The Rise of the Zombie Local Plan


Two recent statements by Eric Pickles have rather taken my breath away.

Firstly he said in the commons on questions on concern over threats to the countryside to areas without plan coverage under the NPPF that neighborhoods without plans should soon get ‘relief’ as there was now 60% adopted plan coverage and over 70% of areas had submitted plans.

And yesterday he said on twitter ‘I do not anticipate many rejections from those that are already submitted’

This despite in 2013 only 46 plans being found sound out of 52 submitted and 161 areas without 2004 plans still have to be found sound. If the 2013 rate it would take 15 years. Some progress.  I make that from the PINS official database only 47.9% not 60%. I really don’t know where DCLG get there numbers from especially since they stopped compiling their own database.

Can Pickles really believe what he is saying? Plan progress ground to an almost standstill in 2013. There was some progress in 2012 before the NPPF became finalised and subsequent before Regional Strategies were revoked. But since regional strategies were revoked all of those local planning authorities relying on them for housing numbers have been sent back to the drawing board, those ignoring the overspill needs of their neighbors have suffered a worse fate, they don’t even get to be considered unsound their plans have been found to be illegal.

There is some hope in 2014, two plans Baburgh and Teignbridge have been found sound, and many of the plans requiring ‘main modifications’ on housing numbers in 2013 will return in 2015. Many authorities, especially those with politically sensitive MPS like Welwyn Hatfield, Epping Forest and Brentwood have needlessly delayed plan publication till after the 2015 election. So expect more of a burst after them. So I doubt it will take 15 years. However many of the better plans have now come forward and planning inspectors tell me the general standard of submission is continuing to fall, a combination I think (not necessarily all three in all areas) of head in the sand politicians, poor resourcing and poor officers trapped in or only being able to get jobs in such areas.

The statement by Pickles is slightly disingenuous as since the localism act rather than being found unsound a local planning authority can simply request for changes and spin the process out, and of course those who know they will be found unsound are less likely to submit in the first place.

The key issue I think is whether we are going forwards or backwards in the process?  It is not just whether or not you have a post 2004 act plan but whether that plan is up to date.   Many authorities with adopted core strategies fund them out of date because they are based on now revoked regional strategy numbers and out of date population and household projections.  Indeed you could say only a handful of authorities now have up to date plans because either they adopted after the revocation of regional strategies or providentially they have had sufficient completions and windfalls to maintain a 5 year housing supply.  Such authorities are in the distinct minority. Even for them they cannot have yet fully taken on board the latest population findings from the census or the housing recovery and likleu decrease ahead in headship rates.

Overall this means that almost every plan in the country apart from those you can count on two pairs of hands which were recently adoped, are ‘Zombie Plans’ plans which are no longer up to date and can no longer guarantee a 15 year housing trajectory.  Those that in addition cannot guarantee a 5 + year housing supply will be in danger of ‘build what you like where you like’.

Rather than the NPPF incentivising plan production it has provided a series of perverse disincentives.  Firstly if you are a Green Belt Authority then if you dont review your Green Belt you win appeals but if you review your plan you will almost certainly have to release some land.  If you dont this look at the recnt court case at Thundersly where the LPA voted to release the land in a published local plan the day before they won an appeal on its existing status.  Also many authorities have been made to look fools through nailing colors to a localist mast that doesn’t exist and so rather than publishing a plan with the same amount of housing as proposed in the regional strategy they delay plans until after the next local and /pr national elections.  Finally as local planning authorities with regional plans now don’t only have to meet unmet housing need in full from local sources but from overspill from other authorities.  As there is no mechanism under the duty to cooperate other than rats in a sack where there is substantial overspill; need, such as around Brum, London and in Sussex, it adds a brake to almost any authority moving forward.  Again if you doubt this the numbers are undeniable plan adoption has slowed to a crawl since the NPPF.

What do you do when you have a plague?  A plague that now threatens to bring down the entire plan led system.  Indeed it is a plague becasue when one plan cannot meet need that infects neigbouring areas as it has not been established whether or not the original area can meet its need in full.  At least the RSS EIP process did this.  Epidemiology has a number of lessons, isolate, immunise, slow down the spread.  If any surgeon general in the face of a plague offered teh same advice as Pickles each is individually responsible for their own health, they wouldn’t last a week.  Government policy should be doing everything to reduce infection by stablising the system to determine housing need (in retrospect the abolition of the The National Housing and Planning Advice Unit was a huge mistake), acting to bring together and broker deals where there is duty to cooperate stalemate, allow local planning authorities a year to bring in new housing numbers following new household projection figures, commissioning proper city regional studies for areas around the major cities (of only as an evidence base).

‘The War has just begun’ Brad Pitt World War Z


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