Researching the interactions between local plan making and neighbourhood plans

The Planning Advisory Service (PAS) on behalf of the Local Government Association (LGA) commissioned DAC Planning to research the interactions between local plan making and neighbourhood plan making, with particular consideration given to the implications of changes introduced in the National Planning Policy Framework (2019). The research aims to identify practices that are occurring across the country as local plans and neighbourhood plans are progressed.  The research also seeks to identify where there may be a need for further support, research or identification of best practice to enable local planning authorities (LPAs) to effectively support neighbourhood planning and reduce any bottlenecks or practical difficulties in the future. The research was carried out through questionnaires and interviews with planning officers from a range of LPAs across the country, as well as a desk-based review of recent local plan and neighbourhood plan independent examinations.

The key findings from the research indicate that support from LPAs for neighbourhood planning is varied, but successful practice points to open communication, proactive support and early engagement. The overall feedback from LPAs indicated a need to employ additional officers dedicated to neighbourhood planning support. Dedicated support provides neighbourhood planning groups with a first point of contact, while also building trust and stronger relationships between neighbourhood planning groups and LPAs. LPAs that do provide dedicated support have noted stronger relationships with neighbourhood planning groups and positive outcomes with the production of neighbourhood plans.  The LPA cutting back on neighbourhood planning support is likely to be a false economy in areas where neighbourhood plan making is active or likely to be active in the near future. Fostering open and continued communication between the LPA and neighbourhood planning groups is crucial to ensuring effective plan production.

Updates to local plans can create considerable uncertainty for emerging or made neighbourhood plans, particularly where the LPA is required to respond to significant changes in strategic housing requirements and local housing need. 

There is limited support for neighbourhood planning officers across LPAs nationally in the form of dedicated networks or support channels (either formal or informal).  This means that opportunities for sharing best practice and problem solving are currently limited. 

The temptation for LPAs to delegate responsibility for allocating housing sites to neighbourhood plans can be significant, but this needs to be balanced against the potential risks associated with delays to the neighbourhood plan or even a change in policy direction and the potential that the plan will not allocate sites at all. Such circumstances can render strategic policies in local plans out of date.

Lack of technological skills and knowledge can be a hindrance to the progression of neighbourhood plans and communication with the relevant LPA. This has been exacerbated by the COVID-19 pandemic.The following recommendations have been identified for LPAs arising from research findings:

1. Consider investing in one or more dedicated neighbourhood planning officers to facilitate effective neighbourhood planning.
   
    
2. Encourage neighbourhood planning groups to produce plans which are effective and streamlined.
   
    
3. Work with neighbourhood planning groups to understand how local aspirations for housing and other uses can be met, and what role the neighbourhood plan can and should take in this.
   
    
4. Support neighbourhood planning groups in assessing and updating their plans as a result of local plan updates and pro-actively identify policies in made or emerging neighbourhood plans which are likely to be impacted upon by a local plan update.
   
    
5. Seek to promote joined up and collaborative working between LPAs, community organisations and independent consultants appointed by the neighbourhood planning group to reduce the potential for duplication or gaps in support coverage, and to reduce the potential for contradictory advice to be provided.
   
    
6. Hold meetings or workshops between neighbourhood planning groups, parish/town councils (where relevant) and planning officers (including development management officers) at key points in the plan-making process and after the plan is ‘made’ in order to improve the effectiveness of policies.
   
    
7. Build on existing networks or form new links regionally to exchange best practice for planning officers engaged in neighbourhood planning.

Ensure that the shift to a digital planning system is not a barrier to involvement and participation in the neighbourhood planning process. Support neighbourhood planning groups to utilise digital technology where possible to enable neighbourhood plan making to continue without face to face interaction.

Background

The Planning Advisory Service (PAS) on behalf of the Local Government Association (LGA) commissioned DAC Planning to research the interactions between local plan making and neighbourhood plan making, with particular consideration given to the implications of changes introduced in the National Planning Policy Framework (2019).

The research aims to identify practices that are occurring across the country as local plans and neighbourhood plans are progressed. The research also seeks to identify where there may be a need for further support, research or examples of best practice to enable LPAs to effectively support neighbourhood planning and reduce any bottlenecks or practical difficulties in the future.

DAC Planning carried out the research through questionnaires and interviews with planning officers from LPAs, as well as a desk-based review of recent local plan and neighbourhood plan independent examinations. LPAs were selected from across the country to provide a range of circumstances relating to geographical context, progress with local plans and extent of made neighbourhood plan coverage.

