The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association

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The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association
The Housing Delivery Test

Workshop / round table one-off
Phase 1 pilots

16th March 2018            www.local.gov.uk/pas
The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association
Today
•   Welcome & introductions
•   We hear from some of the pilots
•   MHCLG / NPPF / NPPG / rule book
•   What have we learned from phase 1 ?
•   What could we do for phase 2 ?
•   What do practitioners want to make their lives
    easier ?
The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association
Introduction
• We did a series of roadshows / introductory
  events on the HDT
• We hoovered up a variety of views from
  around the country
• We asked for some volunteers
  – We had lots - so we divided them up into phases
  – Most of phase 1 is here
     • Thank you!
The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association
Introduction
• This is a small, informal session
• Pilots mean
  – learning, trying, making (discovering) mistakes
  – not knowing things
• Chatham house rules
  – Be frank
• OK ? Anything else ?
The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association
The pilots
•   Carlisle
•   Newcastle & Gateshead
•   Milton Keynes
•   Swindon
•   Lichfield
The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association
Housing Delivery Test Pilot
                              Housing Delivery Test Pilot
                                Carlisle City Council

                                      16 March 2018

                                      Fiona Kenmare
The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association
Carlisle in Context
                 Housing Delivery Test Pilot
The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association
Carlisle in Context
                 Housing Delivery Test Pilot
The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association
Housing Delivery Test Pilot        Monitoring of Housing
                              • Core Indicators for the Annual Monitoring
                                Report [introduced 2004]

                              • Housing Flows Reconciliation

                              • Carlisle City Council employed a
                                dedicated monitoring officer
The Housing Delivery Test - Workshop / round table one-off Phase 1 pilots 16th March 2018 - Local Government Association
In house bespoke database
                            Housing Delivery Test Pilot
Carlisle District Local Plan 2015
                                           – 2030
Housing Delivery Test Pilot

                              • Adopted November 2016
                              • Stepped Approach to Housing
                                – 2013 to 2030 – 478 net new dwellings
                                – 2020 to 2030 – 626 net new dwellings
                              • Monitoring Framework
Housing Delivery Test Pilot
                                                                               Housing Trajectory
                                                           Total/           o/s at         u/c at         Completed
                                                           Potential        01/04/17       01/04/17       16/17       17/18   18/19   19/20   20/21   21/22   22/23   23/24       24/25       25/26       26/27       27/28       28/29       29/30       30/31   31/32   onwards

                              Sites with Planning Permission

                              land North of Kingmoor Ind
                              Estate                                   65          65                 0           0       0       5      20      20      20                                                                                                                     0

                              Raffles                             333             115             30             11      30      30      30      25                                                                                                                             0

                              U 8 land North of Burgh
                              Road 15/0621                             66          66                 0                                   6      30      30                                                                                                                     0

                              Caxton Road, Newtown Ind
                              Estate 15/0878                           63          63                 0           0                       3      20      20      20                                                                                                             0

                              U15 Former Dairy Site,
                              Botcherby                                66          66                 0           0      20      46                                                                                                                                             0

                              50 Victoria Place                        50              0              0          50                                                                                                                                                             0

                              Old Brewery Halls of
                              Residence                                36          36                 0           0       0      36                                                                                                                                             0

                              Portland Sq/Alfred St/
                              Brunswick St                             21          21                 0                                  10      11                                                                                                                             0

                              Leabourne Road                           13          13             10              0      10       3                                                                                                                                             0

                              Hammonds Pond                       318             221             23             48      40      35      35      35      35      35           6                                                                                                 0

                              West Wigton Road
                              (Brackenleigh)                      303              93             39             48      40      35      18                                                                                                                                     0

                              U 5 Land between Carleton
                              Rd & Cumwhinton Rd
                              (Speckled Wood)                     189             155             49             34      40      35      35      35      10                                                                                                                     0

                              U 14 & 19 Carleton Clinic           189             189                             0      35      35      35      35      35      14                                                                                                             0

                              U 4 land North of Moorside
                              Drive/ Valley Drive                 150             150                                            15      35      35      35      30           0           0           0           0           0           0           0                         0
Housing Trajectory
             Housing Delivery Test Pilot
Allocated sites Urban Carlisle:                                        Area (ha)   Indicative Yield   Indicative yr Delivery       Planning Permission             Actual Yield       Date start delivery

