The Ministry of Housing, Communities and Local Government (MHCLG) has released the Housing Delivery Test (HDT) results for the second year. The results of the first HDT were published in February 2019. The purpose of the HDT is to determine whether councils are meeting their annual housing requirement figure. This housing requirement figure is taken from either a recently adopted plan or calculated using the standard methodology. The HDT has been established so that the Government can monitor housing delivery against their target of 300,000 new homes a year and put in place sanctions to boost housing delivery.
The HDT is undertaken every year and the results are to be published in November each year. Councils are required to provide MHCLG with their housing completion figures each year which are used to determine test results. Each HDT covers a three financial year assessment period, the first HDT was for 2015/16, 2016/17 and 2017/18, the second HDT was for 2016/17, 2017/18 and 2018/19. The results of this second three year period were published in February 2020. The third HDT will be for 2017/18, 2018/19 and 2019/2020 and is likely to be published in November 2020. As each HDT is published it becomes harder for local planning authorities to pass the test without consequence.
There are various sanctions a local planning authority (LPA) will face if they fail to deliver their housing requirement. These penalties for failure increase in severity dependent upon how far short the LPA is off their requirement. The test results that are to published in November 2020 will see the bar raised and LPAs will need to deliver 75% of their housing requirement to avoid presumption in favour of sustainable development.
|Score||Consequence for the LPA|
|95% and above||They have successfully passed the test|
|95% and under||The LPA have to produce an action plan to assess the causes of under delivery and to identify actions to boost housing delivery|
|85% and under||A 20% buffer is applied to LPA’s five year housing land supply|
|45% and under||
Presumption in favour of sustainable development is applied
Across the country results of the HDT vary and so each of the penalties put in place by Government can be seen. There were 8 LPAs who failed to deliver 45% of their housing requirement resulting in the presumption in favour of sustainable development being applied. If the 75% threshold had been applied to these results then a further 50 LPAs would have faced this penalty.
Cheltenham Borough Council has successfully passed the HDT this year with a result of 177% and 108% last year. The housing requirement figure has been taken from the adopted Joint Core Strategy (JCS) (December 2017) despite the Cheltenham Local Plan undergoing examination in 2019 and the likely to be adopted in the summer.
Cotswold District Council has successfully passed the HDT this year with a result of 250% and 268% last year. The housing requirement figure has been taken from the adopted Cotswold District Local Plan (August 2018). It is likely that the LPA will continue to pass the HDT in November 2020 even if delivery falls again as the over delivery will still be within the assessed three year period.
Forest of Dean District Council failed to pass the HDT scoring 89% resulting in action plan being required. The LPA had previously scored 100% in the 2018 HDT. The council now have six months to publish their action plan on identifying the reason for the shortfall and how they are to improve housing growth in the future. It may be that granted permissions that have not been implemented have caused the shortfall. The housing requirement figure has been taken from the adopted Forest of Dean Core Strategy (February 2012). The Local Plan is currently under review which will see an increase in the housing requirement as a result of the standard methodology. This may potentially result in lower score in November 2020 as a result of lack of delivery from a new action plan and an increased housing requirement.
Gloucester City Council has successfully passed the HDT this year with a result of 153% and 143% last year scored last year, seeing an increase of 10% in delivery. This result means there are no consequences for the council at this time and they will be hoping to continue to deliver in this way. The housing requirement figure has been taken from the adopted JCS (December 2017).
Stroud District Council have successfully passed the HDT with a score of 104%. Last year the council scored 94% resulting in the required publication of an action plan which was published in August 2019. The housing requirement figure has been taken from the adopted Stroud Local Plan (November 2015) however this plan is currently under review and as a result of the standard methodology the housing requirement figure has increased. The housing requirement may increase further if the council do not submit their new local plan by November 2020 as there adopted plan would be out of date and the standard methodology would apply.
Tewkesbury Borough Council has successfully passed the HDT for the first two years. In 2019 the council scored 181% last year and this year 174% meaning the council face no penalties. The housing requirement figure has been taken from the adopted JCS (December 2017) but as a result of the council submitting a new Tewkesbury Borough Plan their housing requirement figure may change and a result the HDT results going forward may not be as healthy.
If you have land that is available for development we are able to provide advice on what opportunities may arise in the short, medium, long term as a result of the current housing position of local planning authorities.