The 21 councils who could be made vulnerable by the lack of a housing delivery action plan

More than 20 local authorities in areas under-delivering on housebuilding targets are yet to comply with the government's instruction that they produce an action plan setting out how they will address the problem.

New research has found that, of the 108 authorities which were required to produce an action plan following the results of the first test, 81 had produced an action plan by 7th October.

Three of the 108 councils - Poole, Christchurch and Bournemouth - have been merged into one authority, BCP Council, which had its action plan approved earlier in October. 

Of the remaining 25 local authorities that were required to produce an action plan when the HDT results were announced in February, four have either recently adopted a local plan or progressed it to an advanced stage. This means that their housing need figures and housing delivery test results are about to be superseded.

LPAs who have published a HDT Action Plan

LPAs required to provide an HDT Action Plan who, as of 7th October, had not yet done so

LPAs who have not published an Action Plan but have recently adopted a local plan or progressed to an advanced stage 5

Of the remaining 21 authorities, two stated that they expect to produce an action plan later in the year, coinciding with the publication of local plan documents. Nine stated that they are drafting or finalising the action plan, and that it will be published soon. Eight had not responded to researchers' inquiries, and action plans could not be located on websites as of 7th October.

The government issued the HDT results on 19 February and all councils which fell below 95 per cent of housing delivery against their targets during the testing period were required under the NPPF to produce an action plan within six months addressing the causes of housing under-delivery and identifying actions to boost home building. The six-month deadline expired on 19th August.


The Local Government Association’s Planning Advisory Service carried out action plan training sessions with local authorities last year. The organisation’s programme manager Richard Crawley attributes the numbers yet to publish a plan to the complexities of gaining political sign-off and the fact that the plan deadline fell in the August holiday period.

But some councils may also have decided not to produce a plan, he adds. "Inevitably there will be some places who say these plans are not relevant for us, and we are not going to do one," he says.

There have been no direct consequences of failing to publish an action plan set out by the government. "The view of the government is that the action plan is not a punishment or homework but something that councils should be doing for their own benefit," says Crawley.

But it will be difficult for councils to appear at an appeal without an action plan and "be able to argue that their plan is up-to-date and working," he suggests.

Michaek Knott, director at consultancy Barton Willmore, said it is "very likely the case that the absence of an action plan would be viewed dimly by an inspector considering housing land supply".

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