U 1 - Land to the south east of junction 44                              8.03            217                2015 - 20                      (part site)
                                                                                                                                                                        190

                                                                                                                                    14/0761 OUT 17/09/15
                                                                                                                                                                     (7.58 HA)

U 2 - Land north of California Road, east of U 1                         6.54            200                2020 - 25

U 3 - Site of PennineWay Primary School                                  3.57            112                2020 - 25

U 4 - Land north of Moorside Drive/ValleyDrive                           4.96            140                2015 - 20               15/0161OUT 13/05/16              150 - OUT

                                                                                                                                  15/0038 RM undetermined            166 - RM

U 5 - Land between Carleton Road and Cumwhinton Road                     7.25            204                2015 - 20                                                   189                  June 16

                                                                                                                               (part Site) 13/0983 FULL 29/09/15

                                                                                                                                                                     (5.79 HA)

U 6 - Land at Garden Village,west of Wigton Road                         6.08            169                2020 - 25

U 7 - Land at Newhouse Farm, south-east of Orton Road                   30.19            509                2020 - 25

U 8 - Land north of Burgh Road                                           2.83            66                 2015 - 20               15/0621 OUT 15/06/16                 66

U 9 - Site of former Morton Park Primary School, Burnrigg                1.67            54                 2020 - 25          Part Site 17/9003 FULL 07/02/17           60

U 10 - Land off Windsor Way                                             10.60            300                2015 - 20                      Part Site                    277
                                                                                                                                 14/0778 FULL awaiting S106
                                                                                                                                           Rest Site
                                                                                                                                 17/0093 FULL undetermined               19

U 11 - Land east of Lansdowne Close/Lansdowne Court                      2.50            75                 2020 - 25

U 12 - Site to the rear of Border Terrier,Ashness Drive/EllesmereWay     0.40            18                 2015 - 20               14/0975 FULL 16/01/15          18 (affordable)      Complete 2016/17

U 13 – Land east of BeverleyRise                                         1.20            30                 2020 - 25

U 14 – Land north of Carleton Clinic, east of Cumwhinton Drive            9.3            189                2015 - 20               15/0918 FULL 04/05/16               189          U/C Expected Spring 2017

U 15 – Former Dairy site, Holywell Crescent, Botcherby                   1.51            66                 2015 - 20               13/0655 OUT 26/03/14

                                                                                                                                                                         66

                                                                                                                                  17/0254 RM undetermined

U 16 – Land at DeerPark, Belah                                           3.83            100                2020 - 25

U 17 – Land to the south west of Cummersdale GrangeFarm                  2.43            60                 2020 - 25             15/0924 OUT awaiting S106              60

U 18 – Land Opposite RosehillIndustrial Estate                          10.50            150                2015 - 20

U 20 – Durranhill Road                                                   3.32            70                 2020 - 25

U 21 – Laing’s site, Dalston Road                                        1.20            50                 2020 - 25
Housing Delivery Test
                                          Assessment
Housing Delivery Test Pilot

                              • Local Plan Annualised Target 2013 – 2020
                                = 478 per annum
                              • Delivery 2014 – 2017 = 419 + 502 + 541 =
                                1,462 - Annualised delivery average 487
                                per annum
                              • The housing delivery test confirms delivery
                                at 101.88% of local plan annual target
                                therefore no action plan needs to be
                                published or any change to the ‘buffer’ of
                                5% currently implemented.
Housing Delivery Test Pilot                Challenges
                              • Challenging Housing Target

                              • Limited no of developers

                              • Limited Housing offer due to above

                              • c. 2,000 permissions do not have a
                                developer attached to them
Housing Delivery Test Pilot                           Actions
                              • Corporate Priority:
                                  – Economic Liaison Panel
                              • Utilise existing forums:
                                  – Cumbria Housing Supply Group
                                  – Registered Provider Partnership

                              •   Proactive contact with HBF
                              •   Release of Council owned land
                              •   Positive Development Management
                              •   Promoting Carlisle
                                  – Prospectus
                                  – Garden Village
                                  – Bidding for funding
Housing Delivery Test Pilot                 Outcomes
                              • Improvements in housing delivery

