The Housing Delivery Test’s Impact on Council’s Housing Land Supply Buffers

More councils have seen their housing land supply buffers shortened, rather than lengthened, as a result of the delivery test, research shows. Experts say the change could have a significant impact on decision-making but any improvements in councils’ land supply positions may be offset by other policy changes.

Following last week’s publication of the 2018 housing delivery test results, authorities that delivered less than 85 per cent of their housing requirement have to add a 20 per cent buffer to their housing land supply figure. According to the test results, 87 councils fall into this category.

However, many of these councils already have a 20 per cent buffer on their housing land supply, while some of those that had such a buffer have seen them reduced following the test to the standard five per cent. In fact, research by Planning and consultancy Savills show that three times as many local planning authorities will see their housing land supply positions improve as a result of the new housing delivery test. While 37 authorities that had a five per cent buffer will now find themselves having to increase that to 20 per cent, 110 move the other way and will see their buffers reduced to five per cent.

According to Matthew Good, director at planning consultancy WYG, in principle, the test results put councils overall in a better position than prior to its publication. But he said this improvement may be offset by the government tightening the definition of a "deliverable site" in the July 2018 version of the National Planning Policy Framework (NPPF).

Under NPPF rules, councils’ five-year housing land supply has to include sites that are "deliverable". "The new wording restricts the ability of councils to include outline planning permissions under the definition of deliverable sites," said Good.

In authorities where the buffer requirement has changed, authorities "will need to take into account the difference when determining applications or defending appeals", according to Jonathan Dixon, associate planning director at consultancy Savills. "This could lead to the refusal of applications that had been in line for approval," he says. In terms of plan-making, the delivery test results make little difference to authorities facing increases in their buffers, according to Neil Tiley, director at Pegasus Planning. Councils with plans close to submission, which will be subject to the delivery test results, "have had sufficient warning to ensure that their emerging plans provide a sufficient supply," he said.