Local Plan delivery

Final few local authorities begin the process to deliver an up-to-date plan

• 72% of local authorities have adopted an NPPF- compliant Plan – a total of 222 local authorities across England
• 47% of adopted NPPF- compliant Plans are over five years old and are either under or due for a review
• The last six local authorities have now started the process of delivering an up-to-date plan, following the publication of the NPPF in 2012
• Local authorities yet to adopt an NPPF compliant Local Plan in place have an average land supply of 5.6 years

Every local authority in England has now progressed an NPPF-compliant plan to at least initial preparation stage. Areas that have previously avoided producing an updated Local Plan, including Sevenoaks and Amber Valley, are now engaging in early stages of plan production. Early stage plan production exercises include issues and options consultations and calls for sites.

Local authorities are more actively pursuing the review process, with 29% now revising the strategic policies of existing NPPF-compliant plans, a fall from 35% recorded in April this year. In total, 4% of local authorities have a Local Plan over five years old and have not yet begun the review process; this figure is down from 8% in April this year.

The decline in the number of local authorities with plans due for review or under review indicates that the current system is working effectively. Local authorities are revisiting the strategic policies of their plans with success and in accordance with the NPPF; for housing requirements this means greater alignment with standard approach housing need figures. Any proposed changes to policy around housing need should therefore proceed with caution, or risk upsetting a system that is beginning to operate with purpose.

Final few local authorities begin the process to deliver an up-to-date plan

Five year land supply

Land supply issues are more acute across the South

• As of November 2021, local authorities had an average of 6.1 years land supply. This is a slight decrease from 6.2 in November 2020
• Of local authorities that had a lack of land supply confirmed at appeal in the past year, 35% had a published land supply of over five years
• 16% of local authorities cannot demonstrate a five year land supply and have not adopted an NPPF-compliant plan
• Seven repeat offenders had a lack of land supply confirmed at appeal in the year to November 2020 and the year to November 2021

Nearly a third of local authorities failed to identify sufficient land supply for new housing. 10% of authorities had a lack of land supply confirmed at appeal in the year to November 2021 with a further 23% publishing less than five years of land supply in their most recent statements. For local authorities requiring nutrient neutrality as a condition of planning approval this figure is slightly higher, at 39%. When you include areas that Savills have calculated as having fewer than 4.5 years of land supply, the proportion of local authorities increases to 61%.

Of those claiming a sufficient level of land supply, 17% were found to have fewer than 5.5 years based on Savills’ calculation. Our calculation does not question the deliverability of sites, but instead compares published supply against the most accurate housing need figure. For local authorities without an up-to-date Local Plan, this figure is the Standard Method for assessing local housing need.

16% of authorities have both fewer than 4.5 years of land supply are also currently without an up-to-date Local Plan. Between them, these local authorities have a Standard Method  housing need of 49,000. These local authorities also typically perform poorly against the Housing Delivery Test; we have found that 33% of authorities with insufficient land supply will face the most severe sanction of the test under the 2021 measurement.

Land supply issues are more acute across the South

Housing Delivery Test

Local authorities with no Local Plan in place are more susceptible to the sanctions of the Housing Delivery Test

• 6.7 years - published land supply of local authorities that passed the 2021 HDT
• 5.0 years - published land supply of local authorities that failed to deliver 95% of need and have to produce an action plan
• 5.6 years - published land supply of local authorities that required a buffer for delivering less than 85% of need
• 4.1 years - published land supply of local authorities that face presumption in favour for delivering less than 75% of need

The Housing Delivery Test is the Government’s annual measurement of housing delivery across local authority areas in England. The test uses net additional dwellings and housing requirement figures (either adopted housing requirements or Standard Method Local Housing Need figures) to see how delivery has performed over the previous three financial years. 

Two adjustments to the requirement figures have been introduced by DLUHC – a one month reduction to the requirement for 2019/20 and a four month reduction to the requirement for 2020/21, as announced by the Housing Minister in September this year. DLUHC has not yet published the results of this year’s test, despite all relevant data now being available.

Our calculated results for the test are shown below. These are accurate based on available data, although some local authorities have had unexpected changes to their housing requirements in previous years.

According to Savills calculation, 88 local authorities failed the 2021 Housing Delivery Test (HDT), or 29% of all local authorities across England. Of those failing the test, 51 will face presumption in favour of sustainable development, the most severe sanction of the test, having failed to deliver even 75% of housing need in the three years to March 2021.

Local authorities with no Local Plan in place are more susceptible to the sanctions of the Housing Delivery Test