                              • Attracted New Developers
                              • Interest being generated around St
                                Cuthbert’s Garden Village
Economic Benefits   Housing Delivery Test Pilot
Thank You
Housing Delivery Test Pilot
v   Providing a range and choice of
    housing - 30,000 homes
v   Allocating Neighbourhood and
    Village Growth Areas
v   Maintaining and improving existing
    communities
v   Bringing empty properties back into
    use
v   Creating Lifetime neighbourhoods
v   15% affordable housing
   Core Strategy targets in stepped phases.
   20% buffer for past, persistent under delivery.
   Brownfield sites with low values and constraints.
   Multiple developers and landowners on larger sites.
   Unmotivated landowners.
   Strategic infrastructure funding and delivery.
   Newcastle CC set up a ‘Fairer
    Housing Unit’ to facilitate delivery.

   Use of Council assets, procurement
    of delivery partners, HRA, annuity
    lease back, grant funding.

   Gateshead focus on small and
    medium scale sites.

   Stakeholder engagement.

   Permission in Principle
   Improve the type of data we hold.
   Really get to the bottom of things – “root causes”.
   Reality check.

BUT..

   Concern that developers could use data as a “stick
    to beat Council with”.
   “Cherry picking” of easier greenfield sites.
   Future pressure to look for further sites in Green
    Belt.
Swindon Borough Council
Housing Delivery Test Pilot Project
       Emerging Findings

                      Planning Policy
Introduction

Root Cause Analysis focussed on following themes:
1. Swindon’s Development Strategy
2. Swindon’s housing trajectory
3. Swindon’s Housing Land market
4. House Builders active in Swindon
5. Housing demand in Swindon
Swindon’s Development Strategy
Local Plan Development Strategy

           Tadpole Farm:
           1,695 + 5ha         Kingsdow
           emp                 n: 1,650

                                                     NEV:
                                                     8,000 +
                                                     40ha emp

           Wichelstowe:
           4,500 +12.5ha emp
                                    Commonhead:
                                    890 + 15ha emp
A robust housing trajectory
“Planned housing trajectories should
 be realistic, accounting and
 responding to lapse rates, lead-in
 times and sensible build rates. This is
 likely to mean allocating more sites
 rather than less, with a good mix of
 types and sizes, and then being
 realistic about how fast they will
 deliver so that supply is maintained
 throughout the plan period. Because
 no one site is the same – and with
 significant variations from the
 average in terms of lead-in time and
 build rates – a sensible approach to
 evidence and justification is required.”
http://lichfields.uk/media/1728/start-to-finish.pdf
Swindon’s Development Strategy and Trajectory
Action Plan Recommendations

• Explore ways to compress the period between allocation and delivery
  (including new delivery models)
• Be more rigorous in preparing the housing trajectory – which needs
  to be more robust / resilient / “future proofed”
• Don’t place too many eggs in one basket by allocating ‘overly large’
  urban extensions (1,000-2,000 are “just right” to ensure deliverability
  without triggering big ticket infrastructure)
• More work to understand if a house builder is on board at the
  allocation stage to provide certainty of delivery
Swindon’s Housing Land market
Local Plan Development Strategy

           Tadpole Farm:
           1,695 + 5ha         Kingsdow
           emp                 n: 1,650

                                                     NEV:
                                                     8,000 +
                                                     40ha emp

           Wichelstowe:
           4,500 +12.5ha emp
                                    Commonhead:
                                    890 + 15ha emp
Swindon’s Housing Land market
Action Plan Recommendation

• Use the LP review to allocate a full mix of sites in a range of locations
• Develop the Swindon housing sites portal to bring greater
  transparency to Swindon’s housing land market
• Consider opportunities to bring forward SHELAA sites early
• Push forward with releasing the Council’s own land holdings for
  housing development
House Builders active in Swindon
Survey of SME house builders – “what
is your most serious business
challenge”:

The planning process (40%)
The availability and cost of land (37%)
The availability of finance (20%)

Source: National House Building Foundation Report
                              Planning Policy
House Builders active in Swindon
Action Plan Recommendations

