning authorities and the Planning Inspectorate, and it was suggest that planning authorities should be given the power to be able to reject responses that do not adhere to defined standards.
  • It was also suggested that templates at the first mandatory consultation window could be less prescriptive, and those used at the second mandatory consultation window could be more prescriptive, given the differing roles of the consultation windows.
  • For respondents that did not agree with the proposal, there was concern that templates would limit planning authorities’ capacity to tailor their approach to their local context and would unnecessarily restrict communities’ and other stakeholders’ opportunities to share their views as a result of digital exclusion. Others felt that there was still a risk that people would continue to submit emails, PDF attachments or hard copies regardless of the templates provided. Skills and capacity in local government were also both highlighted as key challenges.

Government response

126. Noting the strong support for the proposals and drawing on the views expressed through the consultation, the government has begun to test the role that data standards and clear and consistent templates can play in supporting planning authorities to garner, synthesise and analyse consultation responses more efficiently. For example, we are developing guidance to assist planning authorities’ optional use of Microsoft 365 software (Power Automate) that many already have access to. This supports automatic saving of email responses submitted through consultations, saving time administrating the consultation. We hope to build on our work to date and respond to feedback that highlighted the need for a more holistic view of how consultation responses are collected and reported by planning authorities throughout the plan-making process.

127. The government also recognises that the use of digital products, tools and services alone to support consultation would unacceptably limit access to those that cannot get online or find it more difficult to navigate digital tools and services. Guidance will be used to support planning authorities in considering how they achieve a balance between different types of engagement methods through plan-making consultations.

Chapter 9: Requirement to assist with certain plan-making

Question 29: Do you have any comments on the proposed list of prescribed public bodies [for the requirement to assist]?

128. A total of 327 respondents answered this question.

Key points:

  • Respondents provided a range of suggestions relating to the proposed list of prescribed public bodies, suggesting additional bodies, groups and organisations. Additional bodies most frequently mentioned included: neighbouring planning authorities; county councils; utilities undertakers; Local Nature Partnerships; Homes England; National Highways; Historic England and Active Travel England. Some respondents highlighted that planning authorities may require support from Scottish and Welsh authorities should they be located adjacent to the border.
  • More generally, respondents frequently mentioned that more staff and resources would be required within the prescribed public bodies to assist with the plan-making process. Respondents also suggested the creation of a centralised database (directory) that could be used to identify relevant contacts within all prescribed public bodies.

Government response

129. The LURA sets out a ‘Requirement to Assist with Certain Plan Making’. This will give plan-making authorities the power to legally require that prescribed public bodies provide assistance to develop or review the plan. The government proposed to set out which organisations are within the definition of prescribed public bodies within regulations. This would also include important infrastructure providers, even if they are private utility companies, as well as other bodies of public nature.

130. Noting the feedback received, the government will review the list of prescribed public bodies set out in the consultation to explore whether additional bodies should be added, confirming a revised list in due course. Noting the specific feedback received, where the legal framework does not permit bodies to be added, for example in the case of Welsh and Scottish local authorities, the government will explore the use of guidance to highlight the importance of cross-border working and engagement.

Question 30: Do you agree with the proposed approach [to the requirement to assist with certain plan making]? If not, please comment on whether the alternative approach or another approach is preferable and why?

131. A total of 268 respondents answered this question. Of those, 186 (69%) agreed with the proposal, 16 (6%) did not agree and 66 (25%) were indifferent. This indicates considerable support for the proposal.

Key points:

  • There was considerable support for the proposed approach to the requirement to assist with certain plan-making. Respondents that agreed with the proposals stated that the approach was positive, and that clarity over how other agencies should engage in supporting the plan-making process would be welcomed.
  • A key point raised by respondents related to the adequacy of resources available in the prescribed bodies and a lack of clarity about the implications if requests were not properly responded to. One question raised by a small number of respondents related to the impact of the requirement to assist on the 30-month plan-making timescale.
  • Some respondents that did not agree with the proposal highlighted the need for sufficient engagement from environmental conservation organisations – it was felt that they are not sufficiently involved at the earliest stages of plan-making to ensure that environmental impacts are properly considered.
  • Respondents raised questions around the consequences of the prescribed list of public bodies failing to respond appropriately in a timely manner or in the quantity or quality of work they would undertake.

