Contents

• Hope before experience?
• Redrawing the map
• Summary

Hope before experience?

Local planning authorities (LPAs) in England are required to update their Local Plans every five years. In preparation, many LPAs prepared Local Development Schemes, essentially a roadmap for the process of adopting a new Local Plan.

Over six out of ten LPAs have published some kind of Local Development Scheme, with 190 having a target date for adoption of a new Local Plan by 2030 and most aiming to do so by mid-2028.

How credible are these timelines? Evidence from the past five years suggests that, from the point of publishing a Regulation 19 plan, it takes around two years and eight months, on average, to reach adoption of the new plan. This average hides a great deal of variation: actual timelines can run from a little over a year to well over seven years.

Analysing available Local Development Schemes, LPAs, on average, believe they will be able to progress from Regulation 19 to adoption very quickly, at just over a year and a half. This seems challenging given the need to meet much higher housing need targets, provide the evidence base, and the volume of emerging plans that will be going through the examination process at the same time.

A sign of this optimism can be found at the higher range of estimates. Historically, timeframes of three to four years are by no means that rare, with 15% of adopted plans in the period since 2020 taking over four years to progress from Regulation 19 to adoption. Yet the longest any LPA currently estimates it will take them to advance a plan is just over two and a half years.

Unless there are alterations in the approach to the evidence base and resourcing, this suggests that the process of adopting new plans will be slower than currently anticipated by many LPAs, with knock-on consequences for housing targets and delivery.

Redrawing the map

Further complications could be introduced by the transition to a more strategic system. The Government announced ambitious plans for reorganising local government in England in December 2024. These changes will have a considerable effect on who plans for development and where. It is vital that changes to plan-making responsibilities are delivered in a rational and consistent manner, or they risk disrupting and delaying the Government’s wider efforts for planning and housebuilding.

At present, much of England is covered by overlapping units of local government, with an upper tier (counties) and a lower tier (districts/boroughs). Following similar reform in Scotland, Wales and Northern Ireland, the Government intends to abolish the upper tier of counties and adopt a single tier of “principal authorities” across England. Alongside this, we currently predict that the anticipated wave of mergers will reduce the number of principal authorities by over 40%, from 296 at present to circa 170. These will be of the most interest to the property sector because they will become the future LPAs, and hence decision decision-makers as early as May 2027 in some areas.

In addition to this, the Government is also keen to establish combined authorities. Many combined authorities already exist, especially across urban England, with varying structures and powers. The Government aims to introduce a more standardised system. Each combined authority will be headed by an elected mayor with a set of devolved powers. Importantly, these authorities will be responsible for strategic plan-making in the form of production of Spatial Development Strategies (SDS).  This function already exists in Greater London, with the Mayor responsible for the production of the London Plan (which is currently under review).

The combined authority should have:

• A combined population of at least 1.5 million
• Coherent economic geography
• Alignment with other public sector boundaries

Six areas are on the “fast track” for a devolution settlement, which means they should be in place by May 2027 – Cumbria, Cheshire and Warrington, Norfolk and Suffolk, Greater Essex, Hampshire and the Solent, and Sussex and Brighton. In the long run, all local government areas within England will be covered by a combined authority.

Planning for areas larger than districts/boroughs already occurs in some places. 30% of local authorities already have a joint Local Plan with at least one other authority (though in some places, this accounts for joint arrangements with a National Park, for example, in the South Downs).

These allow for greater cooperation over planning, potentially enabling more sustainable patterns of development, but also require considerable effort and goodwill to achieve and maintain. Perhaps not coincidentally, fewer than a third of joint Local Plans are currently up to date, exemplifying the present challenges over the duty to cooperate.

Reform of both local government and the planning system is key to the Government’s agenda, but as the difficulties of joint Local Plans hint at, attempting rationalisation and a more strategic approach to planning can actually cause more complexity and delay in the short and medium term. Many districts/boroughs are being encouraged to adopt Local Plans now and adjust to higher housing need requirements at the same time as preparing for the practical realities of mergers and deciding which new combined authorities to join – at a time when many authorities are already operating under significant financial constraints.

In order to make the transition as smooth as possible, the Government is likely to look to solutions that work along the lines of existing administrative boundaries. At the same time, strategic authorities, which will cover large and diverse areas, including urban centres and more suburban and rural districts, should align with local economic geographies in order to make the most of their ability to plan at greater scale. This allows economic activity, planning and development, and democratic accountability all to align.

A simple proxy for economic geography is looking at where people travel to and from for work. Using the “fast track” areas as examples, some authority areas align closely to commuting patterns, while others do not. The proposed Cumbria combined authority covers almost all its relevant travel to work areas, but in the western edge of Norfolk and Suffolk, most residents work outside the administrative boundaries of these counties, in places such as Cambridge or Peterborough. In Sussex and Brighton, the northern half of the proposed combined authority only covers half the effective commuting geography, with many residents commuting to Crawley, Gatwick and the southern fringes of London.

Ensuring new authorities align with journey to work or economic areas allows planning to align economic activity and housebuilding with the delivery of the infrastructure. Other forms of infrastructure required to facilitate planned levels of growth can also be addressed at the strategic level, including new water infrastructure in the form of reservoirs, for example, as well as upgrades to energy infrastructure, including the grid. Consideration will need to be given to how new administrative boundaries align with those used to deliver other public services, such as health, education and social services. The effective delivery of these services also has a spatial dimension that will need to be accommodated within the new plans.

Summary: The biggest shake-up of English local government since the 1970s

• The Government intends to replace the current system of local government with a set of fewer, larger principal authorities and higher “combined” authorities.

• There will be trade-offs between using current boundaries for simplicity’s sake and ensuring new local government units align with economic activity.

• At the same time, existing LPAs risk taking too optimistic a view on updating their local plans, especially if juggling major reorganisation at the same time.

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