Letter to Kate Josephs: urban alternatives

Dear Ms Josephs

I am writing on behalf of the Sheffield Green Belt Alliance. We ask you to commission an urgent, independent review of whether urban opportunities could reduce the proposed Green Belt releases, and seek the Inspectors' agreement to a defined pause for that work.

Sheffield needs a Plan that delivers homes, withstands scrutiny and commands public confidence. The case for Green Belt release is that urban alternatives are exhausted. A review either confirms that and strengthens the Plan, or shows there is additional urban capacity the Plan has not counted.

The current consultation does not provide a comprehensive assessment of urban alternatives. It covers six promoted sites, all of which the Council has already decided against allocating. Community-identified sites and the fifteen city centre allocations deleted for lack of availability information have not been taken forward. The Brownfield Register has not been updated since December 2023, despite the annual review required by law. The Council's website states: "Our intention is to produce a further update to the Register once the Local Plan Inspectors have published their report" - in other words, the evidence of urban capacity that may prevent Green Belt release is to follow the Inspectors’ report that depends on it.

On 7 October the Leader told the Strategy & Resources Policy Committee that “the Planning Inspector concurred with our analysis that we had exhausted all of our sites on brownfield or greenfield in the urban area”. The Inspectors have not yet reported; in June, they cited the NPPF duty to examine all reasonable options before releasing Green Belt and required six urban sites to be appraised. The premise is being presented as settled while it is still being tested.

The concerns about the Plan expressed by the Council Leader, local MPs and Sheffield councillors across parties warrant a substantive executive response. Our legal team’s scrutiny is also continuing, with further potential grounds of challenge emerging. Unresolved issues risk litigation, public expense and prolonged uncertainty for housing delivery. Even if the Council defends the Plan successfully against a challenge, it will still have to rebuild confidence in the communities affected. It may also face further lengthy legal disputes over ending two Council farm tenancies.

A route is open. A further schedule of main modifications has been out to consultation since 14 September, and in July the Inspectors asked it to liaise with them on next steps. The Council can put a proposed change to a Green Belt allocation to the Inspectors while the examination remains open.

Relevant lesson from the Lowcock Inquiry was the need for senior leaders to challenge an approach before it became entrenched. The Inquiry recorded missed opportunities for executive intervention (paragraphs 950 and 978), and recommended considering corporate management for major programmes (recommendation 10). An independent review now applies that lesson.

An assessment by external planning professionals who have not been involved in preparing the Plan would provide an independent test of whether urban sites could deliver homes beyond the supply already assumed and reduce or avoid Green Belt release. Completed before the examination concludes, it would allow the Council to act on the findings and reconsider its allocations. We ask you to oversee the commissioning and provide the resources it needs.

The programme should cover the Brownfield Register, a focused call for urban sites, the availability of the fifteen deleted allocations, direct engagement with landowners, and any allocation changes the evidence supports. It should weigh the costs and risks of this work against continuing as now.

Please confirm within 10 working days whether you will commission the review, who will lead it, its timetable and when the Council will approach the Inspectors.

The Council still has an opportunity to address these risks before it is too late. But if it proceeds, the City Futures Leadership Team must be prepared to explain why it allowed a course of action to continue when both the concerns and the means of reconsidering it were known. The Council must take ownership of the Sheffield Plan and be accountable for the decisions it makes, rather than presenting those decisions as unavoidable instructions from the Planning Inspectors. You can act now, while the Council can still put matters right.

Kind Regards

Gill Travis
Sheffield Green Belt Alliance