Local Development Plans - evidence reports and gate checks: action plan and advice

Advice On Essential Content

A. Provide Sufficient Information

• Take a proportionate approach by focusing on significant issues.

This means including more information on issues which matter most. For all plans it is expected that this will include housing and infrastructure. It also means including less information for issues which are less relevant, with a clear but brief statement explaining the authority’s view on why a policy or topic is not relevant.

The same level of information is not required for all of the matters specified in the legislation in all cases. The planning authority should apply judgement to reach their view on what is necessary and explain this for the reporter to test. The focus is on quality and relevance, rather than quantity. The legislation requires that authorities set out their views, rather than comprehensive information, on all of the listed topics.

• Summarise essential information in the Evidence Report.

Planning authorities should be clear about which parts of the submission constitute the Evidence Report and what are supporting documents. It should not be necessary to read supporting documents to understand the evidence and its relevance for the Proposed Plan.

• Use available information.

The Evidence Report should make use of best available information. Primary data collection is only likely to be appropriate for the most significant issues for the plan. Where there are gaps that are considered to be of particular relevance to the plan area, these should be noted, and the planning authority should set out how they will be filled.

B. Focus On Housing And Infrastructure

• Use LDP Guidance Figure 7 template (Annex A) to record information gathered and analyse in relation to significant issues, including housing and infrastructure.

Recognising that some Evidence Reports are already fully formed or well developed, authorities not using the template should ensure they provide the information it covers, including the summaries of evidence, stakeholder engagement and implications for the Proposed Plan, and details of areas of agreement or dispute.

Housing

• Set out an ambitious indicative Local Housing Land Requirement (iLHLR).

Ministers expect a positive and ambitious approach, with the iLHLR exceeding the Minimum All Tenure Housing Land Requirement (MATHLR). The MATHLR is established in policy as a minimum requirement.

Ministers expect this approach to be followed other than in exceptional circumstances. Where authorities do not support a higher requirement than the MATHLR, strong evidence and reasoning is needed.

• Use data and policy ambition information to support the iLHLR.

The MATHLR is based on housing projections, existing housing need and a flexibility percentage (25% urban areas or 30% rural areas) for contingency. The focus of the Evidence Report should be to highlight more up-to-date information or evidence and explain how it leads to an iLHLR that is higher than the MATHLR.

An up-to-date Housing Need and Demand Assessment (HNDA)(including any growth scenario) is a robust and credible source of data to be relied upon. Its information can form the basis of the iLHLR. However, the HNDA is not in itself a land requirement – it is one of a number of inputs.

Updated figures on existing need and/or new household projections should be explained and subject to stakeholder engagement.

Policy ambitions can be applied to determine the iLHLR in addition to updated data and projections.

The ambitions set out in, for example, Local Housing Strategies, Strategic Housing Investment Plans, local housing emergency action plans, City Growth Deals, local economic strategies and other anticipated economic investment, may support more housing growth. Higher growth may also enable affordable housing delivery or support other infrastructure.

It is recognised that such ambitions may be less directly quantifiable in terms of a precise number drawn from an established evidence source or primary data but may still support an ambitious approach. A narrative explanation can be drawn from the relevant documents, with it being open to authorities to increase the flexibility/ contingency percentage. Consideration should also be given to risks from overly excessive levels of housing on a plan-led and infrastructure first approach.

The iLHLR should be evidence-led but also reflect the 10-year plan period, therefore it cannot be an exact science.

• Set out, at least in broad terms, the potential implications of delivering the required land supply.

Particular consideration should be given to impacts on infrastructure and service provision. It is not, however, necessary at this stage to fully explain whether the iLHLR is deliverable as this will be clearer in subsequent stages.

• Provide a summary of the current land supply from the latest available Housing Land Audit.

This is to give an impression of the scale of additional land required at the Proposed Plan stage. This is a ‘snapshot’ of the current situation, and it is acknowledged that it will continue to evolve over the plan preparation period.

• Consider information on completions as a comparative benchmarking tool.

Completions data provides evidence of past trends in delivery of new housing units. They are not necessarily an indicator of future demand or the potential for future delivery. The information is therefore helpful to use as a comparative benchmark.

The reporter’s expectations for housing, based on the above, are set out in Annex C.

Infrastructure

• Provide evidence on infrastructure.

This should focus on the existing capacity of infrastructure and indicate changes that may occur. Relevant information on its condition can also be provided, where the information is available. Where information is not available, this should be explained along with any implications and an indication of future intentions. Planning authorities can aggregate information up to a neighbourhood or area if that relates better to their consideration of the future spatial strategy. The focus should be on land use implications and identifying issues for further consideration at the Proposed Plan stage.

• Whilst infrastructure is critically important, it is recognised that over time plans will be able to build on a growing body of evidence to support an infrastructure first approach. At this stage, a pragmatic approach can be taken, focused on available information and providing any gaps are explained by the authority.
• The standard of evidence will be higher where the intention is to seek developer contributions.

Guidance set out in Circular 4/2025, Planning Obligations and Good Neighbour Agreements, should be considered, particularly section 3.2.2 on Local Development Plans.

Consideration should be given to evidence on education and health, or the intention to have such evidence in place, that will assist developers in preparing submissions in calls for sites or stand up to scrutiny in supporting the infrastructure first and robust approach to developer contributions.

Evidence Reports can acknowledge where there is currently insufficient evidence to seek developer contributions and set out steps to address this.

The reporter’s expectations for infrastructure, taking into account the above, are set out in Annex C.

C. Include Summary Statements

• Include a statement on how the planning authority has sought particular stakeholders’ views, and how these have been taken into account.

Set out how key agencies and other stakeholders have been engaged, summarise their views and identify any outstanding disputes. See template in Annex B.

• Acknowledge any gaps in the evidence to support the spatial strategy or infrastructure delivery, and outline the implications and any next steps.

It is not necessary to provide information for every topic covered by National Planning Framework 4 (NPF4) and the LDP guidance. Planning authorities should decide and explain what is relevant to their area.

• Include a statement on the authority’s analysis of the implications of the evidence for the Proposed Plan.

This can be done on an issue-by-issue basis, for specific sections. The statement(s) should focus on the main issues, challenges and opportunities.