The research considers the implications arising from the COVID-19 pandemic, particularly its impact on the progression of neighbourhood plans. However, the research pre-dates the publication of the Planning for the Future White Paper and the consultation on changes to planning policy and regulations ‘Changes to the current planning system’. The implications from these proposals therefore could not be considered.

It should be noted that other relevant research includes that undertaken by the University of Reading and by the London Assembly, examining the role of neighbourhood planning in London.

Policy context

The National Planning Policy Framework (2019) introduced a number of changes to plan-making which have potential implications for the relationship between local plans and neighbourhood plans, including the need for local plan policies to be reviewed at least every five years and where necessary updated.  In addition:

• the introduction of the new standardised methodology to assess housing needs
• the requirement for local plans to provide housing numbers for designated neighbourhood areas
• the requirement for local plans to distinguish between strategic policies (which should cover a minimum of a 15-year period) and non-strategic policies
• the expectation that LPAs should accommodate at least 10 per cent of their housing requirement on ‘small and medium sized sites’ (up to one hectare) through their development plans and brownfield land registers.
  
  
  
  LPAs have a statutory duty to assist neighbourhood planning groups. Schedule 10 of the Localism Act (2011) stipulates:

3(1)A local planning authority must give such advice or assistance to qualifying bodies as, in all the circumstances, they consider appropriate for the purpose of, or in connection with, facilitating the making of proposals for neighbourhood development orders in relation to neighbourhood areas within their area.

Planning Practice Guidance for Neighbourhood Planning indicates that LPAs should support neighbourhood planning functions in the following ways:

• Be proactive in providing information to communities about neighbourhood planning.
• Fulfil its duties and take decisions as soon as possible, and within statutory time periods where these apply.
• Set out a clear and transparent decision-making timetable and share this with those wishing to prepare a neighbourhood plan or an Order.
• Constructively engage with the community throughout the process including when considering the recommendations of the independent examiner of a neighbourhood development plan or Order proposal.
  
  
  
  Neighbourhood Planning Practice Guidance sets out a general guide for LPAs on how to provide indicative figures to neighbourhood planning groups on request:

Where an indicative housing requirement figure is requested by a neighbourhood planning body, the local planning authority can follow a similar process to that for providing a housing requirement figure. They can use the authority’s local housing need as a starting point, taking into consideration relevant policies such as an existing or emerging spatial strategy, alongside the characteristics of the neighbourhood plan area.

Many areas of the country now enjoy a good coverage of made or emerging Neighbourhood Plans. The latest available data indicates that 2,612 neighbourhood areas have been designated across the country, and at least 820 Plans have been ‘made’.  This poses the challenge of what will happen to the neighbourhood plans that are made or are at the final stages of preparation as and when local plans are reviewed and updated.

In some instances, updates made to a local plan will have negligible implications for neighbourhood plans in the area, particularly where local housing need remains unchanged. In other cases, updates to the local plan may fundamentally alter the strategic planning context that the neighbourhood plan is working within, potentially resulting in the neighbourhood plan (or policies within it) becoming out of date. The impacts may be particularly pronounced where the housing requirement for the area increases through the application of the standardised methodology requiring the local plan to be reviewed and the housing strategy updated.

The remainder of this report sets out the methodology, key findings, conclusions and recommendations arising from the research.

Research approach

A representative sample of 20 LPAs were selected that ensured a range of both rural and urban locations throughout the country were included and a questionnaire sent out to the sample. Planning officers of the LPAs were then invited to interview.

The purpose of the questionnaire was to collect information on a range of matters relating to the approach to local plan review/update and the approach being taken towards emerging and made neighbourhood plans in the area, as well as the support offered.

Thirteen questionnaire responses were received and twelve of these LPAs also agreed to an interview.

Following the receipt of completed questionnaires, DAC Planning conducted online video and phone interviews with planning officers from the twelve LPAs that agreed to an interview. The interviews provided insight into the practical challenges faced by both LPAs and neighbourhood planning groups, existing support offered by LPAs for neighbourhood planning groups, and opportunities for additional support.

A desk-based review of recent local plan and neighbourhood plan independent examinations were undertaken to gain an understanding of how planning inspectors are examining the different approaches being taken by local plans in relation to the future role of neighbourhood plans (see Appendix 3).