• Use the LP review to bring forward sites suitable for SMEs
• Improve planning application processes so that they are more
  responsive to the needs of SMEs (show the love to SMEs)
• Identify and tackle barriers to entry for new housing developers in
  Swindon
Housing demand in Swindon
Creating Demand
A more “liveable place”
Housing Demand in Swindon
Action Plan Recommendations

• Take account of where people want to live as a consideration as to
  where sites are allocated
• Ensure that we plan for the full spectrum of housing types / housing
  models
• Be more proactive in bringing forward sites in areas where we the
  planners want people to live (place making)
• Use LP Review to create a more supportive policy framework for
  delivering schemes in Central Swindon
• Review CIL approach
Summary

Root Cause Analysis work identified following challenges:
• An ambitious Development Strategy
• An optimistic housing trajectory
• Weaknesses in Swindon’s Housing Land market
• Limited range of House Builders active in Swindon
• Weak housing demand in parts of Swindon

Action Plan would identify measures to meet these challenges
Root Cause Analysis / Housing Delivery Test
The expectations in terms of your contributions are pretty much as we
discussed last week. So, if you are able to do 5 or 6 slides and talk (say 15
mins) about your experiences so far with the HDT and particularly any
thoughts around gathering the data; using the templates; and next steps in
terms of actions and implementation, that would be great.

On the ‘Action Plan’ there is a view that seems to be emerging that a simple
‘headline’ table is probably a good way to capture the key components and
remove the need to have large amounts of sensitive data and analysis in the
‘public’ form. This would be fed by the more detailed spreadsheet that you
have already had a go at. Attached is a very simple template/table that is
emerging. It feels like it could work alongside the headings and bullets that
you sent me from your draft work.

It should, in our view, include both measures to unlock stalled sites and
measures to bring forward additional land for residential development,
particularly where delivery falls substantially below requirements.
Pilot Authorities
   Milton Keynes: Current Position

• Early review of delivery based on information in the HWP. Reported to Cabinet 02/01/18
  (delivery at 74%) – to raise awareness & secure commitment for action.
• MKC good understanding of the local housing market. Data for analysis drawn from
  quarterly and annual housing monitoring and reviewing the progress of a cross section of
  key site typologies through the planning process and beyond to final completion. Also
  used data from the OUT and REM applications on key sites to plot the ‘development
  pipeline’, illustrating the journey through various stages of the planning process.
• Reviewed the number of housebuilders active across the Borough. Also raised some
  issues stemming from anecdotal evidence.
• Report was discussed by key service heads and the Councils internal Growth Delivery
  Board (comprises a number of Council departments including, Housing, MK Development
  Partnership and Your:MK (regeneration). Co-operation and joint work should improve
  further given Cabinet support for the recommendations.
• Not yet ready to prepare Action Plan, current priority to develop internal and cross-party
  agreement to delivery. Initial focus on high level, cross cutting issues and actions. Need
  to add to this with more site by site analysis of causes and actions
Pilot Authorities
   Milton Keynes: Key Issues: Action Planning

• Political: delivery of new homes is not always prioritised in member-led decision making –
  e.g. greater priority given to road layout, car parking standards etc. Inconsistency of
  decision making.
• Parking Standards: SPD adopted in 2016 with emphasis on avoidance of tandem parking,
  and increased standards for smaller dwelling sizes. Resulting in reduced number of homes
  on otherwise constraint free sites and can be a ‘deal breaker’ on certain sites.
• Milton Keynes Housing Market: dominated by a few key landowners and handful of
  volume housebuilders on small amount of large sites.
• New town legacy: ‘traditional’ housing growth focussed on serviced, greenfield sites, with
  few constraints. Perpetuated by role of ‘master builders’ eg Gallagher Estates continuing to
  provide serviced sites. Little interest from major housebuilders in urban, brownfield sites.
• Strong local economy: limited uptake of office to residential conversion.
• Long delivery pipeline for major sites: impacted by Council processes for imposing
  planning conditions and negotiating S106 agreements.
Pilot Authorities
   Milton Keynes: Potential Actions 1: Action
   Planning

