Last week the first Housing Delivery Test (HDT) results were released by the Ministry of Housing, Communities and Local Government (MHCLG) having been delayed since November 2018. The results were released alongside changes to the National Planning Policy Framework (NPPF), as follows:
• ‘Deliverable’ site definition altered to clarify how small and large housing sites should be assessed when calculating a 5-year housing land supply;
• Allowing sites that pass the Appropriate Assessment test to benefit from the ‘presumption in favour of sustainable development’; and,
• Standard method for assessing housing need to revert to the 2014-based projections in the short-term with a commitment to review standard method over the next 18 months.
What is it?
The HDT is a monitoring tool the Government will use to demonstrate whether local areas are building enough homes to meet their housing need. As the test is new, the Government has built in time for it to bed down which has created complexity.
Why is it important?
The NPPF identifies the consequences for local authorities; they are tiered depending on level of shortfall in delivery.
What are the consequences?
Authorities pass the test if they have delivered at least 95% of their requirement. For authorities that have delivered less than 95% of their required housing supply, they must produce an Action Plan to identify actions to increase delivery in future years. Authorities that have delivered less than 85% will have to identify a 20% buffer to their land supply. Finally, authorities that have delivered less than 25% of their requirement will be vulnerable to speculative applications, specially, the NPPF’s ‘presumption in favour of sustainable development’ will apply. As the HDT is new, the Government has built int time for it to bed down. This means the ‘presumption’ trigger point changes to below 45% in November 2019, and below 75% in November 2020.
What are the 2018 HDT results?
No authorities have a delivery of less than 25%, thus none currently face the ‘presumption’ penalty. 86 authorities have delivered under 85% meaning they now have to add a 20% buffer. The worst performing authorities are New Forest (35% delivery), Calderdale (36%), Redbridge (38%), Adur (41%), City of London (42%), Barking & Dagenham (43%), Thanet (44%), Medway (47%) and Trafford (47%). 108 authorities come under 95% and will now have to produce an Action Plan. 66% of authorities (two thirds) have therefore this year escaped any penalty at all.
What are the implications for landowners and developers?
The results show that local authorities need to engage with landowners and developers to enable housing delivery to be accelerated in some areas. Please contact Owen Pike or Barnaby Harris should you wish to discuss the HDT results and the potential impacts on your residential proposals.