Participant LPAs

The following table provides a brief contextual overview of each LPA that participated in the research. The following information is up to date as of 1 April 2020.

The key findings from the research are summarised below, firstly in relation to the support for neighbourhood planning and secondly in relation to the implications of local plan updates. Relevant recommendations arising from the research findings are included in blue boxes throughout the section.

Support for neighbourhood planning

The type and extent of support offered for neighbourhood planning varies across LPAs.  Online resources, the provision of advice during the plan-making process and guidance with undertaking ‘Regulation 14’ consultations are extensively offered services. However, some LPAs go further by offering additional services beyond the basic statutory requirements such as an interactive online mapping tool (Cornwall Council) and officer supported workshops (Cheshire East Council). In some areas certain technical services are available for a fee, such as document design and production (Cornwall Council), a neighbourhood plan health check (Greater Cambridge Shared Planning Service) and the production of evidence-based reports (Cheshire East Council).

Dedicated officer support for neighbourhood planning is relatively uncommon, and on the whole appears to be decreasing, although some LPAs do benefit from one or more dedicated neighbourhood planning officers (Cornwall Council and Leeds City Council). For LPAs without any dedicated neighbourhood planning support officers, usually one or more senior officers provide support for neighbourhood planning in addition to undertaking other planning policy work.

  There is limited support for neighbourhood planning officers across LPAs nationally in the form of dedicated networks or support channels (either formal or informal). This means that opportunities for sharing best practice and problem solving are currently limited.  However, in some instances regional networks or support channels exist, such as Neighbourhood Planners London, an informal network of neighbourhood planners throughout London. The use of existing officer networks at regional levels to exchange information on neighbourhood planning (Lichfield, Gedling) and informal officer networks focussed on neighbourhood planning (Sussex Neighbourhood Planning Officers) indicates the potential for additional dedicated networks of support for officers engaged in neighbourhood planning. RTPI courses were also mentioned as an alternative and beneficial source of training and information.

  LPAs that do provide dedicated support generally have noted stronger relationships with neighbourhood planning groups and positive outcomes with the production of neighbourhood plans. This support can also generate benefits for the LPA beyond neighbourhood planning by building strong relationships built on trust and transparency between LPAs and local communities, including parish and town councils where applicable.

Communication and early, adequate support are key strategies to helping neighbourhood planning groups and creating or reinforcing a strong relationship between neighbourhood planning groups and LPAs. Ongoing communication can save time and resources by signalling issues and opportunities at early stages of neighbourhood plan production, and reducing the amount of work required for officers in seeking to address problems later in the process. Early support is more likely to result in an appropriately worded and targeted neighbourhood plan. If the neighbourhood plan group has limited support it is more likely that the plan will struggle to meet the basic conditions or will ultimately be of less value in the decision-making process. The LPA cutting back on neighbourhood planning support is likely to be a false economy in areas where neighbourhood plan making is active or likely to be active in the near future.

It is mutually beneficial for both LPAs and neighbourhood planning groups for ongoing communication to be maintained throughout the production of the neighbourhood plan. Interview data indicates that a number of LPAs have not been kept updated on plan-making progress by neighbourhood planning groups who then supply the LPA with a full draft neighbourhood plan document, limiting opportunities for the LPA to help shape it at the early stages. Equally neighbourhood planning groups need to be kept informed about progress in the local plan and evidence base production, particularly in relation to any changes which will have an impact on the emerging neighbourhood plan. 

 It was suggested that the introduction of a two-way ‘duty to inform’ or similar between LPAs and neighbourhood planning groups would be beneficial in order to try and overcome insufficient exchange of information. This could build on the existing information detailed in Statements of community involvement. It may be that additional Planning Practice Guidance could provide helpful clarification on how this could and should best be achieved, particularly during a local plan update. 

Some LPAs have introduced documents describing the relationship between LPAs and neighbourhood planning groups in an effort to clearly define the scope and extent of support provided, in addition to the expected levels of communication that should be maintained between both parties during a neighbourhood plan’s production. For example, East Staffordshire establishes the support it will and will not provide for neighbourhood planning through a protocol.  South Cambridgeshire District Council’s Memorandum of Understanding includes a timeline for the predicted progression of neighbourhood plans for parish councils to complete. However, the efficacy of this approach has been limited, as neighbourhood plan groups have found it challenging to provide timelines for the production of their plans.