• Decision: Cabinet 02/01/18 agreed to development of comprehensive Action Plan to
  increase and accelerate delivery. Report identifies a number of cross-cutting actions to be
  included based on the analysis.
• Political: develop cross-party agreement on the importance of delivering new homes.
  Work to start post May elections (independently facilitated).
• Corporate: align relevant Council Service areas to prioritise delivery of homes and what
  they need to support this. This happens before the political engagement. New Housing
  Strategy due imminently and potentially creation of Housing Challenge Board to work
  more closely with providers.
• Partnering with neighbouring LPAs – currently seeking a Housing Deal along the lines of
  Oxfordshire.
• Process- seeking to make greater use of PPAs; internal Growth Delivery Board to act
  corporately on delivery issues; revised scheme of officer delegation in June 2017 should be
  starting deliver benefits of speed and efficiency in determining applications.
Pilot Authorities
   Milton Keynes: Potential Actions 2 Action
   Planning

• S106: prioritise delivery of homes and affordable housing when negotiating planning
  obligations.
• Planning policy and guidance: review the impact of current local parking standards on
  delivery of homes (as an e.g.).
• Land Assembly: develop a model to use CPO on suitable sites (eg using brownfield register)
  and work with development partners to deliver.
• New models of delivery: explore models e.g. Community Land Trusts, co-living, self-build
  and off-site construction to deliver more small sites and diversify the Milton Keynes
  housing supply.
• Landowner engagement – develop closer working with key landowners to understand
  delivery programmes, blockages and to hold developers to account.
• Marketing Strategies – proactively market MK to potential development partners (like at
  Homes 2017); particular focus on opportunities in Central Milton Keynes (‘prospectus’
  being developed currently).
The pilots - Lichfield
•Cabinet report underway on delivery issues /
 projections to estimate New Homes Bonus
•Traditionally monitor on an annual basis but
 Leadership have requested more frequent
•Computerised database assists with accessing
 information on s106 triggers
•Historical monitoring issues mean root cause
 analysis has been daunting task to collect
 data from multiple sources
The pilots - Lichfield
• Reviewing officer resource to see if it can be
  improved to meet the challenge
• Major problems with large sites not delivering
  and not even being implemented - struggling
  to understand reasons why
• May have to review approach to site
  allocations in Local Plan review
• Are looking at a CPO on one site to unblock
  delivery – but only 12 homes
The pilots - reflections
•Recognition that the HDT will encourage
 Councils to get a better understanding of
 issues affecting delivery
•Will lead to considering delivery issues earlier
 in the process – at policy stage
•Can help raise housing delivery to Corporate
 level – needs a corporate effort to solve
•Some innovative practice already out there – in
 relation to both policy and implementation
The pilots - reflections
•Collecting and co-ordinating data is time
 consuming and resource intensive
  • especially if starting from scratch
  • turning them into action plans is hard too
•Helpful to align data requirements with 5YHLS
  • Does the NPPF/G assist?
•Large sites often slow to deliver
  • due to range of factors such as appetite;
    infrastructure funding; market etc.
The pilots - reflections
•Concern at how much Council’s can
 significantly influence delivery rates
•May discourage ambitious growth targets

•... Anything else ?
Housing Delivery Test

PAS Workshop – 16 March 2018

Teodora Boarta                 61
Overview

The Housing Delivery Test (HDT) is an annual measurement of housing delivery in a
plan-making authority area.

Through the HDT, the government wants to place local authorities in the driver’s seat of
housing delivery by making them accountable for delivery in their areas, beyond granting
planning permissions.

•   The policy and consequences for under-delivery were first introduced in the Housing
    White Paper in February 2017. At Budget 2017 we announced that the presumption in
    favour of sustainable development will apply at 75% of housing delivery after 2020,
    which we are now consulting on through the draft revised National Planning Policy
    Framework (question 12).

•   The HDT result will be published for individual local authorities, annually in November
    on the Gov.uk website, based on the calculation rules set out in the HDT Measurement
    Rule Book.

•   An explanation of how consequences apply to local authorities and details on what an
    action plan should include are set in Draft Planning Practice Guidance.

