Content

11.1

The Executive Director City Futures submitted a
report and associated appendices setting out potential changes to
the Sheffield Plan that was submitted to the Government for public
examination in October 2023.  They set
out the recommended Council response to the Sheffield Plan
Inspectors’ request for the Council to identify additional
land for new homes and employment use. 
 
The Inspectors wrote to the Council on 6th
February 2025 to set out their preliminary conclusions on those
issues following completion of the first two stages of public
examination hearings held in 2024.
 
The main body of the report summarises the
Inspectors’ preliminary conclusions and sets out the
Council’s proposed response to their
letter.
 
The proposals will require approval by full
Council.  If the list of sites is
approved at Full Council to be submitted to the examination, the
proposals would then be subject to a 6-week public consultation
period.

 

 

11.2

RESOLVED: That Strategy and Resources Policy
Committee:-

 

 

 

(a) notes the
Inspectors’ preliminary view in their letter that the plan
cannot be found sound in its current form, given their concerns in
relation to the housing and employment land need and supply;

(b)
notes the temporary pause in the examination to allow the Council
to provide the additional information requested within the
specified timescale, so that the examination can recommence;

(c) accepts the
Inspectors’ conclusions in relation to housing need and agree
that additional housing sites should be brought forward to provide
3,539 homes (the minimum number requested by the
Inspectors);

(d) accepts the
Inspectors’ conclusions in relation to employment land need
and agrees that the additional employment sites should be brought
forward to provide 52.8 hectares land (the minimum amount requested
by the Inspectors);

(e) agrees that
exceptional circumstances now exist to justify the release of
greenfield land in Green Belt for new development;

(f) agrees the list of
proposed additional site allocations to be presented to the
Inspector for both employment and housing land as set out in
Appendix 1;

(g) notes that the
list of proposed additional site allocations provides an additional
margin above the minimum amounts requested by the Inspectors which
is to provide flexibility and reduce risk (as detailed in Section
3.11);

(h) notes that the
evidence base/submission documents have been/are being updated to
reflect the proposed additional site allocations (as well as to
address certain other concerns raised during Examination) and that
this evidence as updated will be submitted to the Examination at
the same time as the proposed additional site allocations;

(i) agrees to the
proposed public consultation strategy on the information to be
submitted, and for the results/responses of the public consultation
to be submitted directly to the Inspector’s thereafter,
alongside the additional/updated information;

(j) agrees to submit
the list of sites and consultation proposals to full Council for
approval; and

(k) delegates
authority to the Head of Planning, in consultation with the
Administration group leaders, to approve amendments to the list of
additional site allocations and amendments to the consultation
strategy prior to consideration by Full
Council.

 

 

11.3

Reasons for Decision

 

 

11.3.1

Once adopted,
the new Sheffield Plan will make a major contribution to the future
development of the city and will guide development over the period
to 2039.  It is therefore important that
the plan is adopted as soon as possible.  The 8-month pause in the examination process to
allow further work requested by the Inspectors to be undertaken
potentially allows the Plan to be adopted by July 2026. 

 

 

11.3.2

The Inspectors have concluded that additional sites allocations
need to be identified to provide more land for housing and
employment uses.  However, our
conclusion is that this can only be achieved by releasing land from
the Green Belt because we have already exhausted options in the
urban area as part of developing the existing strategy and
neighbouring authorities continue to indicate they are unable to
meet any of our unmet need in respect to both housing and
employment land.  On that basis, when
considering the positive and negative effects of such an approach
compared to alternatives, exceptional circumstances exist, to
justify releasing further land from the Green Belt for new
development.  Any development proposals
on land released from the Green Belt will be subject to the
‘Golden Rules’ set out in the December 2024 National
Planning Policy Framework

 

 

11.3.3

If additional land is not provided, it is likely that the
Sheffield Plan will be found unsound and
the Council will have to start work on an entirely new
plan.  This would cause significant
delay in adopting a local plan and would have major financial
implications for the Council due to the need to produce
a new evidence base and submit the plan
for an entirely new public examination.

 

 

11.3.4

Further significant delay in adopting the Sheffield Plan will
harm the city’s economy and undermine regeneration
initiatives.  It will also mean that the
city’s housing and employment needs will not be fully
met.  The lack of an up-to-date plan
creates uncertainty for developers, the public, and infrastructure
providers.

 

 

11.3.5

The additional sites that are shown in Appendix 1 of the report
have not previously been identified as allocations as part of
public consultation.  Further
consultation needs to take place as detailed in the
Inspectors’ letter.  That
consultation must accord with the Council’s Statement of
Community Involvement.

 

 

11.3.6

The submission documents that support the local plan and the
specific proposals in this report need to be made available during
the public consultation period.  This is
also a legal requirement for the updates that have been carried out
to the Integrated Impact Assessment and the Habitat Regulations
Assessment Appropriate Assessment.

