Determining your draft allocations for local plans: stage 3
Draft guidance to help you understand how to take sites you have assessed and decide which you should propose for allocation in your local plan.
Applies to England
For plans under the legacy plan-making system
If you are submitting your plan under the legacy system, use the create or update a local plan legacy system guidance.
The legacy system covers plans to be adopted under the Planning and Compulsory Purchase Act 2004, excluding the amendments made by the LURA, and The Town and Country Planning (Local Planning) (England) Regulations 2012.
During Stage 3 you will select the sites that you think meet your draft plan’s proposed vision for your area. These sites are your draft allocations, which will form part of your draft plan.
This stage is classed as ‘policy on’ and is where relevant national and emerging local plan policies, and where in place, policies set out in Spatial Development Strategies are more fully applied.
Determining your draft allocations can be an iterative process. It’s likely you’ll revisit different stages and update previous assessments, particularly following consultation and engagement with stakeholders. You’ll refine your assessments and draft allocations, based on any new information you learn.
Aim of stage 3
Use this guide to:
- understand how to determine your draft allocations based on stage 2 findings
- decide how best to engage stakeholders on progress, if needed
- learn what to factor into your selection approach
Outputs of stage 3
Following this guide will give you a:
- list of draft allocations for your draft plan
- clearer view of any evidence you may need to support your draft allocations
Applying planning judgement
Local context is central to making decisions and is the most important element of determining your draft allocations. This includes consideration of the needs of your area, and your proposed vision and spatial strategy for your plan.
The approach you take to determining your draft allocations should be consistent with the National Planning Policy Framework. You should be seeking to meet your development needs in full. Where you do not have sufficient sites, consider what alternative approaches you may have to explore to meet this need.
Developing your selection approach
Your approach to selecting your draft allocations from the sites brought forward from stage 2 will depend on the factors unique to your plan’s objectives. These include environmental, economic and social objectives.
You are best placed to make judgements based on these factors. The context of your plan area, proposed spatial strategy and local vision are important when reaching decisions.
This section sets out some example factors you could consider when deciding on your draft allocations. Draw on any relevant evidence you have developed already through the process, in particular during the assessment of the sites, including:
- the type and category of the sites determined in stage 2
- settlement hierarchy and function, linking to related evidence and the plan vision and spatial strategy
- existing and future connectivity by private, public and active transport
- accessibility to services and facilities
- alternative or competing land uses such as employment, minerals extraction or safeguarded land
- timescales for delivery to ensure new development can be provided throughout the plan period – for housing sites consider the deliverability and developability of sites
- ability to deliver strategic development, either alone or combined with other sites, linking to the plan vision and spatial strategy
- any relevant environmental considerations or objectives of the plan
- economic sustainability considerations such as jobs and skills, regeneration and social inclusion
- local considerations, such as constraints relating to neighbouring or nearby uses or existing or emerging policy designations
- other new or emerging local plan evidence – for example, your whole draft plan’s viability study may give you a more complete picture of how sites meet the needs of your area.
You may want to consider your sites on a settlement or sub-area scale, especially where this would help align your draft allocations with your emerging spatial strategy.
Engaging your stakeholders
As with all stages, engagement with relevant stakeholders is important as you make decisions on sites and progress towards your draft allocations. This includes respondents to your call for sites, developers, and members of the local community.
This will include formal engagement as part of the statutory local plan public consultations. It can also include less formal engagement with relevant stakeholders as and when required. It is recommended you record details of engagement with stakeholders and make sure to conduct it in an open and transparent way. You should also have meaningful, ongoing and proportionate consultation with landowners, developers and promoters, particularly for large or strategic sites.
Wherever you take opportunities for engagement, where appropriate, you should respond to representations made or views shared on sites. Record where representations have identified considerations that influence decisions on sites.
You will need to build in enough time to be able to properly consider views and representations made on sites. Consider how best to engage with elected members following local governance arrangements.
By this stage in the process, you are likely to have established channels of dialogue with the main stakeholders. You can use these to share information as and when needed. For example, this could be in a regular public meeting or by posting progress updates on your website.
If you do not have the right number of sites
The number of sites you’ll need to select to put forward to allocate depends on the proposed spatial strategy of your plan. There are several things to reconsider if, after several iterations, you do not have enough appropriate sites to put forward as draft allocations for your plan.
Among other things, this could include, in no order of priority:
- how you selected sites in this stage - are there any more that could meet your proposed strategy and vision for your area in your draft plan?
- how you assessed sites in stage 2 - could you change the mitigation criteria and local considerations used?
- the assumptions you made around density and development potential - were they right?
- the reasonable alternatives to your spatial strategy, and whether you could do further assessment of these
If you still do not have appropriate capacity within your draft allocations, having exhausted all reasonable options to do so within your plan area, you should be able to justify this and explain the reasons why.
This will form part of the examination of the plan and will directly affect whether the sites element of your proposed plan is considered sound. You will also need to then explore other options to meet any needs somewhere else.
You may find that you have more appropriate sites than you need to meet your development needs. These sites may be similar in terms of their overall suitability and their deliverability and developability. Apply your planning judgement to the process and decide to put forward for allocation the sites that you think are most appropriate to meet your proposed plan vision. Make sure you clearly document the reasons for your choices.
Next steps
After determining your draft allocations, you can move forward to Stage 4: Confirming your draft allocations and recording your decisions.