Insight

Local Plan Watch Wrapped: The High Watermark of the Great Local Plan Slowdown

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Welcome to Local Plan Watch Wrapped, your annual reminder that while the planning system has been busy, it has not necessarily been fast.

2025 in Numbers: The Quietest Year on Record

 

For those of us promoting sites through the Local Plan system, the past few years have felt unusually quiet.  You probably didn’t need to look at the data to confirm this, but it does paint a very dramatic picture. As shown in the table and accompanying graphs, 2025 is on course to be the weakest year for Local Plan adoption in recent memory. Only 10 Local Plans have been adopted in 2025. With one month remaining in the year, this leaves a narrow window to avoid it becoming the quietest year in the dataset. Even if one or two additional plans are adopted before year end, this would still represent barely a quarter of the adoption rates seen at the high points of the last 10 years. Those earlier peaks, it is worth recalling, were themselves insufficient to achieve full and up-to-date plan coverage nationally (we need 63 a year for 5 years to achieve this).

 

Why the System Slowed: Policy Uncertainty and the White Paper Effect

 

The roots of this slowdown lie squarely in the prolonged period of policy uncertainty following the 2020 Planning White Paper. Repeated changes to the direction of travel for the NPPF created hesitation across the system. Faced with shifting expectations, many authorities slowed production, paused drafting, or chose to defer submission rather than risk progressing plans that might quickly become non-compliant.

 

Submissions Are Rising, Adoptions Are Not

 

The first signs of recovery are now appearing in submission rates rather than adoption rates. The table shows a sharp increase in submissions during 2024, with 31 Local Plans submitted, close to the levels seen during the peaks of the previous decade. This reflects the rush to beat the transitional deadlines under the old NPPF regime. However, this surge in submissions has not yet translated into higher adoption numbers because examination times have lengthened significantly. Not surprisingly, our analysis shows that the average time for a Local Plan to be adopted from submission in 2025 was 37 months.

The Coming Submission Surge Towards 2026?

 

This pleasant trickle could turn into a raging current though. In June, the Planning Inspectorate indicated that it expects 147 plans to be submitted by the end of 2026. The Government recently announced that this is the deadline for Local Plans to be considered under the current framework before shifting to the 30 month plan system. Only 11 Local Plans have been submitted since that projection was published, so presumably that leaves 136 expected next year. Many of these authorities will struggle to meet this target and it is realistic to expect a proportion to fall away in spring next year. Even if only half of the projected total is submitted, it would still represent the largest wave of Local Plan submissions we’ve seen for some time. As a result, 2026 is likely to see an unprecedented volume of consultations (many of those 136 authorities have not been through the Regulation 19 stage) and exceptionally high workloads for Planning Inspectors and Programme Officers in 2027 as those Local Plans work their way through the system.

 

Examinations Are Taking Longer Than Ever

 

While submissions are increasing, the time taken to move from submission to adoption has deteriorated sharply. The second chart illustrates this clearly. A decade ago, around half of all examinations that reached adoption were completed in under 18 months. In the last three years, only one authority has managed to achieve that benchmark (hats off to you, West Suffolk). The current average time from submission to adoption is now approximately 37 months, double the typical timescales seen in the mid-2010s.

 

What Is Driving Unsound and Withdrawn Plans

 

The longest running examination currently in the system is Rutland, which will reach its fifth anniversary in February next year. That scale of delay is now unlikely to be repeated following the July 2024 Pennycook letter, which introduced a firm expectation that authorities should be given no more than six months to resolve fundamental issues identified during examination.

 

Life After the Duty to Co-operate

 

Soundness outcomes also paint a revealing picture of systemic stress. Nine Local Plans were withdrawn or recommended for withdrawal last year, either formally or through Inspector conclusions. The statutory Duty to Co-operate was a material factor in five of those cases, including Oxford City, Bournemouth Christchurch and Poole, Oxfordshire/Vale of White Horse, Horsham and Mid Sussex. Infrastructure uncertainty underpinned the withdrawal of plans at Bedford and Stroud. Disputes over the approach to housing need were central to difficulties at Shropshire and Elmbridge.

 

Why This Still Matters for Strategic Planning

 

The forthcoming removal of the statutory Duty to Co-operate is likely to reduce the number of plans that fail on purely procedural grounds. The NPPF requirement to demonstrate that cross-boundary housing need has been addressed remains in force, and this will continue to be used as part of the test of soundness in practice. The potential reopening of the South Oxfordshire/Vale of White Horse and Horsham examinations will be a test case as to whether this watering down will make it easier for plans to be declared sound.

 

From Low Coverage to Potential Overload

 

Looking at; the number of Local Plans now in the system; the many more on the way; and, the watering down of the biggest barrier to soundness coverage, it is easy to see how we could rise rapidly from the current low watermark of 24 percent Local Plan coverage nationally. How high we can go will depend on the number of plans that can be submitted before the end of 2026, when a new system is likely to cause a cliff edge of submissions, and on the robustness of these submissions. Authorities will be under severe pressure to get local plans in and this may mean not all evidence bases will be watertight. Set against this, we will have Local Plan Inspectors weighed down by huge workloads and instructed not to give authorities longer than six months to resolve any post-submission issues. Our 2026 Wrapped could paint a very different picture.

Winter 2025

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Jamie Sullivan

Partner, Planning

Jamie brings extensive industry experience of greenfield Local Plan promotion as well as securing planning permission for large scale complex brownfield regeneration proposals.

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