Hyas have been providing support to the Planning Advisory Service (PAS) to consider the approach to preparing Housing Delivery Test Action Plans as per the requirements set out in the draft National Planning Policy Framework.
Hyas have worked closely with PAS and have led with initial engagement across a number of Councils to understand how to apply the approach in practice and at a local level. The Hyas team facilitated workshops earlier in 2018 to explore key issues and approaches, which has led to the publication of various resources on the PAS website in June 2018. These materials are a work in progress and are anticipated to evolve further through their application in practice.
The Hyas team are currently working with around a dozen pilot Councils across England, helping to take forward the preparation and gathering of evidence and information (a ‘root cause analysis’) and subsequent preparation of Housing Delivery Test Action Plans. We are working with Councils to understand:
- what information and intelligence exists locally relating to housing delivery;
- are there are any gaps in that information;
- how could any potential gaps be filled;
- what the information is suggesting;
- what actions are already underway to improve delivery rates;
- what actions could be implemented in the future;
- what might a Housing Delivery Test Action Plan look like;
- How could it be produced, including who may need to be involved and/or consulted during the process.
We have set out a step by step process to helping consider and evolve an Action Plan in a local area, including what types of initiatives and activities could be taken at a local level to influence delivery rates. Information is available here on the PAS website.
About the Housing Delivery Test & Need for an Action Pan
The Housing Delivery Test measures net additional dwellings provided in a local authority area against the homes required. The methodology for calculating the Housing Delivery Test measurement is set out in the Housing Delivery Test Measurement Rule Book, and MHCLG will publish the Test result for each local planning authority in England annually in November.
The consequences of failing the Housing Delivery Test are set out in the revised National Planning Policy Framework (NPPF). These will apply until subsequent Test results demonstrate that delivery exceeds the required rate in the following year. All local planning authority with a result of less than 95% have six months to prepare a Housing Delivery Test Action Plan. This is set out in the Draft National Planning Guidance (MHCLG, March 2018) as:
“a document produced by the local planning authority to reflect challenges and identify actions to address under-delivery against the housing requirement in the area. The document’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.”
A local planning authority can prepare an Action Plan at any time, irrespective of whether it passes or fails the Test. Indeed a Housing Delivery Test Action Plan can be part of a proactive approach to think ahead, understand and manage potential risks to future housing supply.
A Housing Delivery Test Action Plan is intended to be a practical document, focussed on effective measures aimed at improving delivery within an area. However, issues affecting delivery are likely to vary significantly across the country and within individual areas, so for an Action Plan to be relevant and effective for a particular locality, it needs to be underpinned by evidence and research.
Preparation of a Housing Delivery Test Action Plan requires a good understanding of the issues affecting delivery within a particular area over the last 3 years, to align with the HDT assessment period. It should also have an element of looking forward, to identify potential issues around future delivery