Government response

132. Following the consultation, we intend to implement the requirement to assist, as set out within the consultation document. There will be further development of the procedure to be followed for the request for assistance, so that it is a tool that is used appropriately and only when necessary. This procedure would support the prescribed public bodies in managing requests for their assistance and create standardisation in the process of making and responding to such requests.

133. While powers in the LURA do not extend to creating bespoke compliance mechanisms for prescribed public bodies to meet the Requirement to Assist, prescribed public bodies would be under a legal duty to provide assistance where a plan-making authority notifies them that this is required. The government expects prescribed public bodies to comply with their legal obligations in accordance with the legislative framework.

Chapter 10: Monitoring of plans

Question 31: Do you agree with the proposed requirements for monitoring?

134. A total of 292 respondents answered this question. Of those, 209 (72%) agreed with the above proposal, 25 (9%) did not agree and 58 (20%) were indifferent. This indicates considerable support for the proposal.

Key points:

  • For respondents that agreed with the proposal, there was broad support for both the annual light touch report and full review in year four. Respondents sought clarity on the consequences if reports are not published in time by local planning authorities and emphasised there should be fixed deadlines for reports to be released that are enforced.
  • Respondents also sought clarity on what the implications would be if plans are not performing as intended. Furthermore, there was strong support for the monitoring reports to be templated.
  • For respondents that did not agree with the proposal, the most common concern was around the proposal for annual reports to be prepared on the anniversary of the plan, with most preferring a fixed date nationally that all local planning authorities would need to adhere to. Others highlighted the importance of aligning with other data reporting requirements across government, notably the Housing Flows Reconciliation.[footnote 4]
  • Respondents also suggested there need to be specific mechanisms in place to prompt actions on the outcomes of monitoring reports.

Government response

135. Noting the considerable support expressed through the consultation, the government will implement the proposals for planning authorities to undertake annual monitoring against a nationally prescribed set of metrics. In response to feedback and to achieve a consistent and comparable dataset to identify trends over time, annual monitoring reports will be required to be published by a fixed date annually. It is proposed that these annual monitoring reports shall also incorporate locally identified measurable objectives that are identified in the preparation of the local plan vision.

136. In response to comments supporting the use of templates and to enable data analysis, it is intended that a data standard shall be prepared to template and standardise the form in which this data is prepared and published. Planning authorities would be required to comply with this data standard.

137. The provisions in the LURA do not extend to imposing consequences where a planning authority fails to comply with its monitoring obligations, nor provide a power for the creation of a bespoke enforcement mechanism. However, the regulations will place a legal duty on planning authorities to adhere to the requirements, and the government expects them to do so. Planning authorities will be supported with guidance and templates to meet this requirement.

138. Through the annual monitoring report, every planning authority shall provide a short narrative on the implementation of the policies in its plan, including progress against the vision in the plan. While there will not be direct plan-making implications for plans that are not performing as intended, regular and consistent reporting will mean that this is more readily identified. It could also enable planning authorities to take proactive steps to address this through decision-making and other plan-making steps such as the creation of Supplementary Plans or the early preparation of their next local plan.

139. The government confirms it does not intend to require planning authorities, through their annual monitoring reports, to report on progress against plan-making activities in their local plan timetable or minerals and waste plan timetable. This is deemed unnecessary given the requirement for local plan timetables to be maintained (kept up to date), and the intended requirement for planning authorities to maintain a record of updates that have been made, so that there is a retrospective record of performance. (See Chapter 4 for further details).

140. There was broad support for a more detailed four yearly evaluation, and this stage will therefore be a mechanism to evaluate the effectiveness of the implementation of the policies in local plans and minerals and waste plans. This approach will create a structure to prompt and support the creation of the next plan, focused on what has worked well and where further policy development is necessary. This will be particularly important where a plan has not been performing as intended and where steps need to be taken to address this in the next plan. Given that policies will be locally specific, it is not proposed that the year four plan evaluation report is rigidly templated, but guidance will set out the approach a planning authority should use when preparing this report.

Question 32: Do you agree with the proposed metrics? Do you think there are any other metrics which planning authorities should be required to report on?

141. A total of 260 respondents answered this question. Of those, 162 (62%) agreed with the above proposal, 31 (12%) did not agree and 67 (26%) were indifferent. This indicates considerable support for the proposal.

