The Housing Delivery Test
After much anticipation, the Ministry for Homes, Communities and Local Government (MHCLG) has released the results of the Housing Delivery Test, three months later than initially promised in the NPPF 2018. This will have an immediate impact on those authorities who have been under-delivering on housing.
The Housing Delivery Test is an annual measurement of housing delivery, and is calculated by dividing the total number of net homes delivered over a three-year period by the total number of homes required over a three-year period.
There are transitional arrangements; for the period up to November 2019, the following applies:
- 85%-95% delivery - an Action Plan is to be created to assess the causes of under delivery and how to increase it.
- 25%-85% delivery - a 20% buffer of additional land must be identified.
- Under 25% delivery - the presumption in favour is engaged.
The results show that currently no authority is under 25% delivery. However, there are many authorities in the region where Action Plans are required, or there is an immediate impact on five year housing land supply, as follows:
- Authorities requiring an Action Plan – Arun, Sevenoaks and Worthing
- Authorities requiring a 20% buffer to five year housing land supply calculations – Adur, Brighton and Hove, Guildford, Lewes, Mole Valley, Rother, Tandridge, Tunbridge Wells and Waverley
Revised NPPF 2019
Alongside the Housing Delivery Test, MHCLG also published revisions to the National Planning Policy Framework (NPPF). The changes, whilst minor, provide some key clarifications on issues that had arisen following the publication of the NPPF 2018.
There are four areas in which changes have been made:
1. Local Housing Need Assessment
The amendments confirm that the standard methodology should continue to be based on the 2014-based projections, with market signals capped at 40% rather than the 2016-based projections. The government believes that this will provide stability and certainty to the planning system in the short-term.
The Planning Practice Guidance in relation to this has also been fully updated to help Councils assess their housing needs.
The government will now review the formula and the way it is set using the National Statistics data over the next 18 months to establish a new approach. It is hoped this approach will balance the “need for clarity, simplicity and transparency for local communities with the Government’s aspirations for the housing market”.
2. Housing Land Supply
Footnote 37 has been clarified and expanded to increase certainty in how five-year land supply is calculated. The footnote now states “Unless these strategic policies have been reviewed and found not to require updating. 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.”
The definition of “deliverable” within the NPPF glossary has been amended to provide clarification. The aim of the change is to make “it clearer that non-major sites with outline consent should be considered deliverable unless there is evidence to the contrary”.
Further information on this will be provided through an update to the Planning Practice Guidance.
4. Habitats Regulations Assessment
Paragraph 177 has also been amended, and is now worded to confirm that the presumption in favour is restored if the Appropriate Assessment concludes that the proposals will not adversely affect the integrity of the habitats site (SPA/SAC). The presumption in favour is also restored if any potential impacts can be mitigated successfully.
For more information on how the changes to the NPPF may effect your site, or how the housing delivery test affects five year housing land supply calculations, please contact Fay Goodson or any member of the Planning team.