The introduction of the Housing Delivery Test was one of the key additions to the revised National Planning Policy Framework (NPPF), published in July 2018. The Housing Delivery Test is essentially a government assessment as to whether Councils and Local Planning Authorities are overseeing the development of sufficient homes in their area. The results are calculated using a standard methodology and expressed as a percentage against their individual housing targets over the preceding three year period. The results are due to be reviewed and published in November each year to ensure that Councils are meeting their housing requirements over this rolling three year period.
Local Planning Authorities which deliver over 95% of their target will not face any actions or consequences. Approximately one third of Local Planning Authorities fell short of the 95% target, and will be required to prepare an action plan within six months, to assess the causes of under-delivery and identify actions to increase delivery in future years. Those Local Planning Authorities which fail to deliver at least 85% of their housing target are required to review their Local Plans and identify a 20% buffer to their five year housing land supply, with 86 Councils required to add a 20% buffer to their land supply.
The most severe consequences of the Housing Delivery Test are reserved for those Authorities which fail to deliver at least 25% of their housing target. Where a Local Planning Authority severely under delivers housing, Local Planning Policy is overridden and a presumption in favour of sustainable development as set out in the NPPF applies. The result of the 2018 Housing Delivery Test revealed that no Local Planning Authorities fell below the 25% target. However, year on year the Housing Delivery Test is set to get tougher. From 2019 the presumption in favour of sustainable development will apply to those Councils which fail to meet 45% of their target in 2019 which then jumps to 75% from November 2020. Based on current housing delivery this leaves seven Councils vulnerable to this sanction from November 2019 and 58 Councils from November 2020 unless housing delivery rates are improved over the next year.
What does this mean locally? Our expert team at Development, Land and Planning have reviewed the results of the Local Planning Authorises in which they work regularly. Whilst most Councils are currently meeting or exceeding their targets, there are a few Local Planning Authorities which face consequences under the 2018 Housing Delivery Test. Torbay Council achieved 90% of their target and are therefore required to produce an action plan to boost delivery. North Somerset met 73% of their target, North Dorset achieved 82% and West Devon 69% meaning these Local Planning Authorities are required to review their Local Plans and identify an additional 20% buffer against their five year housing land supply. Both North Dorset and West Devon currently fail to identify a five year housing land supply without this 20% buffer. Therefore, there is an opportunity for landowners with suitable sites in these areas to put land forward as potential development options.
Due to the early stages of the Housing Delivery Test, it is difficult to identify the potential impact the test will have and the implications of the test for Local Planning Authorities. What is known is that there is a pressure for Local Planning Authorities to continue to identify sufficient land to meet their targets and to approve and deliver housing sites to meet their local housing targets to avoid sanctions in the future.
If you would like to discuss the implications of the Housing Delivery Test or would like any help or guidance on planning matters in general please contact a member of the Greenslade Taylor Hunt Development, Land and Planning Team on 01823 334466 and we would be pleased to assist.