More than 100 local planning authorities (LPAs) have failed to meet strict government targets for the number of new homes to be delivered within their localities, according to the latest figures published by the Ministry of Housing, Communities and Local Government (MHCLG).

What is the Housing Delivery Test?

The Housing Delivery Test (HDT) is an annual measurement of the number of homes built in LPAs across England over a three-year period. Under the National Planning Policy Framework's (NPPF), all LPAs have to demonstrate a five per cent land supply buffer as standard, in addition to their required five-year supply of deliverable housing sites.

The HDT was introduced to assess the measures the net additional dwellings provided in a local authority area against the homes required, using national statistics and local authority data to assess how successfully each local authority is delivering housing. It compares each LPA’s level of housing delivery, using the net additional dwelling figures, over a three-year period to the total number of homes required. It also sets out severe consequences for those LPAs which fail to achieve them.

A 20% buffer is applied to the housing requirement where there has been significant under delivery of housing over the previous three years. Significant is defined in the NPPF as delivery below 85% of the requirement. In addition, the presumption in favour is triggered where the local authority’s HDT results indicate that delivery of housing has been “substantially” below the housing requirement over the previous three years. From 2019 onwards, this means that if delivery falls below 45% of the requirement over the previous three years the presumption automatically applies; or where the LPA cannot demonstrate a 5 year supply of deliverable sites (with the appropriate buffer).

Housing Delivery Test 2016-2019 Results

Eight LPAs will be subject to the housing delivery test's most severe penalty, the NPPF's presumption in favour of sustainable development, according to the latest test results just published. These, plus a further 75 authorities delivering under 85 per cent of their housing requirement will have to provide a "buffer" of sites for 20 per cent more homes than are needed to meet their five-year target (i.e. 83 authorities in total).

The results show that of the 106 LPAs which failed to meet the 95% delivery target pass rate:

Eight will become subject to the presumption in favour of sustainable development, meaning that planning permission should be granted, unless the site is protected under the NPPF or the adverse impacts demonstrably outweigh the benefits.
83 must find a 20% buffer of additional deliverable sites for housing; and
26 must produce an action plan identifying the causes of under-delivery and a plan to address it.

Twenty of the 83 ‘buffer’ authorities are new and now have a greater housing land supply target in response to the latest HDT results. This means they now need to increase the proportion of planned homes to add a 20% buffer to their five-year supply.

On a more positive note, 218 LPAs were reported to have delivered 95% or more of the housing delivery targets set for them and will face no action.

Regional Analysis

Source: MHCLG

Many of the LPAs with the most severe penalty are in located in the South of England, specifically City of London, Havering, Thanet and Eastbourne, where the availability or viability of land for residential development is more challenging to unlock or due to the presence of strategic policy protection such as Green Belt.

Conversely, the East Midlands was the strongest performing region in terms of housing delivery, with 85% of the LPAs having met or exceeded the HDT, followed jointly by the North East and West Midlands at 83%.

Region	Passed	Action plan	Buffer	Presumption
East Midlands	85%	5%	10%	0%
East of England	53%	9%	32%	6%
London	50%	15%	29%	6%
North East	83%	8%	8%	0%
North West	77%	0%	23%	0%
South East	54%	13%	28%	4%
South West	69%	8%	22%	0%
West Midlands	83%	0%	17%	0%
Yorkshire and The Humber	71%	10%	19%	0%

Source: MHCLG

Mary-Jane O’Neill, Head of Planning – London & South East at LSH, commented:

“The Government has committed to delivering 300,000 new homes a year by the mid-2020s but, as these latest figures show, many LPAs will need to identify additional sites to accommodate the latest HDT results. This may also necessitate a strategic review of existing green belt boundaries or increasing densities on existing allocated sites.

“Attaining the volume of housing needed to sustain the UK’s growing population requires a co-ordinated approach to viability, planning, investment and delivery and LPAs need to work closely with private sector partners to unlock unallocated and undeveloped sites, or face being stripped of some of their planning powers.”

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