Key points:

  • Overall, there was considerable support for the concept of a focused set of key metrics established by government, however many suggestions were put forward for additional metrics or further detail that should be captured. Suggestions included metrics pertaining to: housing size, mix, tenure; employment type and land values; development on green belt land; social economic and health indicators; agricultural land; and collection and spending of S106 and community infrastructure levy (CIL). Several respondents also requested more detail and clarity around how local plan monitoring would interact with monitoring requirements for Environmental Outcome Reports.
  • There was also support for planning authorities to have the flexibility to include additional indicators that suit their local circumstances.
  • There was some concern around how feasible it would be for councils to report accurately on certain metrics where changes can take place outside the planning system. For example, employment floorspace changes in the context of the flexible Class E use class, or net change in affordable housing units where there is a significant interaction with the Right to Buy.
  • For respondents that did not agree with the proposal, the predominant view was that the proposed metrics should be left for the planning authority to determine.

Government response

142. To ensure clarity and simplification of monitoring plan policies in the new system, the consultation proposed a requirement for planning authorities to report against a small set of nationally prescribed metrics, supporting a more consistent and streamlined approach. 15 metrics were proposed across six thematic areas. We also proposed that planning authorities should monitor against the success of implementing their specific vision for the local plan or minerals and waste plan.

143. Given the considerable support, the government will move ahead with its proposals to introduce a focused set of national metrics that planning authorities must measure, whilst retaining flexibility for planning authorities to establish and monitor locally identified metrics, linked to the vision established in their plan. However, having considered the suggestions made, we will make some adjustments to the metrics to ensure monitoring activities are feasible, genuinely useful and give planning authorities, and wider stakeholders, a good understanding of how a local plan is performing. In reviewing the suggestions put forward, we considered: the proportionality of the request (including whether planning authorities are likely to be able to obtain the information “in-house”, rather than needing to buy in consultancy support); overlaps with other monitoring regimes and the responsibilities of other bodies and agencies; and the extent to which the metric genuinely pertains to or could be influenced by a plan, as opposed to another part of the planning system or another regulatory regimes.

144. As a result, we intend to include:

  • an expanded range of metrics on housing, including specific metrics on housing approvals and five year housing land supply position, and more detail around typologies, tenures and delivery on rural exception sites;
  • more nuanced metrics on employment floorspace, reflecting the feedback received through the consultation, focused on employment floorspace creation and the overall land supply position;
  • and a specific metric on the creation of local infrastructure, which could, for example, track the delivery of transport schemes or educational facilities.

145. We also intend to revise several metrics in response to feedback received through the consultation, including amending the affordable housing metric to measure delivery, as opposed to net change, which feedback indicated would be challenging for planning authorities to measure.

146. We will continue to work closely with key stakeholders to refine the reporting metrics to ensure they capture a holistic view of plan performance and the impacts of plans on the wider built and natural environment. We will also ensure that monitoring requirements remain proportionate, achievable for planning authorities and that any duplication across reporting regimes is minimised.

Chapter 11: Supplementary plans

Question 33: Do you agree with the suggested factors which could be taken into consideration when assessing whether two or more sites are ‘nearby’ to each other? Are there any other factors that would indicate whether two or more sites are ‘nearby’ to each other?

147. A total of 234 respondents answered yes/no/indifferent to this question. Of those, 108 (46%) agreed with the above proposal, 51 (22%) did not agree and 75 (32%) were indifferent. This indicates about half of respondents support the proposal.

Key points:

  • For respondents that agreed with the proposal, they supported the principle and welcomed the flexibility for planning authorities to apply their own judgement to this matter, whereas some considered ‘nearby’ needed to be defined or for a ‘clear and quantifiable test’ to be applied to ensure a consistent approach.
  • For respondents that did not agree with the proposal, they did not see the purpose of restricting sites to be ‘nearby’ one another as there could be lots of reasons to group sites together.
  • Many respondents suggested that sites with ‘shared characteristics’ and ‘functional relationships’ would be more appropriate criteria than sites ‘nearby’ to each other.

Government response

148. The LURA provides for the creation of new supplementary plans. The Act sets out that supplementary plans prepared by planning authorities may contain any subject matter which may be in a local plan or minerals and waste plan, but must be site specific or relate to two or more sites which an authority consider to be ‘nearby’ to each other; except for design related supplementary plans which may be authority area wide.

149. Our consultation set out suggested factors which could be taken into consideration when assessing whether two or more sites are ‘nearby’ to each other. These included: geographical distance between sites; relationship to sites in other similar sized settlements or neighbourhoods in the authority area, or for the delivery of planning obligations.

