Enough is enough! Scrap the Housing Delivery Test and stop rewarding developers’ failure to build homes already approved

There are already enough houses with planning permission or allocated within an adopted Local Plan for “another Maidstone” to be built in Kent in the next five years

Richard Thompson, CPRE Kent planner, lays out how disastrous governmental planning policy is desperate news for Kent

The publication of the 2021 Housing Delivery Test results, combined with existing lack of five-year housing supplies, now puts Kent in the frankly ridiculous position where 11 out of its 13 councils are being punished for developers’ failure to build homes already approved.
The Housing Delivery Test is a backwards-looking assessment that compares how many houses having been built in a council’s area over the last three years against the government-set housing number for that area. The result is given as a percentage of homes built against this target, with increasingly severe punishments the lower this percentage is.
The National Planning Policy Framework five-year supply test is a forward-looking assessment of whether enough houses have been granted planning permission, or are allocated within a Local Plan, to ensure this same government-set housing requirement is likely to be built.
The point is, both tests see the imposition of a housing target on a council and then punishes it for not meeting this target. However, the reasons the targets are missed are largely factors completely outside of their control. That is, it can grant as many planning permissions and allocate as much land as it can, but unless it starts physically building the houses itself, it is at the mercy of market forces.
Private housebuilders will, however, only ever build at a rate that the local housing market can absorb. They are not going to build at a level that over-supplies a local housing market as this would force them to reduce prices and lower profits. They are also currently subject to practical constraints such as labour and material shortages.
As of March 31, 2020, (from when the most up-to-date Kent-wide numbers available) some 64,611 new houses either had planning permission or were allocated within an adopted Local Plan and were expected to be built within the next five years. For context, that’s already enough houses for another Maidstone planned for Kent over the next five years.
Yet this is not deemed enough.  
Because of either the Housing Delivery Test or the five-year supply test, nine of Kent’s councils are subject to the most severe of punishments: an automatic presumption that speculative planning applications will be granted, even if they are contrary to democratically adopted Local Plans. 
Of the remaining four councils, two must produce action plans setting out how they are to increase housebuilding in their areas. The full 2021 Housing Delivery Test results, along with the last published five-year supply figures, are shown below:

Area NameHousing Delivery Test: 2021 measurementCurrent five-year supply (years)Consequence
Dover88%5.56Action plan
Folkestone and Hythe85%5Action plan
Medway67%1.78 – 3.03Presumption
Tonbridge and Malling63%2.89Presumption
Tunbridge Wells97%4.83Presumption

The real-world consequences for Kent of this absurd policy are stark. Councils across Kent are rushing through ever-increasingly unsustainable Local Plans in a fruitless endeavour to beat the presumption punishment. In Kent, this often entails allocating ever-increasing housing numbers on greenfield land, which is more profitable and hence more likely to developed quicker, making them more attractive to councils needing to boost housing delivery in the short term to meet the five-year supply test.
In the meantime, speculative applications are being allowed either by councils or at appeal (because of the current presumption punishment), causing anger and disenfranchisement among local communities.
And it is not just us saying this. In calling for the Housing Delivery Test to be suspended, Canterbury City Council chief executive Colin Carmichael has stated “it cannot be right to punish councils that are working hard to do what the government asks even when most of the levers councils need to pull are out of their control”.
We agree. Only it’s not just the councils that are being punished, it’s the people of Kent who have lost a democratic voice to oppose speculative development. It is Kent’s special countryside that is being sacrificed to this developer’s charter. 
And the government wonders why the people of Kent are so angry with the current planning system.

Wednesday, January 26, 2022

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