Now that the dust has settled on the announcements from the Government on the National Planning Policy Framework 2024 [NPPF24], we look at what the proposed standard method – set out in detail in our blog
here – would mean for authorities across Yorkshire and The Humber.
Yorkshire and The Humber, like other regions, has faced the prospect of delivering Local Plans that seek to concentrate housing growth in its largest cities (Leeds, Sheffield, Bradford and Kingston-upon-Hull) due to the 35% uplift for urban centres introduced in December 2020. For these cities, meeting their housing need, within tightly drawn urban areas with Green Belt constraints, has been very challenging and has been met with resistance at the local level. Other authorities in Yorkshire, such as East Riding, Doncaster and Calderdale, have adopted Local Plan requirements that are higher than the figures generated by the current standard method, suggesting that fewer homes could be delivered in their next Local Plan. The result is that housing delivery is being suppressed across the board.
The new standard method [SM] would take a stock-based approach – explained
here – that seeks to address these imbalances.
The new standard method in Yorkshire and The Humber
The map below sets out the new local housing needs figures for all local planning authorities [LPAs] in Yorkshire and The Humber under the proposed method, including average delivery rates over the past three years and compare these with the current method's figures.
Out of the 15 LPAs in Yorkshire and The Humber, 11 will see an increase in their Local Housing Need [LHN] figure under the new method.
Bradford and Sheffield will see a decrease because of the removal of the 35% uplift but both will require an increase over their average delivery over the last three years, and it would be above the current method if they were to not apply the 35% uplift. Indeed, in the case of Sheffield at least, they would have to plan for housing growth above their current target in their emerging Local Plan which has a proposed housing delivery figure of 2,090 dwelling per annum (as opposed to 2,249 without the urban uplift and 2,667 under the new method).
Even Leeds and Kingston upon Hull (both subject to the 35% uplift under the current method) would see their LHN increase under the new method, demonstrating the challenges and lack of affordability in those two areas.
The map above also shows that the new method will results in notable increases to housing need in LPAs adjoining Sheffield, Leeds and Bradford (such as North Yorkshire, Doncaster and Rotherham), demonstrating a more equitable distribution of housing need across the region and beyond.
Implications for decision making and Local Plans
The proposed changes to the standard method will, if introduced in their proposed form, will have significant implications for planning applications and plan-making over the next two to three years.
Decision making
The standard method will have implications for planning authorities’ 5 year housing land supplies [5YHLS] which in turn will affect decision making. If they can’t meet their 5YHLS then the tilted balance comes into effect (which remains in NPPF24 at paragraph 11d). It also means that sites on ‘Grey Belt land in sustainable locations’ (and where they cannot meet the 5YHLS), will not need to overcome the ‘very special circumstances’ bar that Green Belt sites currently have to. We set out in our separate blog
here an overview of what ‘grey belt’ means in more detail.
Suffice to say, it is worth looking at what the implications could be for authorities’ 5YHLS under the proposed standard method. The Yorkshire and The Humber authorities are listed below with a broad indication of whether they are likely to have a 5 year housing land supply under the new standard method
[1].
Based on the Table above, 11 authorities are likely to have a less than 5 years’ supply of housing land, and only three (Barnsley Calderdale and Leeds) would retain their 5YHLS (based on their stated levels of supply).
Hull, East Riding, Doncaster, Rotherham and Wakefield would likely have the NPPF24 presumption in favour of sustainable development applied, from a position where they are able to demonstrate more than a five year supply of housing land under the current methodology.
York, Sheffield and Kirklees would continue to have less than five years supply of housing land and would continue to have the new presumption applied. Although Calderdale could demonstrate a marginal five year supply, the Authority fails the Housing Delivery Test (49%) and therefore would also have the presumption applied via that route.
In terms of North Yorkshire, the Government has only published a housing need figure for the new unitary authority. We expect the Government will need to publish figures for the constituent former local authority areas in due course as planning decisions currently rely on them until the new North Yorkshire Local Plan progresses. For now, we have calculated what the new standard method would be using the Government’s published figures on housing stock and affordability ratios. We calculate that all but one (Richmondshire) would likely struggle to have a 5YHLS should the proposed method be confirmed.
What’s the impact on Local Plans?
A more equitable distribution of housing need across the country, including within Yorkshire and The Humber, will seek to address issues of unmet housing need across market areas.
We set out the proposed transition arrangements are
here and it is clear Local Plans will be shaken up by the introduction of a new standard method as a result of the increase in their housing need. Together with reforms to the plan-making system that are yet to be switched on from the Levelling Up and Regeneration Act 2023, it is going to be an interesting two to three years for Local Plans.
The chart below compares the housing needs of the 15 LPAs in Yorkshire and The Humber.
West Yorkshire
Based on the proposed transitional arrangements, the ‘Leeds Local Plan 2040’ (approaching Regulation 18 stage but not yet started) would need to be prepared under NPPF24 using new standard method. This will increase from 3,987 to 4,159 dwellings per annum [dpa].
In Bradford, the proposed standard method (2,089) is lower than the current method (2,232) because of the removal of the 35% urban uplift. It is, however, still higher than Bradford’s ‘baseline local housing need’ of 1,704 dpa as stated in their Regulation 18 Local Plan. Like Leeds, they would be required to progress their Local Plan under the NPPF24 using a housing need figure of 2,089.