150. The government will set out, in guidance, factors to support plan-makers determine whether they consider sites to be ‘nearby’ to each other, acknowledging that authorities should have flexibility on this matter, to reflect local circumstances. Whilst the government cannot be more definitive in the regulations, the guidance will support plan-makers to apply their judgement, and the supplementary plan examination process will test whether the plan-maker has had regard to the guidance. We will also explore the suggestions put forward to broaden the permissible scope of multi-site supplementary plans to encompass ‘functional relationships’ or “shared characteristics”.

Question 34: What preparation procedures would be helpful, or unhelpful, to prescribe for supplementary plans? e.g. Design: design review and engagement event; large sites: masterplan engagement, etc.

151. A total of 283 respondents answered this question.

Key points:

  • For respondents that agreed that different preparation procedures may be suitable for different types of supplementary plans, the majority advocated for minimal prescription of preparation procedures, and that these should be kept general and not topic specific. They considered that this should be supported by guidance and tools offering best practice of preparation procedures for different types/topics of supplementary plan.
  • Responses widely proposed that the minimal prescription of preparation procedures also be light touch. They should be clear, unambiguous and consistent, regardless of the topic of supplementary plans, and should be centred on minimum requirements and legal compliance e.g. include prescription of minimum consultation procedures, environmental screening and masterplanning for large sites etc.
  • In relation to consultation procedures, it was suggested that this could include setting out when more than one formal consultation is required, the minimum length of consultation and any specific bodies to be consulted.
  • In relation to environmental screening, it was suggested that a template be provided, much like the approach taken locally for neighbourhood plans.

Government response

152. The LURA allows for regulations to make provision about the preparation, withdrawal, or revision of supplementary plans. Given the possible diversity and flexibility of supplementary plans, different preparation procedures may be suitable for different types of supplementary plans.

153. Depending on the content, supplementary plans may be subject to Strategic Environmental Assessment obligations. We expect planning authorities to use an environmental screening approach for supplementary plans similar to that used for neighbourhood plans.

154. The government will be continuing with the direction of travel and principles set out within the consultation document. We will use regulations minimally but consistently, to provide a framework for the preparation of supplementary plans with supporting guidance and may provide templates. We intend that regulations will include requirements for supplementary plan-making authorities to:

  • prepare and publish a supplementary plan commencement notice, which will contain details including the area to which the supplementary plan will apply.
  • carry out a minimum of one formal consultation stage with communities and stakeholders, including appropriate general and specific consultation bodies, for a period of no less than 6 weeks. However, it will be at the discretion of the supplementary plan-making authority to decide and publicise at which point during the plan preparation this will take place. Through guidance, we will encourage earlier consultation, appropriate to the topic of the supplementary plan, and further consultation where there are substantial unresolved objections prior to examination of a plan or where there are contentious matters.
  • prepare a statement of representations procedure which will contain details including how, where and when representations can be received and how requests for notification of examination stages can be made.
  • prepare a Supplementary Plan Policies Map which reflects the area covered by the supplementary plan, unless the supplementary plan is to be an authority-wide design code.
  • publish its Statement of Compliance, which must, as a minimum, explain how the proposed supplementary plan meets the requirements of the legislation.

Question 35: Do you agree that a single formal stage of consultation is considered sufficient for a supplementary plan? If not, in what circumstances would be more formal consultation stages be required?

155. A total of 277 respondents answered yes/no/indifferent to this question. Of those, 165 (60%) agreed with the above proposal, 51 (18%) did not agree and 61(22%) were indifferent. This indicates considerable support for the proposal.

Key points:

  • The majority of responses supported the proposal for a single, formal consultation to enable a swift response to unanticipated plan-making needs.
  • The majority of responses considered that where a supplementary plan may benefit from informal or focussed engagement then this should not be prescribed but encouraged. This will allow planning authorities to develop engagement plans as appropriate and proportionate to the role of the plan e.g. where significant issues are raised during any stage of the engagement process.
  • Responses suggested that, to ensure robustness of a single formal consultation, guidance and best practice should be clear on what ‘good’ engagement looks like. Some respondents who were unsure whether they supported the proposal suggested that stakeholders should be able to review any response to the initial consultation and should have the opportunity for further comment. This, however, may be carried out in an expedited manner, rather than requiring a whole additional consultation stage.
  • Responses suggested further consultation (not necessarily formal) in the following circumstances: complex regeneration sites; design codes; allocation of major new sites; modifications at examination stage; masterplans covering large areas with mixed uses; and infrastructure schemes.

