Decision Maker: Strategy and Resources Policy Committee

Outcome: Recommmend Forward to Council

Is Key Decision?: Yes

Is Callable In?: No

Date of Decision: April 30, 2025

Purpose:

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)