Housing Delivery Test and recent planning policy changes
Hard Times or Great Expectations?
On 19 February, the Government published its Housing Delivery Test (HDT) and an update to the National Planning Policy Framework (NPPF 2019) to provide clarification on the standard method for local housing need assessment, housing land supply, the presumption in favour of sustainable development and the definition of ’deliverable’.
Housing Delivery Test
NPPF 2012 required a 20% buffer to be added to a housing requirement where there had been “persistent under delivery” in housing land supply.
In NPPF 2018 ‘persistent’ was replaced with ‘significant’ with past delivery to be measured against the then proposed HDT which is an annual measure of housing delivery in an area, published every November. The HDT measures the number of net homes delivered against that required in a rolling three-year period with the following consequences for Councils (and opportunities for landowners/developers):
- 100% and above = no consequence.
- 95%-99% = no consequence.
- below 95% = 22 Councils to prepare an action plan (identify cause of under-delivery and correct).
- below 85% = 20% buffer (increase in housing) and action plan applied to 86 Councils.
- below 75% from November 2020 = the presumption in favour of sustainable development will also be engaged. On 2019 figures, unless delivery improves, a number of Council’s would be exposed to this measure.
What this means for the south of England is shown on the map below.
We have also looked at what this means in areas where Pro Vision is currently representing clients:
West Berkshire (117%)
|Buckinghamshire||Slough (86%)||Action plan|
|Dorset||Christchurch & East Dorset (75%)|
North Dorset (82%)
|Essex||Basildon (76%)||20% buffer|
|Hampshire||Test Valley (155%)|
Basingstoke and Deane (76%)
New Forest (35%)
Tunbridge Wells (88%)
Tonbridge and Malling (155%)
|Oxfordshire||South Oxfordshire (179%)||No consequence|
|Surrey||Guildford (75%)||20% buffer|
|West Sussex||Arun (91%)|
National Planning Policy Framework 2019
NPPF 2018 lasted all of 6 months, now with the following main updates:
- Standard Method for local housing need assessment – Planning Practice Guidance confirms use of the 2014-based household projections and local housing need assessment is not a ‘target’ but the ‘starting point’ for Council’s to plan for. The 2016-based projections led to significant variations in housing need at a local level and doubt over the Government target for 300,000 homes delivered per annum. We think this creates short-term stability for plan-making and decisions in areas where the standard method applies, including that the use of an alternative method by Councils (e.g. to try and lower housing need) will require ‘exceptional circumstances’, though constraints such as Green Belt mean Council’s may still seek to justify that it is not possible to meet all local housing need. The Government intends to review operation of local housing needs assessment over the next 18 months.
- Housing Land Supply – "Where local housing need is used as the basis for assessing whether a five year supply of specific deliverable sites exists, it should be calculated using the standard method set out in national planning guidance". This clarification to footnote 37 is welcomed and should for example reduce the need to debate the method of calculation at appeal.
- Definition of Deliverable – Non-major sites with outline permission should be considered deliverable unless there is clear evidence to the contrary. We support the change, which reflects recent appeal decisions and adds clarity for applicants who may otherwise want to challenge alleged deliverability.
- Appropriate Assessment – Paragraph 177 has been amended following the ‘People Over Wind’ court ruling last year. The ‘presumption in favour’ of sustainable development remains engaged where an Appropriate Assessment has concluded that proposed development “will not adversely affect integrity of habitats site”. This clarity is useful, and potentially removes a barrier to new development.
Get in touch?
This is a general overview. If you would like to know more about these issues or you want to discuss how these changes might affect a specific project, please contact us on: 01794 368 698 or email@example.com