Government response

156. Supplementary plans will undergo formal consultation with communities and stakeholders, including statutory bodies and independent examination. A key objective for planning reform is to enhance opportunities for public involvement, which includes where planning authorities are creating policies on additional matters not covered in their local plan. The government remains committed to supporting planning authorities on plan-making engagement and we intend to set out in guidance that informal engagement will be encouraged throughout the supplementary plan-making process.

157. The government will be continuing with the direction of travel and principles set out within the consultation document, which had broad support. Namely, that a single formal consultation for supplementary plans is sufficient for plans to be prepared at pace between local plan cycles. The government intends to set out in regulations that the timeframe for the single formal consultation must be no less than 6 weeks. However, guidance will encourage on-going informal consultation and engagement, particularly focussed on the early stages of plan preparation, where appropriate to the topic of the plan being prepared.

Question: 36 Should government set thresholds to guide the decision that authorities make about the choice of supplementary plan examination routes? If so, what thresholds would be most helpful? For example, minimum size of development planned for, which could be quantitative both in terms of land use and spatial coverage; level of interaction of proposal with sensitive designations, such as environmental or heritage.

158. A total of 249 respondents answered yes/no/indifferent to this question. Of those, 105 (43%) agreed with the above proposal, 72 (29%) did not agree and 72 (29%) were indifferent. This indicates that less than half support for the proposal.

Key points:

  • Respondents that agreed with the proposal suggested that any site specific supplementary plans which relate to sites that are in public ownership or subject to a wider public service transformation plan produced by a public body, should be subject to examination by a person appointed by the Secretary of State. Some respondents state that local authorities are best placed to define thresholds for a ‘large or complex site’.
  • Respondents also proposed that more complex supplementary plans should need to be submitted to the Secretary of State for examination, citing examples including: joint plans; site specific supplementary plan for large/strategic sites (500+ dwellings); demonstrable impact on community, infrastructure, heritage and natural assets; or where an objection is received from a statutory consultee.
  • Some respondents considered that either the Planning Inspectorate or another organisation should decide which examiner route should be pursued, to ensure objectivity in the process. Concerns were raised about possible perception of bias or conflict of interest if planning authorities decide who to appoint to examine a plan that the planning authority has prepared. Concerns were raised about length of examination extending the plan development period, and the impact on both financial and staff resources.

Government response

159. As set out in the consultation, the government were keen to hear views on whether we should set thresholds to guide the decision that authorities make about the choice of which supplementary plan examination route to follow. There was support for the proposed examiner options and clear thresholds to be set in guidance, so that there is some flexibility. The LURA allows plan-makers to choose their supplementary plan examination route. We will proceed as proposed by setting out in guidance factors, such as the complexity of the policy proposal, for planning authorities to consider when deciding which route may be most appropriate for their supplementary plans when taking into account the nature, sensitivity and impact of the plan proposal.

*Question: 37 Do you agree that the approach set out above provides a proportionate basis for the independent examination of supplementary plans? If not, what policy or regulatory measures would ensure this?

160. A total of 245 respondents answered yes/no/indifferent to this question. Of those, 132 (54%) agreed with the above proposal, 42 (17%) did not agree and 71(29%) were indifferent. This indicates considerable support for the proposal.

Key points:

  • Overall, there was significant support for the approach set out for the independent examination of supplementary plans. Respondents that agreed with the proposal stated that the proposed approach of streamlined examinations should provide proportionate scrutiny of supplementary plans.
  • Some planning authority respondents also suggested the following criteria could be added: the contribution of supplementary plans to the principle of sustainable development; supplementary plans must have regard to the NPPF and national development management policies; environmental screening, to ensure this has been robustly considered in the process and an Environmental Outcomes Report is prepared if necessary; Local Nature Recovery Sites, and climate change mitigation and adaptation. Some respondents considered that supplementary plans should also be subject to tests of soundness.
  • For respondents who were unsure about the proposals, many raised concerns that the reference to sites being ‘nearby’ to each other is unclear and unsatisfactory, ambiguous and open to interpretation – and inappropriate for inclusion in this otherwise consistent list of considerations that could equally apply to other development plans.