The benefits of early investment are noted in the experience of LPAs which received grants through the Neighbourhood Planning Front Runners Scheme. A full list of the LPAs in the research sample which received Front Runners grants is available in Appendix 2. Most of these LPAs were able to build strong relationships with neighbourhood planning groups and develop proactive forms of support from the outset. They have generally continued to provide this support (to varying degrees) and build on the established relationships with neighbourhood planning groups through continued communication and positive joint working. From the interviews, it is clear that open and sustained communication between LPAs and neighbourhood planning groups can lead to better outcomes for neighbourhood planning.

One model to facilitate communication is employed by Cornwall Council in the form of engagement and ‘interpretation’ meetings. Once a neighbourhood plan is ‘made’, an interpretation meeting is arranged between the Neighbourhood Planning Steering Group, parish council and development management planning officers. During these meetings, officers discuss the implementation of the plan and reasons behind planning application decisions. The contact with development management enables neighbourhood planning groups to gain a better understanding of how the neighbourhood plan can be most effectively put into use, whilst ensuring that council officers fully understand the intent and purpose of the policies in the plan. This support is enabled through effective coordination between planning officer teams.

Responses from LPAs indicated the need to ensure that resources are sufficient to effectively support neighbourhood plan making during the local plan review and update process.  This can ensure that neighbourhood planning groups understand the context within which the neighbourhood plan is being produced, and also for made neighbourhood plans this helps to ensure that groups are clear as to which neighbourhood plan policies may be at risk of becoming outdated. Responses indicated that pro-actively identifying which neighbourhood plans and policies will be impacted by a local plan review and update helps to provide tailored support to neighbourhood planning groups (East Staffordshire Borough Council and the Central Lincolnshire authorities). Cornwall Council specifically recommends advising neighbourhood planning groups to design their plans with flexibility to allow room for future policy changes arising from local plan updates.

 There was concern that neighbourhood planning might not be adequately supported when local plan updates are occurring simultaneously to neighbourhood plan updates. This is compounded in LPAs without dedicated neighbourhood planning support officers, where limited planning officer resources may have required the prioritisation of working on the local plan, potentially to the detriment of neighbourhood planning.

In some areas, independent charities operate to support communities in meeting their needs and planning for the future. For instance, Planning Aid or regional organisations that form part of the ACRE Network. Such independent charitable organisations often provide a further source of support and advice for neighbourhood planning groups in producing their plan. Where support packages are carefully coordinated between the charitable organisation and the LPA, this can be beneficial in providing further dedicated support to neighbourhood planning groups, whilst also reducing the reliance on overstretched planning officers within the LPA or external consultants employed by the neighbourhood planning group. For this to be successful, LPAs and community organisations (and indeed any independent consultants appointed by the neighbourhood planning group) need to maintain regular dialogue and a close working relationship to reduce the potential for duplication or gaps in support coverage, and to reduce the potential for contradictory advice to be provided.

Support for neighbourhood planning has largely moved online due to COVID-19. The main impact from the pandemic is the shift to online communication methods in respect of social distancing. Most responses felt that the level of support they provided to neighbourhood planning groups has remained the same since the start of the pandemic, but some expressed concern over the ability of neighbourhood planning groups to adapt to online platforms. Additionally, there are delays to the progression of neighbourhood plans from the rescheduling of referenda and concern that when referenda resume in May 2021 this could potentially overwhelm electoral services (Cornwall Council).

Managing the implications of local plan updates on neighbourhood planning

 The relationship between local plans and neighbourhood plans varies across LPAs. A reliance between the two is dependent on several factors, including the number of ‘made’ and emerging neighbourhood plans in an area, the existing relationship between the LPA and neighbourhood planning groups and, the support structures in place for neighbourhood planning.

Paragraph 65 of the NPPF requires LPAs to establish a housing requirement figure for their area and set out a housing requirement for designated neighbourhood areas ‘which reflects the overall strategy for the pattern and scale of development and any relevant allocations’. The guidance does not indicate a specific approach, and from the responses, different methods are being used to determine housing requirements for neighbourhood areas in local plans.

The varied methods in use and the current absence of methods in a number of LPAs undergoing local plan reviews and updates (such as Lichfield District Council and Leeds City Council), indicates that existing guidance in establishing housing requirement figures for designated neighbourhood areas in local plans would benefit from more detail to ensure that future approaches are robust and transparent.

