In November, the very first housing delivery test results will be announced by the government. The test measures the number of homes created by councils against their housing requirement over a three-year period. The draft National Planning Policy Framework (NPPF), published in March, says that, where the test indicates that delivery has fallen below 95 per cent of the housing requirement, the authority "should prepare an action plan in line with national planning guidance, to assess the causes of under-delivery and identify actions to increase delivery in future years".
Analysis by Planning (PlanningResource, 20 April 2018) shows that 46 per cent of English local planning authorities had a delivery rate of less than 95 per cent between 2014 and 2017. For various reasons, our methodology does not match exactly that the government will use. But if future performance trends match previous ones, our figures indicate that almost half of councils may have to start preparing such plans from November.
New draft Planning Practice Guidance (PPG), published shortly after the NPPF, states: "The [action plan's] purpose is to detail the reasons for under-delivery and the steps the authority intends to take in mitigation and drive up delivery in the area. A good action plan will identify ways to reduce the risk of further under-delivery and set out the case for measures to maintain or improve levels of delivery."
Authorities should involve "relevant stakeholders" such as developers, infrastructure providers and upper-tier or neighbouring councils. They should also publish their action plan within six months of the delivery test results’ publication every November, it added.
While many authorities already document their delivery rates in their annual monitoring reports and housing land supply studies, practitioners say some are more proactive than others.
"This goes a little beyond the scope of current annual monitoring," said Paul McColgan, associate director at consultancy GL Hearn. "It will require the council to go further into the reasons for under-delivery rather than just look at the figures themselves. They will also need to ensure they have the expertise either in-house or at hand to advise on ways to drive up delivery."
Helen Reid, principal planner at consultancy Boyer, said: "There’s also a new emphasis on collaboration with key stakeholders which hasn’t been done before. This is probably what councils are not doing enough of at the moment."
The PPG’s recommended remedies, such as local plan reviews or revisiting strategic housing land availability assessments (SHLAAs), have prompted concerns about the impact of the action plans on over-stretched council planning teams.
"It may require a further call for site process or more frequent pre-planning application discussions, both of which will require man hours," McColgan added.
Richard Crawley, PAS programme manager, said: "Some councils – particularly those who struggle with a five-year land supply – already have their data well marshalled. Councils such as this have told me [that meeting the new requirement] is a process of bringing it together and making a snapshot. For others – smaller councils and those where staff turnover has reduced their ability to form personal relationships with the local developers – it’s going to be a very difficult task."
Nicky Linihan, housing delivery spokeswoman at the Planning Officers Society (POS), said: "It could be hard for some of the smaller authorities if they have limited staff resources. They may also be looking at a number of smaller sites to deliver their strategy, which means there would be more developers and landowners to engage with."
POS has also expressed concern that the list of recommended actions in the PPG to boost delivery is too long. Linihan noted: "There’s a risk it will be seen as a minimum to be addressed. Local authorities should focus on the main causes for particular sites and how they should be tackled, so they can concentrate resources in the right place."
Jonathan Dixon, associate director at consultancy Savills, expressed a further worry about a lack of compulsion in the PPG for authorities that are not subject to more severe delivery test penalties – such as the NPPF’s presumption in favour of sustainable development – to actually implement the actions they identify in their plans.
If action plans do what the government intends, consultants said developers and landowners would welcome the opportunities for more engagement with councils and the potential identification of more sites.
But Dixon warned: "If authorities seek to tighten controls on development, for example by reducing timescales for implementation, then this could have the opposite effect to that intended, increasing barriers to delivery and reducing the amount of housing coming forward."
Smaller developers could also stand to benefit, he said. "If there is a shortfall in supply, those small sites of 50 units or less could be brought forward to plug the leak. To increase delivery over a three-year period, authorities will want sites to come forward from scratch in a year or two – bringing forward larger schemes would take longer."
Crawley added: "The idea that councils should be able to marshal a picture of ‘what is going on out there’ and think about how to collectively respond to changing markets or new opportunities is completely sensible. But the reality is that councils have actually fairly limited ways in which to intervene and any such interventions take an enormous length of time to bear fruit."
ONE BOROUGH’S ACTION PLAN EXPERIENCE
One authority that has already trialled the use of housing delivery test action plans is Swindon Borough Council. David Dewart, the council’s planning manager, said it was one of about a dozen authorities that took part in a pilot scheme set up by the Local Government Association’s Planning Advisory Service (PAS). The authority started preparing the plan in December, before the Planning Practice Guidance was published, and spent three to four months working on it, he said. The plan itself has not been published, said Dewart, but the results were presented to MHCLG about two months ago.
The council’s action plan did not follow all the detail outlined in the PPG, according to Dewart, who described it as "a bit more high-level".
He said: "In Swindon, we are heavily reliant on large urban extensions to deliver our housing requirement. We identified the need to broaden the portfolio of sites we allocate for development to ensure that smaller sites can come forward alongside big urban extensions." The council wanted to encourage more activity by smaller builders as well as volume house-builders, said Dewart, to produce a wider range of new homes to better meet local demand.
The council would achieve this through a review of its local plan, he added. But, ahead of the review, it is also pursuing interim measures such as working on a new SHLAA to identify a range of sites suitable for new housing.
According to Dewart, preparing the action plan was not a burden on planning team resources. He said: "We were doing the thinking on this issue already. It was about putting that into writing in a coherent format. It wasn’t particularly time-consuming or beyond our day-to-day jobs of monitoring housing delivery and understanding which policies are working and which aren’t."