Government response

161. The government set out in the consultation that under the LURA an examiner cannot recommend that a supplementary plan is adopted until they consider that the relevant procedural requirements have been met. We also proposed to set out in regulations a requirement for plan-making authorities to prepare a statement for the examiner setting out how their plan has addressed the points within the consultation document to ensure clarity for the examiner and interested parties.

162. There was considerable support for the approach set out for independent examination of supplementary plans. The consultation responses mostly supported the approach and considered that it provided an appropriate level of scrutiny.

163. Although some respondents were concerned about the requirement for sites to be ‘nearby’ to each other, the LURA sets out an explicit requirement for certain supplementary requires that for supplementary plans dealing with certain matters[footnote 5] which relate to two or more specific sites, the authority must consider those sites to be nearby to each other. As set out in our response to question 33 above, guidance will be provided to support plan-makers to apply their judgement and to evidence this in their statement of compliance.

164. Given the significant support, government is confident that the proposed approach provides a proportionate basis for the independent examination of supplementary plans. We will set out in regulations that plan-making authorities must provide a statement of compliance which must, as a minimum, explain how the proposed supplementary plan meets the statutory requirements, including:

  • to have regard to national policies and guidance
  • that the supplementary plan must not be inconsistent with or (in substance) repeat any national development management policy
  • and, so far as the relevant plan-making authority consider appropriate, having regard to the subject matter of the supplementary plan, the plan must be designed to secure that the development and use of land in the authority’s area contribute to the mitigation of, and adaptation to, climate change, and take account of any relevant local nature recovery strategy.

Chapter 12: Minerals and waste plans

Question 38: Are there any unique challenges facing the preparation of minerals and waste plans which we should consider in developing the approach to implement the new plan-making system?

165. A total of 170 respondents answered this question.

Key points:

  • A number of respondents representing planning authorities highlighted that minerals and waste plans should be consistent with local plans.
  • Many respondents explained that minerals and waste plans are more strategic and cross-boundary in comparison to local plans as minerals can only be worked where they are found, and waste facilities often serve areas outside of the authority boundary. This can mean that approvals are needed from a greater number of parties which can result in delays, making the 30-month timescale challenging.
  • Another key point raised was that the lack of resource and expertise experienced in planning authorities is an even greater problem for minerals and waste planning, as it requires specialist knowledge. This can also lead to delays and costs. Many respondents expressed support for the ability to prepare joint plans as this will alleviate some of these pressures, allowing authorities to pool resources.
  • Many respondents suggest that housing and employment development can often be given priority over minerals and waste development, and that communities are often more likely to be opposed to the latter. Existing guidance for authorities also focuses on housing, therefore specific guidance on minerals and waste plans would be helpful.
  • Some respondents suggested that reliable and consistent data can be difficult to obtain for minerals and waste. The guidelines for aggregate provision being out of date also makes it difficult to plan, and some emphasised the need for them to be updated.

Government response

166. Minerals and waste plans will continue to form an important part of the development plan under the reformed system. The LURA requires each minerals and waste planning authority to prepare “one or more documents which are to be known collectively as the minerals and waste plan”. This will continue to enable minerals and waste plans to be produced.

167. The consultation allowed the government to hear a range of views in response to this proposal and respondents highlighted a number of unique challenges facing the preparation of minerals and waste plans. The first main issue raised was that minerals and waste plans require more strategic consideration than local plans due to the cross-boundary nature of minerals and waste. The approvals and engagement processes then become more challenging as a greater number of parties need to reach consensus and a greater number of communities may be affected by developments. Many respondents recognised the value of the government-funded Aggregate Working Parties who work at a regional level to monitor the Managed Aggregate Supply system and some suggested that funding should be given to Waste Technical Advisory Boards to account for the cross-boundary nature of waste planning.

168. Secondly, many respondents acknowledged that resourcing and skills issues present a challenge across planning in general, however, they explained that this has been particularly difficult for minerals and waste planning as it requires specialist knowledge and is often considered a less desirable area to work in than mainstream planning. Some respondents highlighted the benefits of being able to work on joint plans to pool limited resources.

169. Thirdly, respondents explained that obtaining reliable minerals and waste data is difficult and this often results in authorities not being able to accurately assess and plan for the supply and demand of minerals and waste management facilities. One of the key reasons for this is that surveys which seek to gather data on minerals and waste resources are voluntary and often have low response rates. Some respondents suggested that reinstatement of mandatory surveys like the Annual Raised Minerals Inquiry (AMRI) and an update to the guidelines for aggregate provision would help with forecasting/planning for minerals.

