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Housing Delivery Test - What Local Authorities Need to Know

on Tuesday, 18 December 2018.

The revised National Planning Policy Framework was introduced in July 2018, replacing the NPPF 2012. One of the key additions under the revised NPPF was the Housing Delivery Test...

... And the results of the test for 2018 are due to be published imminently and annually thereafter.

The National Planning Policy Framework (NPPF) sets out the potential sanctions to be imposed on Local Planning Authorities (LPAs) if they fail to plan for and deliver new homes, including operation of the presumption in favour of sustainable development.

What is the Housing Delivery Test?

The Housing Delivery Test is a percentage based calculation, measuring the number of actual homes built against the number of homes required within a LPA. The aim of the test is to ensure that LPAs meet their housing requirements by planning for and building new homes over a rolling three year period. The results will be published by the Ministry for Housing, Communities and Local Government in November of each year.


Under the revised NPPF, where LPAs fail to deliver their plan-led targets at the percentages given below they will face corresponding sanctions.

  • Less than 95% of requirement - LPAs will need to produce an action plan addressing the under-delivery of houses and take steps to rectify the problem.
  • Less than 85% of requirement - LPAs will be required to find a 20% 'buffer' of additional land to deliver housing. This may leave undeveloped land vulnerable to speculative applications.
  • Less than 25% of requirement (rising to 75% in 2021) - in these circumstances the NPPF creates a presumption in favour of sustainable development whereby planning permission will be granted unless the land is protected under the NPPF or the adverse impacts of development outweigh the benefits. This is the most severe sanction LPAs may face and echoes the default position in cases where LPAs are unable to show a five year housing land supply.

According to research conducted by Savills using 2017/18 statistics, around 120 councils may face sanctions following publication of the 2018 Housing Delivery Test results. Research suggests that LPAs are expected to avoid the most severe sanction in 2018.

Impact of the Housing Delivery Test

The implementation of the Housing Delivery Test is just one element of the Government's new strategy to help deliver its target of building 300,000 new homes a year by the mid 2020s. In 2017/18 around 222,000 new homes were built. The Housing Delivery Test will hold individual LPAs accountable and loosen their control over development where delivery targets are not achieved.

Due to the early stages of the Housing Delivery Test, it is difficult to say what impact it will have and how the sanctions will operate in practice. We may have to wait until 2020, after several years of results, to understand the success of the new test. In the meantime, LPAs must ensure that they continue to develop robust plans for development in their local areas and work proactively with developers to ensure efficient build out of consented sites. LPAs may also want to think about how they can use conditions and planning obligations to encourage delivery of housing.

If you would like further information on the Housing Development Test or the impact of the revised NPPF within your LPA, please contact David Bird, a Partner in our Planning Law and Infrastructure team on 0117 314 5382.