                                                                                              62
HDT Measurement: Formula

HDT/        Non-           Development corporations   Development corporations       Metropolitan   London     National
authority   metropolitan   with plan making and       without full plan making and   boroughs       boroughs   Park
area        districts      decision taking powers     decision making powers                                   Authorities
Applies          ü                   ü                                                    ü           ü

Does not                                                          ü                                                ü
apply

 HDT Measurement Formula

                                                                                                                             63
HDT Measurement: Net homes delivered

 The number of net homes delivered is the net additional dwellings, with an adjustment
 for student and other communal accommodation.

 The net homes delivered figure over a rolling three year is calculated as the total of:

    1. Net additional dwellings:
 National Statistic for annual net additional dwellings in England

    2. Student communal accommodation:
 Apply a nationally set ratio* to the total number of student communal accommodation.

    3. Other communal accommodation:
 Apply a nationally set ratio* to the total number of other communal accommodation.

 Areas with a high number of demolitions are able to reflect this in their housing requirement set out in
                  their strategic plan by using stepped requirements as appropriate.
*The nationally set ratios for student and other communal accommodation will be based on the average number of
students in a student household, or the average number of adults in a household, from England Census data against the
number of bedrooms provided in student or other communal accommodation, respectively. These nationally set ratios       64
will be published by MHCLG.
HDT Measurement: Homes Required part 1

   The number of homes required, used for HDT calculations, is …
    … the lesser between:                          Local Plan              Joint Local Plan             Development                    Local Plan in an
                                                                                                      Corporations (with full         area covered by a
    Local housing need figure
    (or projected household growth
                                                                                                      plan & decision making power)        Spatial
                                           •    Stepped housing
    for 2014-15 to 2017-18)                     requirement                     Apportioned                                             Development
                                           •    Annual average                     housing                                            Strategy e.g. London
  … if the latest adopted housing               housing requirement            requirement, or                                               boroughs
  requirement:                             •    Lower end of the                joint housing
  • Is less than 5 years old, or                range, if LHN +              requirement, if the       Housing requirement
                                                                                                                                             Housing
                                                neighbour’s need, or        former not available        in the Development
  • Has been reviewed and does                                                                                                           requirement in a
                                                middle point of the                                         Corporation’s
    not need revising (with review                                                                                                          Local Plan
                                                range otherwise                                              Local Plan
    published online).

   … if the latest adopted                                                                              Apportioned housing            Apportioned housing
                                                                             Local housing
   housing requirement:                                                                                    requirement, in a           requirement in a LHN-
                                                                            need figure for            borough/district plan or a
   • Is more than 5 years old;                 Local housing need           individual local                                          compliant SDS that is <
                                                                                                       LHN-compliant SDS that             5yrs old (or with no
   • Has not been reviewed;                     figure (or projected         authorities (or           are < 5yrs old (or with no       revision needed) OR
     or                                        household growth for             projected                revision needed) OR             local housing need
   • Has been reviewed and                     2014-15 to 2017-18)          household growth        local housing need figure         figure if > 5 yrs old, has
     needs revising.                                                         for 2014-15 to          if > 5 yrs old, has not been       not been reviewed or
                                                                                2017-18)            reviewed or needs revising              needs revising

  Changes to housing requirement within the HDT three year period

1. When
   within the HDT three-year period then the new housing 2. figure becomes out of date during the
          a new housing requirement figure is adopted       Where a housing requirement
                                                                                                                3. Ifortherequires
                                                                                                                             figure has not been reviewed,
                                                                                                                                   revision, the HDT measurement
requirement will be used for the HDT calculation from the      HDT period, the figure will be used for the       will be based on local housing need (or
start date of the strategic plan period. The HDT can be        HDT measurement up to the fifth                   projected household growth for 2014-15 to
updated any time during the year to reflect these changes      anniversary of the plan’, unless a review         2017-18) from that point onwards.       65
with immediate effect.                                         confirms that this does not need revising.
HDT Consequences

If delivery of housing falls below the housing requirement, then certain consequences will
apply, with immediate effect from the publication of Housing Delivery Test results, depending
on the level of delivery:
    Starting from         Nov 2017 onwards         Nov 2018        Nov 2019     Nov 2020 onwards

    Under-delivery
   against planned
     development

                        95%             85%          25%             45%              75%

LA’s to publish an
Action Plan

Plan for 20% buffer
on the 5-year land
supply
Presumption in
favour of sustainable
development

 The consequences will apply until subsequent Housing Delivery Test results demonstrate that       66
             delivery exceeds the required rate of delivery in the following year.
How will Housing Delivery Test
                                                                consequences apply to…

… Areas with a joint plan?                                   … Areas covered by a spatial development
                                                             strategy?

