The Framework's November 2020 key date

November 2020 is the date when the Housing Delivery Test ramps up to be fully effective, according to footnote 7 and Annex 1 of the National Planning Policy Framework.  At least that is what the Framework promised.  In practice it is not so much like bonfire and fireworks' night but more like gathering leaves in a gale. 

Sweeping up the Housing Delivery figures

November is also the month that the housing delivery figures are published.  However it will be several months before the Housing Delivery Test results are provided by the Government in mid February. It's almost as if the housing delivery figures have to compost down before being spread as fertiliser on those local planning authorities that are struggling to achieve enough housing growth.

First the leaves are swept up by compiling the raw data on net housing delivery.  This is usually published in mid November at https://www.gov.uk/government/collections/net-supply-of-housing.  Use the link at the top of that webpage to view the ‘Live tables’.  The key ‘live tables’ are table 122, for housing delivery by local planning authority over time, and table 123 for a breakdown of new build, conversions, change of use and demolitions.

Using the leaf pile analogy, 95% of the pile is visible in mid November, but late leaves such as communal housing (students and care homes) need to be swept onto the pile later before the full amount is ready to be composted.

The Housing Delivery Test

The composting process requires mixing two sets of data - the housing delivery figures and the housing needs figures.  The two sets of data are compared using the methodology for the Housing Delivery Test set out at https://www.gov.uk/government/publications/housing-delivery-test-2019-measurement.  The compost of these figures is churned, digested and finally published in mid February at https://www.gov.uk/government/collections/housing-delivery-test.

Winds of change on housing needs

This would be straightforward if it wasn’t for winds of change blowing on the housing need figures, which are currently all "up in the air". 

Changes to the way housing need is calculated were published for consultation in August 2020.  If the proposed methodology is adopted, the new housing need figures will be as set out at https://lichfields.uk/grow-renew-protect-planning-for-the-future/how-many-homes-the-new-standard-method/#method. However in mid-November the Minister Robert Jenrick warned not to rely on the proposed methodology as it could change.

The new “standard method” will come into effect when it is published in the National Planning Practice Guidance, expected over winter 2020/21 in time to feed into the publication of the Housing Delivery Test figures in mid February 2021.

A hurricane on the horizon for housing numbers?

A potential hurricane is on the horizon in the Government’s more radical changes to the planning system which threatens to replace the standard method with housing figures arrived at by an opaque political process.  The hurricane of a future planning system has to first run the gauntlet of parliament and so is not expected for at least 12 months. 

Housing Delivery Test fertiliser for 2021’s growth prospects

The Housing Delivery Test results in February 2021 will act like fertiliser for development in those local planning authorities that are delivering less than 75% of their housing needs, by applying the presumption in favour of sustainable development as set out in paragraph 11 and footnote 7 of the Framework. 

The HDT may have at least one year of effectiveness, providing barren soil for some but potent fertiliser for others.  Last year 54 local planning authorities had below 75% delivery and were anxious about their position come November 2020.  This year, with the winds of change greatly affecting many authorities, the list could be radically different. 

It pays to look ahead and be prepared: a back-of-the-envelope calculation for your LPA comparing the mid-November housing delivery figures and the proposed new ‘standard method’ will indicate potential in your area.  However the final outcome depends heavily on the final ‘standard method’ adopted by the Government and it could be ‘all change’ when the revised methodology is published.  Perhaps you should keep your fireworks for the New Year.

For examples of the Housing Delivery Test being used in appeals, search appeals on our Home page.