In our latest piece analysing the new National Planning Policy Framework, Paul Forshaw, director in our Manchester office, looks at how the changes will impact the promotion of sites through Local Plans.
In March 2026 the “new” system for creating and examining Local Plans introduced by the Levelling Up and Regeneration Act 2023 came into force. The new National Planning Policy Framework (NPPF) published on 17 August 2026 includes new policies against which these “new style” local plans will be examined.
It is important to note that the plan-making policies in the August 2026 NPPF are only relevant to the “new style” local plans. Local Plans being produced under the “old” local plan system will be examined against the polices in the 2024 NPPF.
What’s the most significant change for Local Plans under the new NPPF?
Possibly one of the most significant changes in the 2026 NPPF for Local Plans is the reduction in the length of time a local plan should cover (the “plan-period”). Since the first NPPF in 2012, we have been used to local plans looking ahead for a period of 15 years.
Policy PM2 in the 2026 NPPF reduces this timescale to 10 years. It does not preclude a longer plan-period, but suggests that longer period should only be used where it would support the longer-term delivery of infrastructure.
The potential issue with a shorter plan period for local plans is with trying to plan for larger, strategic allocations which inevitably have long-lead in times that are sometimes uncertain.
When the issues surrounding lead-in times for larger allocations are considered (such as land assembly, the delivery of upfront infrastructure, etc. and the timescales required in preparing and determining planning applications for larger sites), with a shorter plan-period, it is not unthinkable that large strategic allocations may not start delivering within the 10-year local plan period or may only deliver a small amount of development during a 10-year period.
This is problematic because under Policy PM15 of the NPPF, for local plans to be “effective” and therefore “sound” they need to contain allocations that are cable of being delivered during the plan period, with Policy HO3 requiring local plans to demonstrate a deliverable supply during years 1 to 5 of the plan and developer sites for years 6 to 10.
There is a greater risk with larger strategic allocations and larger non-strategic sites that delivery will slip and with a shorter plan-period, a greater risk that development needed to meet plan-period housing requirements may slip beyond the plan-period.
We may therefore start to see local plans focusing more on a greater number of smaller sized allocations, given that it is generally easier to demonstrate delivery of smaller sites.
More emphasis on Spatial Development Strategies?
This does not mean that there is a move away from longer-term planning or the role of larger strategic sites in the new NPPF. Far from it. This shortening in local plan periods puts more emphasis on Spatial Development Strategies (SDS), which the new NPPF places greater focus on. SDS are to cover a longer period – 25 years – and are to consider a spatial strategy at a sub-regional scale, including identifying broad locations or strategic allocations to deliver that strategy.
These may seem familiar to some of us of a certain age. For those of us who remember PPG12, it required a 10-year plan period for local plans. Back then, the role of local plans was less strategic than it has been over recent years, with Structure Plans picking up that role. With the emphasis on SDS in the new NPPF, the merging of local authorities across certain parts of the country, and the Mayoral Authorities, we are moving back to a more regional – well, sub-regional – approach to strategic planning.
The perceived benefits of this sub-regional approach are that it allows greater coordination of strategic issues that cross local authority boundaries, such as infrastructure provision. However, from recent experience in the North West, planning across a sub-region is not without its issues, with competing individual local authority priorities, additional complexities of planning for larger areas, and more political interference across local authority boundaries all adding complexity and timescales.
The preparation and examination of Greater Manchester’s Places for Everyone is a prime example of this. It took eight years from initial preparation to adoption, with one council withdrawing from the process and another unsuccessfully asking the Secretary of State to quash the adopted plan and then being prevented from withdrawing from the plan by the housing minister.
Then there is Liverpool City Region’s Spatial Development Strategy, which has seen little progress made since 2023, with individual local authorities’ local plans having overtaken its production in some instances.
What are the implications of this shorter Local Plan period for promoting sites?
Given the shorter plan-periods, it’s likely the amount of evidence that both local planning authorities and examining inspectors require to demonstrate there is a reasonable prospect a site will deliver within the plan-period will increase, as will the amount of scrutiny given to such evidence.
Therefore, regardless of site size, more technical evidence to show site specific constraints can be overcome and that the site can deliver development in the plan-period will likely be required in representations, and this may be required at an earlier stage in the plan-making process than currently to give sites the best chance of being allocated.
There may also be a case to push local authorities to identify more sites than needed to provide a buffer in case the delivery of other allocations slip beyond the shorter plan-period.
It is also going to be important, where dealing with a larger site that will take time to deliver, that it is promoted through both the SDS and Local Plan preparation process, with representations to the Local Plan demonstrating the delivery of a part of the wider strategic site within the shortened local plan period.
For developers, occupiers, investors and landowners, now is the time to revisit sites that may previously have been discounted. In many cases, the policy landscape has moved materially in favour of development and we are seeing, now the new NPPF has been published, that a number of local authorities are starting to progress with the new-style local plans, with a number currently consulting on early drafts and requesting details of sites for potential allocation.
If you would like further advice on the promotion of potential development sites through the Local Plan / SDS process, please get in contact with us.