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Housing Delivery Test: 2021 Measurement

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The Challenge of the test

50 out of 309 English local authorities have delivered less than 75 per cent of their housing requirement in the three years to March 2021. According to the sanctions set out in the 2021 Housing Delivery Test, future planning decisions across these areas will be subject to presumption in favour of sustainable development.

Almost three quarters of all local authorities in England have passed the test under the 2021 measurement, delivering over 95 per cent of their housing requirement in the three years to March 2021. Local authorities passing the test delivered a total of 578,000 homes over this period, against a requirement of 383,000.

The remaining authorities delivered between 75% and 95% of housing requirement over the test period. Those delivering between 75% and 85% of their requirement will need to apply a 20% buffer to their housing need figure in order to mitigate potential future under delivery. Those delivering over 85% will face a lesser sanction, and will simply need to put together an action plan exploring ways to reduce the risk of further under delivery within the next year.


Reduced Requirements

The Coronavirus pandemic resulted in a national lockdown starting in March 2020, and results for two years of the test have been adjusted to reflect disruption caused to the construction sector as a result. For the year to March 2020 this means annual housing requirement in the test is reduced by one month, and for the year to March 2021 housing requirement is reduced by four months.

The reduced measurement has a material impact on the number of homes required over the course of the test across the country. The reduction in five months of housing need across 2020 equates to just under 97,000 homes. This is equivalent to over twice the total annual housing requirement across Greater London.

The outcome of the adjustment is shown in Figure 2, with 66 local authorities facing reduced sanctions as a result of reduced housing requirement. In total, 25 local authorities have escaped presumption in favour of sustainable development, 23 have avoided adding a 20% buffer to future housing need and 18 will not be required to write an action plan.


 

Tackling low supply

At a local authority level, the areas performing poorest on the test are generally those where land supply is heavily constrained. The majority of local authorities that failed to deliver 75 per cent of housing requirement feature some element of Green Belt coverage, for example.

This is not the only land constraint in play, however, and many areas failing to adequately meet their housing requirement are also constrained by National Parks, Areas of Outstanding Natural Beauty (AONB) and Sites of Special Scientific Interest (SSSI). Restriction of land through these designations, and others, has a material impact on how the sanctions of the test operate, with some sanctions posed by the test superseded by land use classification across the county.

Triggering of the presumption in favour of sustainable development under the Housing Delivery Test is one of the routes to the tilted balance within the NPPF. This is relevant for planning applications and planning appeals on land not allocated for housing development. However, planning authorities with land covered by the restrictive planning policies identified in paragraph 11 footnote 7 in the NPPF will not face consequences on such sites as the tilted balance will not be engaged. This makes the hurdle for planning applications and planning appeals that bit higher regardless of the Housing Delivery Test outcome or five year land supply position. Housing Delivery Test results are interesting but despite the categories they hold little practical consequences.

Having reached its fourth year, and measuring against at least 75% of housing requirement, the Housing Delivery Test is now well positioned to challenge areas of historically low housing delivery. However, questions are raised over the true power of the test in tackling the housing crisis, with housing requirement leniency affecting at least the next two years of the test, and sanctions of the test failing to stand up against existing planning designations.

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Source: DLUHC