Here are our top tips on preparing a Housing Delivery Test Action Plan

1. 2020 Housing Delivery Test Action Plans
Shelly Rouse, PAS
Rachael Ferry - Jones, PAS
March 2021 www.local.gov.uk/pas

2. Welcome and introductions
• Housekeeping and the tech
• Introductions
• Safe space for a bit of group therapy

3. HDT recap
The Housing Delivery Test is a % measurement of the number
of net homes delivered against the number of homes required,
as set out in the relevant strategic policies for the areas covered
by the Housing Delivery Test, over a rolling three year period.
Over 95% - No Requirements
Over 85% - Action Plan
Under 85% - Action Plan and Buffer
Under 75% - Action Plan, Buffer and presumption

4. We are at maximum impact
2020 HDT
Covid19 =1 Month off

5. Housing Delivery Test HDT
• Net homes = HFR
• Requirement can be
– Yr 1 is average household growth 2014 figures
– Plan figure, or if over 5yr old
– LHN
• Next year HDT 2020 Yrs1 – 3 could be all LHN or Plan

6. HDT 2020 results
– 55 authorities have delivered below 75% to trigger the
presumption in favour of sustainable development;
– 18 authorities have achieved between 75% and 84% and
should to add a 20% buffer on their 5 year housing land
supply as well as produce an action plan;
– 33 authorities have achieved between 85% and 94% and
should to produce an action plan within 6 months of
publication; and
– 203 authorities have achieved 95% or over and will face no
consequence.

7. Presumption for everyone in the future??
• 55 councils under 75% - 40 of them have no Plan
• 18 need to 20% buffer - into presumption or not??
• HDT yrs2 & 3
– 13 Councils had a blend of plan/LHN
– 67 Councils plan requirement
– 220 Councils local housing need LHN aka standard method#1
• Many more through 5YHLS

8. A little bit about HDT Action Plans
Updated June 2020

9. Remember our Councillors guide
• Find the whole thing online
• https://local.gov.uk/pas/pas-
topics/monitoring-and-delivery
• Steal it all
• HDT Action Plans -
https://local.gov.uk/pas/pas-
topics/monitoring/housing-
delivery-test-action-plans

10. HDT Action Plan Process
Step 1: Evidence
Gathering
Step 2: Root Cause
Analysis
Step 3: Action
Planning
Step 4: Consulting and
Publishing
Step 5:
Implementation
Step 6:
Monitoring
Six
month
deadline
19th June 2021

11. The HDT Action Plan
Reasons for
under-delivery
Improve
levels of
delivery
Implementing and
Monitoring
Root Cause
Analysis -
Explaining the HDT
result
Identify Actions
How can you solve
the issues?
Monitoring
How are you going to
know if its working?

12. What does the PAS Guidance say
the Action Plan should include a “… root cause analysis to set out key delivery issues,
challenges, problems and weaknesses, potentially to review issues across key
strategic sites/areas and by development typologies. This could include commentary
relating to the following:
– The planning context including local plan status, approach to growth, etc
– Current housing supply needs & delivery rates;
– The nature and composition of the local housing market including for example
any quantifiable data in respect of the numbers and types of housing sites;
– An overview of the typologies of sites/development activity across the local
area, such as the extent of urban/rural, greenfield/brownfield, town/village
development;
– Issues relating to development costs, values and viability;
– Issues relating to infrastructure planning, funding and delivery including the
relationship with housing supply”

13. What could you look at
● The policy context.
● The typologies of site allocated.
● The types of developers and housebuilders delivering in the district.
● Looking at issues related to land purchase and development costs, inputs and viability.
● Looking at allocated sites yet to be submitted or achieve a detailed consent and exploring
the reasons why.
● Reviewing sites with an extant planning permission which have not yet commenced and
exploring the reasons why.
● Analysing approval rates and determination periods of planning applications
● Analysing the post consent period between consent and construction.
● Reviewing the number and type of conditions and planning obligations on consented
development.
● Review SHLAA/Phasing Methodology

14. From Root Cause Analysis to Actions
• Once you have identified the root causes, there is a need
to identify actions
• Proposed framework for presenting root causes:
Root Cause Evidence Action
Why has there
been under-
delivery?
How do we
know?
What actions are
we proposing to
address the
problem?

15. Three types of Actions
1. Processes or behaviour change (DM,
Policy, Cllrs)
2. Policy & Local Plan - new approaches and
seeking land
3. Corporate delivery and outside planning
market influences

16. Action Plans - What does ‘good’ look like?
• Content and Coverage
• The right audience
• HDT result looks back - Action plan looks forward
• Lessons learnt

17. Content and Coverage - Keep It Simple
• Try and make it straightforward and framed in terms that
allow [normal] people to understand what you're trying to
do and why it matters to them
• Would the CEx or resident recognise the narrative ?
• Is it a neat parcel that links back to what matters ?
– think of a busy reader

18. Numbers and the direction of travel
• Projections
• Scenarios
• Predictions
• HINT: many peoples results will get worse because of the
way LHN is phased in - the perception that your actions
are making things worse is not good

19. The right audience
Who are you expecting to read this thing?
• Hint: it's not going to be government / an inspector
– unless it is ! in a topic paper supporting your plan !
• Your developer community ? Your leader ?
• Why do they care ?
– No one wants to read your “things to do list”
• Think “inside” / “outside” [the council]
• Think “big up Bolton” = promotion and intent
• Think “paint a picture” to support your team

