Housing Delivery Test likely results

The NPPF still promises that, “The Secretary of State will publish the Housing Delivery Test results for each local authority in England every November” although to date it is usually published the following January (NPPF page 67).  Less well publicised are housing delivery figures, which were published yesterday.  These are the performance figures that the DLUHC is yet to mark.  While we await the test results, what can we glean from a look at the raw exam papers?

Housing Delivery figures

The housing delivery figures are provided in the ‘Net additional dwellings by LPA’ and ‘Communal Accommodation’ set out in DLUHC's Live Tables 122 & 124, published on 25th November 2021.  These provide the ‘number of homes delivered’ used in the Housing Delivery Test (HDT).  A significant number of local authorities have seen delivery numbers fall in 2020/21.

The HDT uses the delivery figures for the last 3 years, so it is the three year total for 2018-2021 that matters.  This will be causing some LPAs that performed well 4 years ago (2017-18) and badly this past year (2020-21) to break out in a cold sweat as previously high figures are replaced by the more recent, lower delivery.

Housing requirements

The HDT compares the number of homes delivered against the number of homes required.  While the formula in the rules for the HDT is unlikely to change in the next 2 months, there is uncertainty surrounding the housing requirement figures.  If the HDT were an exam, the rules are the ‘marking guide’ whereas the housing requirement figures are the ‘correct answer sheet’ used by the examining DLUHC. 

Housing Delivery Test estimated results

We don’t know what the housing requirements will be for the 2021 Housing Delivery Test (on which more later) but if they remain unchanged we estimate a slight increase in the number of LPAs with scores of less than 75% and which will in consequence have the 'presumption' applied.

Table 1: Number of LPAs failing the Housing Delivery Test

Although the totals might remain broadly similar, a number of local planning authorities are expected to move between categories.

LPAs with worrying falls in housing delivery

The table below shows those local planning authorities that are potentially at risk of falling into the 'presumption' category, if (and it's a big if) housing requirements remain broadly unchanged.  It highlights those LPAs where the housing delivery figures have dropped and where they would now enter the 'presumption' category if the 2020 housing requirement were applied. It highlights the signficance of the housing requirement figure, which the Government could change with the sweep of a ministerial pen.

Table 2: Drop in housing delivery and expected drops below 75%

* Column J in HDT 2020
** 2018-21 uses 2020/21 figures from Live Tables 122 & 124
*** Only an estimate but if the HDT methodology remains unchanged it should be in the right ballpark

All local planning authority delivery figures are easily accessible in Tables 122 & 124 on the Government's website so if your LPA is not listed above, just look up the relevant figures there.

Possible changes to housing requirements

The only person who knows what will really happen to housing requirements is Michael Gove, the Secretary of State, Department for Levelling Up, Housing and Communities, who to date is being tight-lipped about any future changes to the planning system.  In the House of Commons Housing, Communities and Local Government Committee on 8th November, Matt Vickers asked him, “In their manifesto, the Government committed to building 300,000 homes per year by the mid-2020s, yet MHCLG’s outcome delivery plan makes no mention of the target. Does the target still stand?"

Michael Gove’s interesting reply was: "Yes. I think it is going to be stretching, because of all the other factors that we know about—the rise in the cost of materials, pressure on the labour market as a result of covid and so on—but yes....I am not retreating from the desire to have 300,000 new homes as soon as we can. The key figure, as we have just been discussing, is where and of what tenure. I want to make sure that people recognise that we are not taking the approach of saying, “Let’s hit that target as quickly as possible and devil take the hindmost.” We absolutely want to hit that target, but we also want to take account of beauty, the environment, quality, decency, local democratic control and infrastructure."

A tantalising reply, suggesting the ‘where and of what tenure’ is being actively considered.  We will have to wait until the HDT is published (expected Jan 2022) to see whether any changes will affect this year’s figures.  A technical tweak to the HDT might be a tempting and relatively low profile way for the Government to impact planning decisions whilst avoiding newspaper headlines, if it so chooses.

Impact of the Housing Delivery Test

The consequences of failing the HDT can be very significant.  NPPF footnote 8 defines less than 75% delivery as a Plan being ‘out-of-date’, in which case NPPF paragraph 11d applies a presumption in favour of sustainable development.  This results in decision-makers applying a ‘tilted balance’, which can result in even small housing developments being allowed on appeal as described in my October blog.

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