Careers Advice: Justifying a local plan housing requirement and ensuring sufficient allocations

Written by: Jon Palmer
Published On: 13 Oct 2017

Bramley housing plan

Identifying the objectively-assessed need (OAN) for housing has been one of the most challenging issues faced by planners involved in preparing local plans over the last few years. This is set to become simpler with the Government's proposed OAN methodology. However, it will only be part of the equation and policy planners in many locations may still need to justify a different local plan housing requirement, whilst ensuring there are sufficient deliverable housing allocations to meet this figure.

The East Riding Local Plan seeks to support housing-led regeneration and investment activity in the city of Hull. It resulted in a housing requirement that was lower than the OAN figure for the East Riding alone, which attracted a considerable level of challenge through the examination in public. This was addressed through:

  • Focusing on the agreed strategic priorities for the authorities in the combined housing market area, setting out the shared outcomes and involving elected members throughout the process. A Hull and East Riding Joint Planning Statement was agreed by the Cabinets of both councils setting out the split in housing numbers between the two authorities.

  • Preparing a joint / aligned evidence base with policy implications outlined clearly in joint background papers, which helped to explain and justify the approach in a clear and consistent manner. The key issue here is avoiding gaps or inconsistencies which can be exposed through examination.

However, many objections still related to site specific considerations which needed to be explored and answered. Aligning work on the Strategy and Allocations made the Local Plan process easier to explain which was aided by adopting a site assessment methodology (SAM) for assessing all sites. This was valuable, both for community consultation and in terms of responding to objections through the examination, in helping to clearly show the choices available and the most suitable options. The East Riding Local Plan inspector recognised that "the SAM represents a quite sophisticated and detailed methodology for analysing the sustainability credentials of sites for allocation." It resulted in a significant and robust body of evidence used to inform site selection and recognised that:

  • Integrating the SAM within the Sustainability Appraisals (SA) process improved the rigour of the site selection process. The site assessments also helped to provide the content for the SA report.

  • Applying a site size threshold for allocations helped to ensure the site assessment process was applied in a pragmatic and proportionate manner. There were over 2,000 sites (above 0.17ha) considered for allocation through the local plan and preparing full assessments for all smaller sites would have impacted on the timely progress of the plan.

  • Professional opinion needs to be applied for several issues that require a value judgement. Whilst such judgements tend to generate the majority of objections, it is important to recognise that selecting site allocations is not a wholly mechanistic or scientific process.

  • Undertaking an early 'fact check' consultation with the site promoter on the draft assessment allows all relevant sources of evidence to be identified and agreed prior to undertaking public consultation. This also presents the opportunity to confirm the deliverability of sites.

Jon Palmer is planning policy manager at East Riding of Yorkshire Council