170. Finally, respondents highlighted that minerals and waste development and planning is often overlooked in favour of housing or employment. Minerals and waste development is perceived by some as less valuable and is therefore deprioritised in planning and this perception also results in local communities opposing minerals and waste developments more than other types. There is also a lack of minerals and waste specific plan-making guidance. Related to this, in relation to standardised national development management policies, many respondents were in favour of minerals and waste being included but flagged that due to the development impacts specific to minerals and waste, there would either need to be a separate minerals and waste National Development Management Policy or enough flexibility in the main set for these specific issues to be captured.

171. Many respondents agreed that some or all these challenges will make meeting the 30 month timescale difficult for many authorities.

172. Following the consultation, we will be continuing with the direction of travel and principles set out within the consultation document for new style minerals and waste plans, however we will seek to identify solutions to address the unique challenges raised as we develop the detail to support our proposals.

Chapter 13: Community Land Auctions

Question 39: Do you have any views on how we envisage the Community Land Auctions process would operate?

173. A total of 329 respondents answered this question.

Key points:

  • Many respondents thought that the Community Land Auctions (CLAs) proposals were too complex. Several respondents also set out that further information and clarity is required on the CLA proposals.
  • Respondents who agreed with the proposals considered the CLA proposals an interesting concept and would potentially be welcomed as an additional mechanism to capture land value uplift and should be explored further.
  • For those respondents who disagreed with the proposals, they raised concerns that less sustainable land would come through the planning system and less land overall would come forward as part of the CLA approach. They also raised concerns over the presentational risks that financial benefits could give rise to the buying and selling of planning permissions/allocations, and that the consideration of financial benefits should not be the only factor.
  • Overall, many respondents raised that there will be planning authority capacity issues in operating this novel approach, and that MHCLG should provide additional (financial) support.

Government response

174. The consultation allowed the government to hear a range of views in relation to time-limited pilots of CLAs. Overall, there was a mixed response to the proposals, with many respondents highlighting that further clarity and information in relation to the CLA proposals were needed because they were too complex. Even those respondents who welcomed CLAs as an interesting proposal to capture land value uplift requested further information about how the mechanism would operate in practice.

175. Several respondents were concerned that there would be gaming or collusion in the CLA process, and that it would allow less sustainable land to come forward into the planning system. A number of respondents who agreed with the proposal nevertheless expressed a view that financial benefits should not be the sole factor taken into account when assessing land through the CLA process.

176. It is the government’s considered view that CLAs are likely to be unworkable in practice. The realities of the land market in England bear little relation to the arrangements required for the approach to operate successfully, namely small and substitutable land parcels with multiple landowners. Where such arrangements do exist, CLAs are likely only to be attractive proposition in areas with significant housing demand and high land values, in all likelihood on greenfield land rather than more complex brownfield sites. Finally, it remains unclear how auctions will drive down land prices in the absence of any element of compulsion.

177. As such, the government believes that the best way to deliver the social and affordable housing local communities need and the wider infrastructure that will mitigate the impacts of new development is by focussing on improving the existing system of developer contributions. Therefore, the government does not intend to implement CLAs, as introduced in the LURA. We will repeal the relevant provisions in Part 5 of the LURA in due course.

Question 40: To what extent should financial considerations be taken into account by local planning authorities in Community Land Auction pilots, when deciding to allocate sites in the local plan, and how should this be balanced against other factors?

178. A total of 295 respondents answered this question.

Key points:

  • Several respondents considered that financial considerations should be given no weight in the planning process, with many requesting further information on the CLAs proposals.
  • Some respondents who agreed with the proposals were of the opinion that ‘typical planning matters’ such as environmental, social, and economic impacts (including long-term sustainability) should be given primacy.
  • For respondents who disagreed with the proposals they were concerned of the presentational risks of the consideration of financial benefit in relation to the local planning authority and the wider planning system. Conversely, some commented that financial considerations should be prioritised when allocating sites in the local plan.

Government response

179. The consultation allowed the government to hear a range of views in response to this proposal and many respondents highlighted that financial considerations should be given little to no weight in the planning process. However, some respondents were of the opinion that financial considerations could be given appropriate weight in the process.

