Market Insight

Breaking down Local Plan Making – in association with Sigma Strategic Land

Gatwick Planning partner Suzanne Holloway recently sat down with Sigma Strategic Land to provide her insights into Local Plan Making in a Q+A session. Here's what she had to say:
October 28, 2021

Sigma Strategic Land (SSL) has been in conversation with Suzanne Holloway, a Chartered Town Planner at Vail Williams, a national property adviser for a range of commercial and residential services and assisting occupiers, landlords, developers and investors. Suzanne is a Partner of the firm and helps head up the planning team based in Vail Williams’ Gatwick office.

Suzanne has more than 25 years of commercial planning experience from a wide range of development projects, primarily related to regenerations, strategic allocations and developing sites for commercial property developers. Having worked in regeneration and development facilitation for 10-plus years, alongside her policy development work, she has focused on assisting developers in the delivery of major development opportunities, from site identification to successful occupation.

Throughout her career Suzanne has regularly assessed and commented on the LPAs’ plan-making and planning policies for her clients and has supported Examination-in-Public in connection with Crawley Borough Council and Mid Sussex and Tandridge district councils.

Having previously worked in local government formulating planning policy, and now regularly assessing policy at all stages in the planning process, Suzanne is extremely well placed to provide her insight and experience on the topic of Local Plan making.

SSL sat down with Suzanne to learn more…


  1. To begin with, town planning is frequently described as being a ‘plan-led’ system. This certainly appears to be case given the number of plans covering any given site. These plans operate across a range of scales from the nationally set NPPF, the London Plan covering a city, through to Local Development Plans covering both joint and single authorities right the way down to Neighbourhood Plans. These plans seek to provide the essential framework for making planning decisions, as well as setting residential and economic growth, amongst other aims. Given this number and range of plans within the planning system today, how successful do you see them meshing together and do you consider it to be a true ‘plan-led’ system?

I think the layers of plan making are essential to providing as much certainty to both the public and developers alike. The main aim for me for the planning system should be to be transparent and engaging so all levels of engagement can take place.

Whilst I am sure we all agree that improvements could be made to improve the speed and engagement in a plan-led system, the objectives of the plan-led system are ones I support. The number of tiers of plans, the complexity of their interaction and lengthy timelines for adoption are definitely areas that should be improved to support both planning applicants and developers and those developing Local Plan policy.


  1. SSL is based in Horsham within West Sussex with a particular focus of looking at sites in Sussex, Surrey and Hampshire. What have your notable experiences been of Local Plan preparations and examinations in this area?

My main experiences as an LPA Principal Planning officer and as a Partner at Vail Williams have taught me that both sides of the plan-making process are essential to a sound and supported plan. All LPAs, including those across all three counties you are focusing on, have an unenviable task of constantly trying to balance need and demand, with land supply and then being challenged by both sides of the development process.

I may be biased having worked a long time in local government, but planners on both sides want what’s best for their residents and the local economy, and the “balance” argument means that there are always winners and losers. In my experience, Local Plan examinations should and mostly do, allow each group a valid voice to hear and listen to all sides of the debate, and these three county areas are striving to do this.

With the wider planning system being so complex for the lay person, planning consultants like Vail Williams can help find a positive way to navigate the complexities that are the maze of planning policy and the planning process.


  1. Locally, some Examinations-in-Public have been ongoing for close to two years now. Do you think there should be a time bar by which Local Plans should be determined for the sake of good plan-making? Does this position make any difference between green belt and non-green belt authorities? 

The time delay to any LPA, and lack of certainty in the absence of an adopted plan, is frustrating for all. The need to ensure that all evidence is clear and robust and provided expediently is essential to allow all parties to assess and comment fairly. Locally LPAs are struggling with the provision of key infrastructure. The issue is not theirs alone and so cross boundary and regional working is essential, especially when such significant infrastructure issues are involved.

I believe that a set time frame or one-size-fits-all is not the approach, but clearer and quicker more responsive Local Plan processes, with more integrated engagement, must aim to resolve such significant delays and uncertainty for all involved and ensure that essential development can come forward for the certainty of residents and developers alike.


  1. Time and again we see at Local Plan Examinations that infrastructure capacity for draft strategic allocations form a considerable concern for the Planning Inspectorate. How do you see the Planning Inspector’s role in assessing and managing this concern and is there a place for new strategic plan-making in this process?

For many of us, having practised planning for a long time, the return of a regional or strategic tier of planning to deal with infrastructure capacity has been called for now for a while. In my mind, the Planning Inspectorate has a key role to play in determining local plans and their ability for new development to be supported by adequate and deliverable infrastructure.

However, locally, we also are experiencing cross boundary inter-connected/reliant demands, and therefore I think it is essential for all LPAs to be able to work more effectively cross boundary to ensure regional delivery, and not just LPA boundary-based solutions. A new approach to ensure infrastructure provision is at the heart of development delivery, and not piecemeal or the responsibility of last-over-the-line, is long overdue.


  1. One of the proposed changes of the planning reform package is for the review of Local Plans to happen every 30 months. Do you think this is realistic and what does this mean for council resources?