20. Looking in both directions
HDT HDT HDT Yr 1 Yr 2 Yr 3 Yr 4 Yr 5
Now
Looking backward 3yrs Looking forward 5yrs

21. Actions - Bang for your buck
• You are the author and most likely reader
• What can only you do ? What can others do?
• Where are the biggest and quickest wins ?
• Look forward to the 5YHLS for solutions
• Weaponise your Action Plan - make it a tool to
work for you

22. The Actions
• Actions like being in a table
– what is the best table ?
• Framed in ways your audience connects with
– outcomes on their terms
• Not enormous leaps but steps along the way
• Realistic timescales
• With previous completed steps still visible

23. HDTAP’s - lots of actions
what was missing?
• Resource LPA
adequately
• Relax attitudes/policies
to free up land
• Political and public
objection

24. Sketch out the strategy, demonstrate the
link to actions

25. Shelly’s Take on ‘Good’ Action Plans
● Concise and allow normal people to understand what you're
trying to do
● Respond to the ‘Wake Up Call’ the HDT is
● Have immediate actions as well as short/medium/long term
● Action Plan must reinforce your strategy not undermine it. Think
about how it might be used against you.
● Protect what's important. Ensure that actions really are
connected to delivery and your existing strategy
● Look beyond planning
● Are written as a tool to use

26. Good Action Plans
• Addressing both general and site-specific issues/barriers
and providing solutions tailored to those
• Critical evaluation of current council led processes
• Acknowledgement of issues that are outside of council’s
control but still attempting to influence
• Providing estimated timelines for further steps
• Communication with neighbouring local authorities with
better HDT results for advice
• Feedback gathering from the communities and
developers

27. Good Actions
• improve/adopt local plan
• improve monitoring process
• address delays in commencement after planning permission
• prompt engagement with early stalling site
• improve planning application process (provide pre-planning
application advice; check list and ‘model’ information)
• attempt to retain skill and labour force
• pursue funding (such as HIF)
• identification of land (launch Call for Sites, update Brownfield
site register)
• Influence the wider housing market

28. Monitoring
• Is there a need to improve or better resource the
monitoring function?
– Infrastructure Funding Statements requirement
• Reigate and Banstead a good example

29. Monitoring

30. Group therapy

31. Root Cause - evidence gathering progress
• Go round the virtual room:
– Progress to date?
– Was the evidence readily available?
– Were any difficulties encountered? Covid 19?
– Did colleagues/stakeholders engage meaningfully?

32. Potential actions
• Go round the virtual room:
– Any other actions?
– Role of Local Development Orders / CRtBO / S&CB/ support for
Community Land Trusts?
– Role of developer (and landowner) forums?
– Difficult internal discussions (DM, Housing, Cllrs)?
– HDT Action Plans - Useful or Pointless?

33. Is the answer diversity of supply?
• “I conclude that if either the major house builders
themselves, or others, were to offer much more housing
of varying types, designs and tenures (and, indeed,
more distinct settings, landscapes and street-scapes)
on the large sites… then the overall absorption rates –
and hence the overall build out rates – could be
substantially accelerated”
– Letwin (2018) Independent Review of Build Out Rates - Draft
Analysis

34. Encourage
more
housing of
varying
types
• Harlow and
Gilston Garden
Town Design
Guide
(November
2018)

35. Housing of various
types
“Missing Middle Housing is a range of multi-unit or
clustered housing types — compatible in scale with
detached single-family homes — that help meet the
growing demand for walkable urban living.”
Source: https://missingmiddlehousing.com/

36. Is there a trade off between deliverability
and ‘sustainability’?
Larger sites, e.g.
new settlements,
major urban
extensions
Smaller sites, e.g.
dispersal, smaller
town and village
extensions
More sustainable
(assumed
infrastructure
provision)?
Less sustainable
(infrastructure less
easy to secure)?
Less deliverable
(slower build out
rate)?
More deliverable
(faster build out
rate)?
Striking a balance
in terms of mix of
allocated sites?

37. Or does it really matter?
There are some options available
1. Do the minimum to update the Action Plan
a. Short term blip
b. Plan imminent
2. Make it a useable tool - mat con
a. This is an ongoing trend
b. Presumption already applied?
3. Maximum effort - move, move, move
a. Dynamic tool and real culture change
Whatever you do - Don’t make it pointless

38. “Presumption”
In this section
1. How is it different to 5YHLS presumption?
2. Planning research
3. https://www.bailii.org/ew/cases/EWHC/Admin/20
20/518.html

39. How is it different to 5YHLS presumption?
• Honest answer?
• We don’t know yet
– Need to see how PINS behave
– And how appellants behave
– And how planning committee behaves

40. How is it different to 5YHLS presumption?
• Looks backward not forward
– Could it be the numbers (yrs1-3)
– What's happened - is it a specific thing
– Is the future bright?
• Unlike 5YHLS it's a simple sum and may not
involve dissecting sites
• Fixed for a year – different risk profile ?

41. Planning research found …
1. You are not necessarily doomed
2. Harm matters more than benefit
3. Impact (on landscape) is critical
4. Green belt proposals must demonstrate no harm to
openness or purpose of GB
5. Proposals that reduce gaps must leave enough gap
6. Transport impact and Highway objections matter
7. If heritage harm, benefit to public crucial

42. shelly.rouse@local.gov.uk
pas@local.gov.uk
@Pas_Team
web www.local.gov.uk/pas