by Ed Dade
Posted on Jan. 24, 2021
Last week, the Ministry for Housing, Communities and Local Government (MHCLG) published its latest Housing Delivery Test (HDT) measurement. This post discusses those results, and is accompanied by an interactive map which I developed.
Screenshot of Interactive HDT map. Note, this is just an image, not the actual map!
My interactive Housing Delivery Test 2020 map is free to use and requires no registration. To view the map, please visit:
On the map, each local authority area is shaded to illustrate the 'consequences' of its HDT measurement. Clicking a local authority area reveals a pop-up label providing further information.
The HDT calculates the number of new homes built as a percentage of the number of homes required over the past three years. MHCLG re-calculates the HDT figure annually for every local authority area in England.
Where housing delivery has fallen below the number of homes required over the previous three years, this has consequences for the local authority.
Depending on the amount of shortfall, the local authority must prepare an Action Plan, apply an additional buffer when calculating its Five Year Land Supply - and in the areas with the greartest shortfall, apply the presumption in favour of sustainable development when determining planning applications.
This may all sound a tad 'high level', and you may be wondering what relevance it has for neighbourhood planning.
If a local authority is required to apply the presumption in favour of sustainable development as a consequence of its HDT result, planning policies contained in Local Plans may be rendered 'out of date' and will carry less 'weight' when determining planning applications.
Where a local authority's HDT result requires the authority to apply a buffer, if the local authority becomes unable to demonstrate five year's supply of housing land it must also apply the presumption in favour of sustainable development.
Since the HDT was introduced, the thresholds have gradually increased each year, meaning more local authorities are now subject to the most stringent sanctions than in previous years.
The HDT is a genuine threat to Neighbourhood Plans as it can severely reduce the status of their policies, rendering them out of date. This undermines the efforts of those communities who have prepared a Neighbourhood Plan, punishing them for poor housing delivery which may be entirely outside of their control.
When preparing a Neighbourhood Plan, you should speak to your local authority about their housing supply situation and ask how this is likely to affect the longevity and status of your plan.
It is immediately clear from the interactive map that many more local authority areas now face the presumption in favour of sustainable development as a direct consequence of the HDT (shaded red on the map). For comparison, under the previous year's measurement there were 8 local authorities faced the highest penalty (the presumption...). The latest HDT 2020 figures show this has increased sharply to 55 local authorities.
The increase in the number of local authorities 'caught' by the HDT is unsurprising. The threshold for the 'presumption' penalty increased from 25% in 2018, to 45% in 2019 and to 75% in 2020. In other words, if a local authority failed to deliver at least three-quarters of its housing requirement, certain policies contained in the Local Plan and Neighbourhood Plans are now out-of-date.
I chose to display the HDT results on a map to highlight the geographic spread of those areas facing penalties under the HDT.
What is most striking is that those areas which performed most poorly tend to be clustered together, and are not evenly distributed across the country.
This clustering suggests that shortfall in delivery is unlikely to be due to the failure of individual local authorities, but that there are other socio-economic factors at play which are specific to that locality or region.
Most significant is the London area and wider south-east region, where there is a large number of local authorities facing penalties under the HDT. In addition, the map shows smaller clusters in some city regions, such as around Machester and Leeds, Nottingham and Derby, and Birmingham.
The HDT is very effective in highlighting those locations where the delivery of new homes has failed to keep pace with the housing requirement. Yet placing penalties on individual local authorities appears to do little to address the root causes of poor delivery over a wider geographic area i.e. at the city-region scale.
Preparing Neighbourhood Plans against the backdrop of the HDT means that the experience of groups preparing a Neighbourhood Plan will differ greatly depending on their location. Where housing delivery is good, Neighbourhood Plans will be untouched by the HDT. Yet, in areas of poor housing delivery, Neighbourhood Plans may be out of date even from the day they are formally made.