180. For those respondents who agreed with the proposals they requested further information on the CLA proposals (with some noting that a consultation on CLA regulations is forthcoming). They also considered that ‘typical planning matters’ such as sustainability of development, transport matters, and infrastructure requirements should take primacy over financial considerations. Respondents believed that clear guidance and/or regulations will be required for CLA arrangements.

181. Overall, respondents thought that financial considerations created uncertainty and complexity. Many were concerned of the presentational risks of the consideration of financial benefit in relation to local planning authorities and the wider planning system.

182. As set out in the response to question 39 above, the government does not intend to implement Community Land Auctions, as introduced in the Levelling-up and Regeneration Act 2023, and intends to repeal these provisions in due course.

Chapter 14: Approach to rollout and transition

Question 41: Which of these options should be implemented, and why? Are there any alternative options that we should be considering?

183. A total of 296 respondents answered this question.

Key points:

  • There was broad support for a small cohort of ‘front runners’, and an understanding of the need for a phased rollout. Some respondents felt that it would be important to ensure there is a broad range of front runner authorities, including minerals and waste planning authorities and unitary authorities, and that they should have sufficient support and guidance provided.
  • In terms of the phased rollout, there was concern that having to wait for a commencement window would go against a local area’s ability to make their own decisions on commencing plan-making and that an authority should not be held back from bringing a plan forward. Some respondents felt that waves might not reflect wider drivers for needing to get a plan in place, including for those areas of major change or infrastructure delivery. It was also felt that roll out in waves would be too slow and would not lead to universal plan coverage for many years.
  • Some respondents suggested that regulations, policy, and guidance should be in place at a sufficiently early stage to allow transition with confidence. Others felt that government should make clear what preparatory plan-making activities can take place ahead of the new system coming into effect.
  • Some respondents welcomed the principle of improving capability and capacity in planning authorities but expressed concern that the measures would not deliver a comprehensive improvement in the sector in the short term.

Government response

184. This section should be read in conjunction with government’s August 2024 consultation on the National Planning Policy Framework and other changes to the planning system, and its recent response (December 2024)[footnote 6], which set out the government’s expectations for local plans that are already in development in the current system and the government’s intention to implement the new plan-making system in 2025.

185. Noting the feedback received through the consultation, we confirm our intention to make available as much information as possible to plan-makers ahead of implementing the new system. This will include a reasonable familiarisation period to enable planning authorities to undertake early preparatory and scoping work ahead of formally commencing plan-making. We are prioritising the delivery of guidance, tools and templates for plan-makers based on when these will be needed during the plan preparation period.

186. With regard to the specific rollout options proposed, given the government’s ambition of achieving up-to-date universal plan coverage as soon as possible, we do not intend to proceed with the proposals to identify frontrunner authorities. Instead, we intend to provide tailored support to authorities that bring a plan forward early in the new system and to share their learning and best practice with other authorities.

187. We will develop more definitive proposals for a phased rollout of local plans, and we intend to publish further details in spring 2025. These proposals will consider the key practical challenges raised through this consultation, whilst reflecting this government’s ambitions for rapid progress towards universal plan coverage and the promotion of a more strategic approach to planning.

Chapter 15: Saving existing plans and planning documents

Question 42: Do you agree with our proposals for saving existing plans and planning documents? If not, why?

188. A total of 261 respondents answered yes/no/indifferent to this question. Of those, 207 (79%) agreed with the above proposal, 23 (9%) did not agree and 31 (12%) were indifferent. This indicates strong support for the proposal.

Key points:

  • Respondents broadly recognised the importance of saving existing documents for a transitional period to avoid the creation of a policy vacuum.
  • Some respondents raised concerns about authorities retaining documents indefinitely and called on government to encourage the preparation of new style local plans as quickly as possible once the new legislation is in force.

Government response

189. We will take forward the proposal to allow existing development plan documents and saved policies to remain in force until the planning authority adopt a new style local plan or mineral and waste plan.

190. We also confirm our intention that Statements of Community Involvement and Local Development Schemes will also remain in force where they relate to emerging ‘old-style’ local plans, until those plans are adopted.

191. In line with our proposal in Chapter 11, Supplementary Planning Documents (SPDs) will remain in force until planning authorities adopt a new style local plan or minerals and waste plan. In response to requests for more clarity on SPD transition, we intend to set out further details in spring 2025, as part of proposals on rolling out the new plan-making system.