Most responses reflected that due to the uncertain outcome of the neighbourhood planning process (and the fact that neighbourhood planning groups are under no statutory obligation to allocate sites for housing within emerging Neighbourhood Plans) they cannot depend upon neighbourhood plans to contribute towards ‘strategic’ District or Borough wide housing requirements and local housing need, thus limiting the reliance local plans place on neighbourhood plans.

As a result of this uncertainty and the concern that this reliance might impact upon their ability to meet five year housing land supply requirements, most LPAs choose to avoid placing any significant responsibility for providing for ‘strategic’ housing requirements to neighbourhood plans (Central Lincolnshire local authorities), a problem heightened for areas with high housing pressures (Greater Cambridge Shared Planning Service).

Site allocations in neighbourhood plans are generally viewed by LPAs as providing flexibility to the overall housing supply and an additional buffer over and above the identified local housing need. However, some LPAs currently rely on and/or are likely to rely on neighbourhood plans to contribute substantially to meeting ‘strategic’ housing requirements and local housing needs within the district or borough in the future (Chichester District Council, Lichfield District Council, East Staffordshire Borough Council).

Reliance on neighbourhood plans for housing allocations can be beneficial for some LPAs, enabling communities to have a greater say over the location and scale of development in their area and, in some cases, to benefit from Community Infrastructure Levy income revenue (Gedling Borough Council). However, when neighbourhood plans are approached as tools to constrain development, housing allocations become a point of contention and can reduce an LPAs ability to meet its ‘strategic’ housing requirement. This can become an acute problem where LPAs have a strong dependence on neighbourhood plans to provide housing allocations and/ or where a local plan update results in an increased housing requirement.

 Several LPAs noted that it was challenging to find an appropriate balance between strategic and neighbourhood level planning when it came to establishing the approach to planning for future housing needs within the Local Plan (Torbay Council, Lichfield District Council, Greater Cambridge Shared Planning Service).

For the majority of LPAs, housing allocations in neighbourhood plans tend to generally be limited to small or medium sized sites of less than one hectare, which can contribute positively towards meeting the local plan requirements for small and medium sized sites (as required by paragraph 68 of the NPPF).

From the review of recent independent examinations of local plans (Appendix 3), it was clear that Inspectors generally welcome instances where local plans delegate a degree of responsibility for meeting ‘strategic’ housing requirements to neighbourhood plans, but Inspectors caution that the successful implementation and delivery of such an approach depends on the successful progression and completion of neighbourhood plans.

The research highlighted the importance of LPAs keeping up to date with progressing neighbourhood plans in order to inform local plan updates. Several LPAs indicated that neighbourhood plan policies would help to inform the production of local plan updates (for instance, Cheshire West and Chester Council and Leeds City Council).

For some LPAs included within the sample, it is too early to assess the impacts that local plan updates are having on ‘made’ or emerging neighbourhood plans. Many LPAs are at relatively early stages of producing updates to local plan policies following completion of a review. Most responses, however, predict that neighbourhood plans will be impacted by updates to local plan policies with select policies in neighbourhood plans at risk of becoming out of date, particularly for populous centres and areas of high housing need where predicted future growth in housing is more challenging. As a result, neighbourhood plans in areas where local plans are to be updated to reflect increased housing requirements are likely to be considerably impacted.

Complications can arise when neighbourhood plans and local plans are at different stages. For example, the combination of an inadequate housing land supply (and outdated housing policies), an emerging local plan and emerging neighbourhood plans can put a significant strain on the finite officer resources available. Scarce officer resources will often be prioritised towards local plan production or defending planning appeals, at the expense of supporting neighbourhood plan production.

 For practical reasons, neighbourhood plans that are in the production process while local plans are under review or update may also find themselves at a disadvantage.  Neighbourhood plans in this situation may struggle to ensure general conformity with the strategic policies of the local plan, given that the status and approach of the strategic policies will change during the production of the plan.  If the neighbourhood plan is made before the emerging local plan update is adopted, there is a risk that the plan (or elements of it) will become outdated soon after it is made.  Equally, if the neighbourhood planning group decides to wait for the local plan update to be adopted this can create a significant amount of delay to the progression of the neighbourhood plan. Consequently, local plan reviews and updates can delay the progression of a neighbourhood plan or impact on the ability of neighbourhood plans to comply with the basic conditions.

Several responses predict that as most neighbourhood plans were produced before the NPPF (2019) update requiring local plan reviews at least every five years, some neighbourhood planning groups are unprepared for the additional work that a local plan update might entail. There is concern that the local plan update will undermine or disrupt the work of neighbourhood planning groups (Central Lincolnshire authorities).

