Interesting what’s not changed in the revised NPPF published on 19th December. There’s no change to the Government’s objective of, “significantly boosting the supply of homes” (para 60) and the Housing Delivery Test (HDT) has survived pretty much unscathed. For all it’s rhetoric, the Government is keeping the pressure firmly on LPAs to deliver much-needed housing. It remains a priority, even if it's not clear exactly how delivery is going to be improved.
What surprises me is that the Government has belatedly published the HDT results for 2022 but made no mention of those for the year ending March 2023. It's evident the 2022 HDT increases the number of local planning authorities affected by the ‘presumption’ in favour of sustainable development, or more accurately the ‘tilted balance’. Clearly a political decision has been taken to put renewed pressure on these LPAs as per NPPF paragraph 80 which states, "The Housing Delivery Test consequences [including the presumption] will apply the day following the annual publication of the Housing Delivery Test results, at which point they supersede previously published results. Until new Housing Delivery Test results are published, the previously published result should be used." So if pressure is to be applied, surely it should be based on up-to-date figures? My bet is that they’ll now publish the 2023 dataset within a month. We'll see.
To make it easy to see the direction of travel on the Housing Delivery Test for each and every LPA, I have put together a table of 3 years of HDT results, by LPA, in a handy table here.
Does the Housing Delivery Test make a significant difference to a planning appeal? This question was addressed in an earlier blog in January 2023. One of my conclusions was it makes a planning application less likely to be refused in the first place. In other words, it keeps the pressure on LPAs to deliver on housing. It’s therefore always worth mentioning the HDT in Planning Statements, especially if a LPA’s performance is below what it should be. Hard facts and figures to back up your case have never been easier to obtain, for example using the DLUHC’s own housing dashboard on net additional dwellings or using the links in a previous blog on ‘Winning appeals with good evidence on affordable housing’. There’s nothing like hard evidence for winning others over.
Other tools to help you make the case for housing development are available here.
Let’s hope the Government continues to 'catch up' and publishes the Housing Delivery Test results for the year ending March 2023 early in the New Year.