 

 

11.3.7

Approving submission of the additional sites to the Secretary of
State is reserved to Full Council.  The
Council’s constitution requires that this committee prepares
in draft and submits any such document to Full Council for the
purpose of its’ submission to the
Government.

 

 

11.4

Alternatives Considered and
Rejected

 

 

 

Scale and Distribution of Development

11.4.1

The consideration of options relating to the scale and
distribution of future development is an integral part of the
process of preparing a local plan.  As
already explained earlier in the report, the options are considered
through Integrated Impact Assessment (IIA) at both a strategic and
site-specific level.  The IIA is
attached as Appendix 7 to this report. 

 

 

11.4.2

At this stage of the Local Plan process, it has been agreed with
the Inspectors to limit consideration of additional site options to
those sites that have been promoted to the Council by developers
and landowners (including Council-owned land) during the different
stages of preparing the Sheffield Plan. 
As explained in paragraphs 3.5.10 to 3.5.11 above, initially, the
Inspectors asked officers to focus on sites that were ‘lower
scoring’ when assessed against the purposes of Green
Belt.  However, as already noted,
officers concluded that lower performing ‘omission
sites’ and other lower performing
Green Belt parcels would not provide sufficient land to meet the
shortfall employment and housing land identified by the Inspectors,
even before factoring in sustainability considerations.  Therefore, sites that were promoted through the
call for sites in 2019 and the Regulation 18 Issues and Options
stage (in 2020) have also been considered, in addition to those
promoted at the Regulation 19 Draft Plan stage in 2023.  This includes some sites that are ‘higher
scoring’ when assessed against the purposes of Green
Belts. 

 

 

11.4.3

The shortlisted sites that were discussed with Members, but
which are not recommended as allocated sites, are listed in
Appendix 2.  Other promoted sites that
are not recommended are listed in Appendix 3.  The sites in these appendices are not recommended,
taking into account the sustainability
appraisal, impact on Green Belt purposes and planning
appraisal.

 

 

11.4.4

Of the 102 sites in scope of this exercise
that have been promoted to the Council during the process of
preparing the Sheffield Plan, 14 are now recommended as additional
allocations.  It should be noted,
however, that, in some locations, promoted sites have been combined
to create a single larger proposed allocated site.

 

 

 

Response to the Inspectors’ Letter

11.4.5

The Council could decide not to put forward
additional site allocations and ask the Inspectors to reach their
conclusions based on the Plan that was submitted in October 2023
(together with various amendments already put forward by officers
during the course of the
Examination).  However, given the
preliminary findings set out in their letter received in February,
it is almost certain that the Inspectors would conclude that the
Plan is unsound and would ask the Council to withdraw the
Plan. 

 

 

11.4.6

If the Council has
to withdraw the Plan, it would be necessary to start work on
a new Plan under the latest National Planning Policy Framework and
planning guidance.  It would mean
returning to the Regulation 18 Issues and Options
stage.  The new plan would need to look
beyond 2039 and would be produced using the higher housing need
figure referred to in paragraph 2.6 above.  By the time a new Plan was ready to be submitted,
more of the brownfield sites would also have been used
up.  This combination of factors would
inevitably necessitate a much higher level of release of Green Belt
land for development in any new Plan.  A
new Plan would need to be submitted to the Government by December
2026 in order to comply with national
planning policy .

 

 

11.4.7

Sheffield’s current local plan
(comprising documents adopted in 1998 and 2009) is extremely out of
date.  This has implications for
decisions on planning applications because they should be
determined in accordance with the development plan.  It also means that the Council is unable to
identify a 5-year supply of housing land which means that the
presumption in favour of granting permission has to be applied to applications for new housing
development. 

 

 

11.4.8

The ongoing absence of an up-to date adopted
Plan would significantly hinder a citywide co-ordinated approach to
infrastructure delivery and the mechanism for securing finances for
new infrastructure.  The current public
sector budgets place greater emphasis on the Sheffield Plan as one
of the most important drivers of funding for the Council through
planning contributions to deliver new essential
infrastructure.  Future external funding
bids for regeneration projects would also be seriously
compromised.  Ultimately, a failure to
produce a local plan at all could lead to the Government taking
over plan-making in Sheffield. 

 

 

11.4.9

The option of providing additional allocated
sites within the existing urban areas is set out in Section 3.3
above.  We have also explored with
neighbouring authorities whether they are able to meet any of
Sheffield’s development needs (see Section 3.4
above).  As explained in those sections,
neither of those options are considered to deliver the quantum of
development identified by the Inspectors as being needed.

 

(Details of the
recorded vote on this item will be included in the minutes)