   HDT consequences will apply to all local planning            HDT consequences will apply to local planning
authorities with a joint plan collectively if the housing    authorities covered by a spatial development strategy
figure used to measure against the delivery test is the      individually, as triggered by the level of under-delivery
joint housing requirement, and will apply individually if    of each.
the housing figure used is the apportioned one.

… PPTS Gypsy and Travellers housing requirement?

   Where applicable, the housing requirement for gypsies & travellers under the PPTS will be added to the
NPPF requirement. Plan-making authorities should inform MHCLG of their housing requirement for gypsies and
travellers under the PPTS through the annual HDT data collection.

                                                                                                                   67
How will Housing Delivery Test
                                                      consequences apply to…
… Areas with Neighbourhood Plans?
We have set out in policy that for some neighbourhood plans in defined circumstances, the adverse
impact of allowing development in conflict with the plan is likely to significantly and demonstrably
outweigh the benefits. These circumstances are where the neighbourhood plan:
• has been passed at referendum two years or less before the date the decision is made.
• contains policies and site allocations to meet the neighbourhood area’s identified housing
  requirement;
• the local planning authority has at least a three year supply of deliverable housing sites, when
  assessed against its five year supply; and
• the local planning authority has delivered at least 45% of its housing requirement over the past three
  years (as assessed against the HDT).

There are also two transitional arrangements for the policies relating to this protection, which are
contained in paragraph 212 of the NPPF.
• The first allows the protection to apply to neighbourhood plans that were approved at referendum
  more than two years before the application is decided, if they meet the other criteria set out above, up
  to and including 11 December 2018.
• The second relates to the 45% housing delivery threshold. In line with the transitional arrangements
  for the HDT (set out in paragraph 211 of the Framework), the protection for neighbourhood plans will
  apply where housing delivery is at least 25%, as measured by HDT in November 2018. The 45%
  threshold will apply from the November 2019 HDT measurement onwards.
                                                                                                             68
HDT Consequences: Action Plan
The action plan is 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.

It is a locally-owned document created with the purpose to detail the reasons for under-delivery and the steps the authority
intends to take to mitigate and drive up delivery in the area.

Who produces an action plan?
Local planning authorities, in           Local planning authorities where     Although the Housing Delivery Test does not apply
collaboration with key stakeholders,     delivery meets, or exceeds, 95%      to National Park Authorities and development
where delivery is below 95% of their     of their housing requirement may     corporations without all plan making and decision
housing requirement, as set out in       wish to produce an action plan as    taking functions, if the identified housing need is
an up to date plan, are expected to      a matter of good practice or to      not met for these areas we would encourage the
produce an action plan. This will        identify processes to exceed         use of an action plan to help identify causes of
apply for each year of under-delivery.   housing targets in order to          under-delivery and actions to address these.
                                         demonstrate best practice.

Who can be involved in the creation of the action plan?
The action plan needs to be produced by the local planning authority, involving relevant
stakeholders in the process. Representatives of those with an impact on the rate of              What is the time-frame for an
delivery in the area should be included, such as, but not limited to:                            action plan?
• Small and large developers;
• Land promoters;                                                                                To ensure the document is of
• Private and public land owners;                                                                optimal impact, local planning
• Infrastructure providers (such as utility providers, highways, etc);                           authorities should publish an
• Upper tier authorities (County Councils) in non-unitary areas;                                 action plan within six months of
• Neighbouring authorities with adjourning or cross-boundary sites.                              the publication of the Housing
                                                                                                 Delivery Test result.
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          The Draft Planning Practice Guidance sets out what local planning authorities
          can take into consideration when creating the action plan (pages 22 & 23).
Thank you for listening!

    Any questions?