Kirklees is about to embark on a new Local Plan and they would be required to do so under NPPF24 with a housing need figure of 2,043.
Calderdale adopted their Local Plan in 2023 and won’t be required to review until 2028. Likewise, Wakefield adopted their Local Plan in 2024 and won’t need to review until 2029.
South Yorkshire
Sheffield’s Local Plan is currently at examination. Under the proposed transition arrangements, the Plan will continue to be examined under the current NPPF (which in Sheffield’s case is the September 2023 version) but assuming it reaches adoption based on its currently proposed requirement, Sheffield will need to start work on a new Local Plan because their current housing target is more than 200 dpa below the proposed standard method (2,090 vs 2,667).
Rotherham has not updated its Local Plan since it was adopted in 2014 and it committed itself to undertake a Core Strategy partial review in 2020. Given that it could be facing a 5YHLS of 4.9 years based on the proposed standard method, the pressure will be on to make progress on their Local Plan under NPPF24 with a housing need figure of 1,233, as opposed to 850 in its current Local Plan.
Doncaster adopted its Local Plan in 2021 and will be up for review in 2026. Barnsley concluded in 2022 not to update its Local Plan and given it may continue to have a 5YHLS under the proposed method, it may be that they do not commit to a plan review for a while yet. This could change, however, given the age of their plan and their 5YHLS position potentially being marginal.
York and North Yorkshire
York’s Local Plan has been at examination since 2018 and nearing its conclusion. Should it be adopted, then York will have to start a new plan immediately under the ‘new plan-making system’.
North Yorkshire has recently committed to prepare a new Local Plan for the whole district and they would need to do so under NPPF24 with a housing need of 4,232, up from 1,391 calculated under the current method.
One interesting point in North Yorkshire is Selby’s emerging Local Plan which is at Regulation 19. The Revised Publication version (2024) plans for 386 dpa which is 133 dpa below the new standard method proposed in NPPF24. As such, because this shortfall is not higher than 200dpa, they would be able to continue to examination under the currently-applicable NPPF.
Hull, East Riding and North East and North Lincolnshire
Hull adopted its Local Plan in 2017 and it is aiming to consult on a Local Plan update from February 2025 (Hull City Council Local Plan Timetable, April 2024) and they would need to plan for a housing need of 1,053 dpa under the proposed standard method, 438 dpa higher than their adopted Local Plan.
East Riding of Yorkshire’s Local Plan update underwent examination during 2023 and 2024 and the Inspector has written to them this month to conclude that the Plan is likely to be capable of being found legally compliant and sound, subject to main modifications.
The North Lincolnshire Local Plan is currently at examination and plans for 419 dpa. This is more than 200 dpa lower than the standard method in the NPPF24 which means, once the Plan is adopted, they would be required to start immediately on a new Local Plan under the ‘new plan-making system’.
North East Lincolnshire progressed with a Regulation 18 consultation of its new Local Plan in December 2023. Under the NPPF24 transition arrangements, they would need to progress under NPPF24 which means accommodating an additional 2,039 dpa under the proposed standard method compared with the current.
One caveat
If an LPA is to review its Green Belt boundaries when preparing a Local Plan, then exceptional circumstances will still need to be demonstrated. However, the main difference with NPPF24 is that housing need can expressly justify those exceptional circumstances.
Nevertheless, whilst NPPF24 at paragraph 142 proposes to mandate that LPAs review and, if necessary, alter Green Belt boundaries when they cannot fully meet housing or commercial requirements, this is subject to the question of whether the Green Belt review demonstrates that such alterations would “fundamentally undermine the function of the Green Belt across the area of the plan as a whole”. We expect this to be a new point of debate for Local Plan examinations.
Conclusion
Under the proposals in the NPPF24, many authorities in Yorkshire and The Humber face the prospect of increasing their housing need. Should the Government progress the NPPF24 as planned then, in the short term, considerably more LPAs in the region will face the prospect of the tilted balance than is currently the case. This brings into view debates about Grey Belt sites in decision making because they may no longer be able to demonstrate a 5YHLS.
Most LPAs will also need to take into account the higher housing need when preparing their Local Plan which will cause some uncertainty and delay in the short term especially for those currently at Regulation 19. Even for LPAs with emerging Local Plans at an advance stage, such as Sheffield and York, it won’t be long before they can ‘avoid’ a higher housing need figure.
[1] Using the 5YHLS figures published by Planning Resource Magazine (April 2024) to calculate each LPA’s supply and taking into account whether their Local Plan is less than 5 years old and whether the housing delivery test applies.
[2] Calculated by Planning (April 2024) as revealed by an appeal decision or in a published position statement at the time of Planning publication. Figures correct as of February 2024. Planning recalculated each authority's position to take account of the changes to planning policy brought forward in the revised National Planning Policy Framework (NPPF) – published in December 2023 – and the publication of the 2022 housing delivery test results.
[3] Lichfields calculations, using the same data sources that inform the Government’s published figures, including housing stock data (MHCLG) and affordability ratio data between 2021 and 2023 (ONS)
[4] Sum total of the former LPAs that have formed North Yorkshire