Resourcing is a key concern for many of us working in planning, whether we are relying on planning to effectively deliver timely decisions or looking at planning policy implications or allocations of sites. A robust, but flexible and reactive, planning process needs to provide clarity for developers and our clients but also residents, key stakeholders and infrastructure providers. We all know overworked case officers, delayed validations, non-determination applications and delayed S106 agreements are a result of reduced planning resources.

Whilst I imagine we all do our best to assist the process, additional layers of resourcing for both development management and policy side must be matched with emerging and adopted new additional planning legislation and requirements.

At Vail Williams, to help with bringing on the next generation of planners, we assist new graduates passing their MRTPI and we work with universities to help new graduates get essential work experience. We also promote careers in property locally, but would advocate that any additional objectives to speed up the planning process generally must be adequately resourced and not overstretch LP officers or disillusion those entering our profession.


  1. The Duty to Co-operate (DtC) has seen many Local Plans stall at an early stage of their examination, most notably and recently those of Wealden DC, Sevenoaks DC, and Tonbridge and Malling BC within the south-east. With the DtC falling away through the planning reform package, what do you think lies in store for plan-making and this centrally important matter?

While we await the Planning Bill and Mr Gove’s new approach to planning, I find myself wondering what will replace the DtC, if anything. The overall objective is sound, in regards of ensuring that any deficit can be assessed and if possible, provided elsewhere. But, in practice, this is fragmenting and dividing neighbouring or regional LPAs that would initially have worked together as best they can to deliver a pragmatic solution.

I imagine that the cross-boundary working will stay but may be renamed and rebranded. In reality I believe we need to understand and develop a more regional approach, to ensure effective plan making and infrastructure delivery, and take a step back to positive and successful planning that does not stop at an arbitrary LPA boundary.


  1. To what extent do you see Local Plans and effective plan-making as being the key to unlocking the government’s ambition for 300,000 dwellings per annum by the mid-2020s?

As discussed above, I believe an effective, well-resourced plan-led system is the right mechanism to help deliver development. Transparency in the plan system, engagement and effective communication with all involved must be improved, to ensure widespread delivery. LPAs have to make hard decisions about demand and supply and therefore an effective plan-led strategy, rather than piecemeal reactive planning, including at appeal, must be of benefit to all of us involved in the planning system.


  1. According to, nine in ten LPAs have an adopted Local Plan, but many of them are not kept up to date. In March 2020 the government set a deadline of December 2023 for all councils to have up-to-date Local Plans in place. The Minister of State for Housing, Rt Hon Christopher Pincher MP, has said that it is critical to advance Local Plans through to adoption by this date in order to ensure that the economy can rebound strongly from the Covid-19 pandemic. What do you see as being the main issues in keeping Local Plans up to date?

Most recently, in our experience, the hardest part for all our local LPAs and clients is the changing planning landscape. The impact of Covid-19 and its impact on our evidence base for both applications and local plan reps has been further frustrated by the changing legislation, PD rights and use class changes. Traffic movements, ecological assessments, a delay to site visits and revised evidence-based documents, on top of remote working for case officers, and changes to remote committees, has all impacted on local plan progress.

While an up-to-date Local Plan is important, the soundness of any Local Plan must also rely on the evidence base provided to support its ambitions, allocations and future decision making. Delays are occurring now due to new technical issues, nitrates, water neutrality, NPPF changes, and uncertainty over long-term strategies. Local Plans cannot therefore always be as responsive to changing circumstances. These take time.

Whilst the ambition to ensure work continues towards a wider coverage of adopted plans, it must be that this is not at the expense of the full and sound evidence base that supports them. A strong rebound to the economy must come from both confidence in the market and clarity over a ‘fit-for-purpose’ planning system and not just Local Plans adopted by a set date.


  1. Horsham DC has stalled its Local Plan-making in order to detail a 30-year vision as required by the latest version of the NPPF. The current draft plan prepared under the previous requirements set out planning policies and proposals to guide development up to 2038 only. What do you make of this situation and how detailed should a 30-year vision actually be?

The amended NPPG now seems to have recently clarified this further, but dealing with decision making in a changing landscape is hard for all LPAs. If the government intention is that strategic allocations look ahead for 30 years, then further guidance about what this entails for all LPAs, across the local plan process, must be also clear to ensure that there are no grey areas for both developers and residents. For emerging plans this can be planned for, but advice on partially drafted plans further along the process is necessary to clarify any level of detail needed.

Our clients will look to the development plan to provide certainty and consider key phasing and infrastructure delivery, as well as viability, but, as this last 18 months has shown us, we also need to make sure plans can also be flexible enough to respond to changing circumstances. In our view, a more agile plan process and the use of supporting framework documents can help shape this vision effectively.


  1. What are your views of joint authority plan-making such as in the case of Central Bedfordshire? Do you think that joint plans have the potential to unlock greater strategic joint working across neighbouring authorities that can better help meet the housing need particularly in constrained areas? And do you think there a case to be made for greater joint plan-making in the south-east of England?

My personal opinion is that regional or cross-boundary solutions are possible, and becoming more necessary, and that we should be working towards more unity between councils and not creating wider boundary divisions. Joint plans can have merit when they are joint from inception, and can provide a mesh of solutions to wider regional issues. However, personally, let’s not force joint working when it is not the best fit. We have coverage at Vail Williams for many LPAs and, from our work across the UK, there is not one solution that works for all.