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Lunch
Preparing an Action Plan
Process & Tools

                           72
Preparing a Root Cause Analysis
Creating an evidence base

Existing data will be useful:
• 5 year housing land supply data; Annual Monitoring Report; SHLAA
• Any capacity assessments you may have undertaken
• Data/information relating to Section 106’s for large sites (there may
  be relevant triggers on numbers of homes etc.)
Questions to reflect on:
• Do you currently categorise this information into typologies etc.?
• Do you have strategic sites that are critical to delivery rates?
• Do you have regular contact/forums/discussions with developers
  either collectively or individually?
• Are there very clear and obvious issues affecting delivery in your area
  -how do you know this to be the case?
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Preparing an Action Plan
Issues to consider

The NPPG provides clear advice – but some additional practicalities
• A robust root cause analysis will lead to more appropriate actions
  being identified
• A meaningful Action Plan (as opposed to tick box exercise) requires
  effort - start early as some actions could be controversial and may
  need wider buy in
• Test your appetite for proactive measures such as purchasing land,
  partnering with RSL’s to deliver, bidding for external funding etc.
• Actions could be site specific (strategic sites) and/or more generic
  (encouraging more housebuilders into the area)
• Consider policy responses – allocating more land, smaller sites, better
  PPA processes, etc but will take time to be effective
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Preparing an Action Plan
Issues to consider

 • Preparing an effective Action Plan is a joint effort – other
   Departments; other authorities, external agencies (e.g. Homes
   England) and will require preparation and planning
 • Encourage Corporate buy-in and sign off
 • What is the appropriate route to define, agree, report and
   monitor an action plan: Planning Committee; Executive etc.?
 • How best to reveal real site specific issues & challenges
 • Potential need to keep the published Action Plan relatively high
   level with more detailed actions & evidence base in the
   background
 • Needs to fit well with local context

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Preparing an Action Plan
Process & Tools

                           76
Preparing a Root Cause Analysis
Creating an evidence base – data capture template

   Excel spreadsheet with series of fields to capture key info and related actions
   1. Site Analysis
   2. Planning Overview and RAG rating
   3. Delivery Numbers – Projections and Completions
   4. Income – S106, CIL etc
   5. Comments
   6. Actions – who, what, when, where, how                                        77
Preparing an Action Plan
Issues to consider – reporting – high level table

                                             Simple table drawn from
                                             more detailed analysis
                                             • Site Description;
                                               Delivery Summary;
                                               Observations; and
                                               Actions
                                             • Strategic Sites
                                             • Other small and
                                               medium sites
                                             • Potential split between
                                               brownfield and
                                               greenfield
                                             • Section for general
                                               actions and
                                               observations to pick up
                                               potential corporate
                                               and political aspects78
Preparing an Action Plan
Challenges & Opportunities

Challenges
• Data availability & integrity – understanding the issues
• Resources – how much effort is needed
• Securing appropriate stakeholder engagement
• Corporate support – buy-in to the likely necessary actions
Opportunities
• Positive & responsive service delivery

                                                                       ?
• New thinking – solution focussed
• Engender a collaborative approach
• Corporate profile raising                              What   else
• Securing wider benefits & objectives
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A package of support ?
Part Activity        Notes                Outputs

1    Kick-off        Local 1 day          Governance / process /
     Begin data      + submit for ‘data   timetable
     capture         clean’               Clean dataset
                                          (‘evidence’)
2    Diagnostic       Group therapy 1     Ideas to test
     Issues / options day
3    Action plan      Local 1 day         Write up ideas and
                                          make Action Plan

• In three chunks ?
• Is there a better way of doing this ?
43 field
spreadsheet
Templates / standards / toolkits ?
Part Thing            What              Why
1    Spreadsheet      Standard format   Makes it easier to
     – site by site   and sample data   forecast, aggregate
2    Summary –        Standard format   Publish in standard
     pipeline         and sample data   format
3    Action plan      Standard          Publish in standard
                      headings          format

• Process chart ?
• Good examples / commentary ?
Closing thoughts
How do we all feel about the HDT ?
Who wants to be a phase 2 pilot ?
We are at local.gov.uk/pas
Questions?

Email     pas@local.gov.uk
Web       www.local.gov.uk/pas
Phone     020 7664 3000
Twitter   @Pas_Team
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