The research seeks to identify where there may be a need for further support, research or examples of best practice to enable LPAs to effectively support neighbourhood planning and reduce any bottlenecks or practical difficulties in the future. 

The following section summarises the key findings and conclusions arising from the research.

Support for neighbourhood planning

 

The key findings from the research indicate that support from LPAs for neighbourhood planning is varied, but successful practice points to open communication, proactive support and early engagement. Updates to local plans are likely to have impacts on ‘made’ and emerging neighbourhood plans, particularly where the housing strategy of the local plan is being altered.

The overall feedback from LPAs indicated a need for more resources to employ additional officers dedicated to neighbourhood planning support. Dedicated support provides neighbourhood planning groups with a first point of contact, while also building trust and stronger relationships between neighbourhood planning groups and LPAs. Most responses understood the support needed for neighbourhood planning groups, but have insufficient resources to provide the extent of support that they consider is required.

Existing levels of support and resources for neighbourhood planning across LPAs is uneven and inconsistent. Mechanisms to share successful support practices between LPAs could help to address this imbalance and make best use of available resources. Coordinated and potentially shared support between LPAs for neighbourhood planning could encourage more efficient services and enable existing knowledge on successful practices to benefit a wider number of neighbourhood planning groups.

Neighbourhood planning is a specialised area with limited support systems in place for planning officers and a limited supply of consultants offering targeted services. In many areas there is currently insufficient coordination across LPAs to exchange information and best practice. Creating these links could help to address uneven neighbourhood planning outcomes across LPAs and reduce the pressures on planning officers.

A majority of responses agreed that the key strategy to support neighbourhood planning groups is open and continued communication. There are different methods to facilitate communication and keep neighbourhood planning groups and LPAs sufficiently informed to benefit neighbourhood plan production. When LPAs do not play any substantive role in the formation of the neighbourhood plan and do not provide enough guidance on its scope, this can produce uncertainty and worsen relations between LPAs and neighbourhood plan groups. Insufficient communication at early stages of the neighbourhood plan process can lead to misleading expectations which inform neighbourhood plan policies and are more difficult to address at a later stage in the plan-making process, by which point groups tend to be more wedded to them.

Most LPAs reflected that it would be beneficial to narrow the scope of neighbourhood plans and shift the focus either to housing or locally specific needs appropriate to the neighbourhood plan. This may require a redefinition of the policies and purpose of neighbourhood planning. LPAs also found that because neighbourhood plans are not obliged to include housing allocations, the LPA cannot rely on neighbourhood plans to contribute meaningfully towards meeting strategic housing requirements or local housing needs without incurring a considerable degree of risk. It was also recommended that neighbourhood planning groups produce plans with a small number of simple but effective planning policies.

Managing the implications of local plan updates on neighbourhood planning

 

Updates to local plans can create considerable uncertainty for emerging or made neighbourhood plans, particularly where the LPA is required to respond to significant changes in strategic housing requirements and local housing need. Proactive support and two-way communication are beneficial in the context of local plan reviews and updates.

A changing policy landscape produces challenges for neighbourhood plan production and can impact on progress. This can be mitigated through early and ongoing dialogue between LPAs and neighbourhood planning groups. With policy changes, neighbourhood planning groups are faced with added gaps in knowledge. Planning officers offering support to bridge these knowledge gaps help empower neighbourhood planning groups to make appropriate decisions and understand the planning system.  However, such officer resources are often in short supply, and are likely to be prioritised towards other tasks.

The application of strategic policies which allocate sites for a local area within a local plan can potentially be seen as ‘top-down’ and can produce friction between LPAs and neighbourhood planning groups. Understandably, in areas where neighbourhood planning groups are active, the temptation to delegate responsibility for allocating housing sites can be significant, but this needs to be balanced against the potential risks associated with delays to the neighbourhood plan or even a change in policy direction and the potential that the plan will not allocate sites at all. Such circumstances can render strategic policies in local plans out of date.

The different methods used by LPAs to determine housing requirements (indicative or otherwise) for neighbourhood areas indicates the need for clearer guidance for LPAs on how this should be approached.

Due to the shift to online platforms for the neighbourhood planning process, accelerated by the COVID-19 pandemic, skills and access to the internet/hardware is increasingly important. Lack of technological skills and knowledge can be a hindrance to the progression of neighbourhood plans and communication with the relevant LPA.