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This is what we want to do about it
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These are the next steps
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•
The plan looks at the reasons for under delivery
and the steps to be taken to drive up housing delivery in the
area.
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Adopt the Action Plan and deliver the actions to
increase delivery.
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1.1
This reportseeks to outline the content of the
HousingDelivery Test Action Plan 2024. The Action Plan is a
requirement because only 61% of the housing needs have been
delivered over the last three years.
1.2
The
Housing Delivery Test Action Plan 2024 identifies actions to
address under deliveryagainst the housingrequirement in the area.
The Plan looks at the reasons for under delivery and the steps to
be taken to drive up housing delivery in the area.
1.3
The
Plan’s year is 2024 rather than 2025 as the data is
calculated to 31/03/24.
2.
Key issues
2.1
The
HousingDelivery Test (HDT)has been introduced by the Government as
a monitoring tool to demonstrate whether local areas are building
enough homes to meet their housing need. The HDT, which was
published in December 2024, updates the previous results in 2018 -
2023. The test compares the number of new homes delivered over the
previous three years with the authority’s housing
requirement. In the case of Spelthorne, the housing requirement is
the minimum annual local housing need figure (631per annum as of
April 2024).
2.2
The
calculation for Spelthorne is given as:
992(homes delivered) / 1632 (homesrequired) =
61%.
It shouldbe noted that the
Government’s housing deliverytest only considers the
quantum of dwellings which have been delivered, it does
not reflect the acute affordable housing need which remains grossly
unmet in Spelthorne.
2.3
The
HDT was originally introduced in a phased approachover three years.
It will have the following consequences:
·
Where
housing delivery over the previous three years has been less than
95% of the housingrequirement, LPAs shouldprepare an action plan
setting out the causesof under delivery and the intendedactions to
increase delivery.
·
Where
deliveryhas been less than 85% of the housing requirement, a 20%
buffer should be applied to the supply of deliverable sites for the
purposes of housing delivery assessment.
·
Where
delivery has been less than 75% of the housing requirement, the
National Planning Policy Framework’s (NPPF) presumption in
favour of sustainable development will apply. The three year
transitional periodhas now ended therefore the HDT consequences
will be standardized moving forward.
2.4
As a
consequence of the HDT being 61%, the local authority falls into
the category where the following apply:
·
an
actionplan should beprepared,
·
a 20%
housing bufferfigure is appliedto the housing requirements;
and
·
a
presumption in favour of development within the boroughapplies as
the housing delivery over the last three years is less than
75%.
The proposedaction plan
demonstrates that Spelthorne Councilis taking positive steps and is
serious about housing delivery.
The presumption in favour
ofsustainable development
means that proposed developments should be granted planning
permission unless their adverse impacts "significantly and
demonstrably" outweigh their benefits.
2.5
The
housingtest results for the last six years are set out in the
following table:
|
Measurement Year
|
Total Homes
Required
|
Total Homes
Delivered
|
HDT score
(%)
|
Consequence
|
|
2024
|
1632
|
992
|
61%
|
Presumption +
Action Plan + 20% buffer
|
|
2023
|
1,566
|
1,072
|
68%
|
Presumption +
Action Plan + 20% buffer
|
|
2022
|
1,554
|
1,073
|
69%
|
Presumption +
Action Plan + 20% buffer
|
|
2021
|
1,574
|
785
|
50%
|
Action Plan + 20%
buffer
|
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2020
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1,509
|
904
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60%
|
Action Plan + 20%
buffer
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2019
|
1,394
|
876
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63%
|
Action Plan + 20%
buffer
|
An analysisof the 2023 position
in all Surreyauthorities is containedin Table 8 of the Action Plan.
Other Surrey Local Planning Authorities (LPAs) with the same
‘consequences’ are Epsom and Ewell (38%), and Tandridge
(42%).
2.6
The
HDT Action Plan isthe Council’s responseto the challenge set
out in the Government’s National Planning Policy Framework to
boost significantly the supply of homes and has four
goals:
·
To
examinethe possible causesof the ‘under delivery’ of
new homes in the Borough.
·
To
explainwhat the Councilhas been doing so far to boosthousing
delivery.
·
To
build relationships with developers, landowners and agents
responsible for building homes on sitesthat have
planningpermission, allowing the Council to adopt the role of an
enabler of much needed residential development ensuring housing
permissions are built out as quickly as possible.
·
To set
out what actions the Council can take to increase the rate and
number of homes built in Spelthorne.
3.
Options analysis and
proposal
3.1
The
first section of the report examines the Action Plan context.These
include Spelthorne’s corporate documents which play a role in
housing delivery. It should be noted that this action plan does not
play any role in deciding the future of the currentGreen Belt or
proposed housingallocations. These have been dealt with completely
separately as part of the of the emerging new local
plan.
3.2
The
next section is an assessment of the ‘under delivery’
of newhomes in the Borough including a review of the potential
reasons behind the housing supply deficit. This includes the local
and national issues which influence housing delivery, (i.e.,
affordability issues, proximity to London, build costs, post Covid
19 impacts, difficulties once development has commenced). A range
of data and sources have been used to inform this analysis. As part
of this process, the Council has engaged with stakeholders to
improve its understanding of the issues effecting housing delivery.
The analysis of the issues has been used to inform what actions the
Council need to take to improve its housing delivery.
3.3
Critically, the final sectionof the action plan includesa
number of measures to improve decision making and also to support
wider opportunities. These include, amongst many:
·
working with site promoters and other stakeholders to
deliver Local Plan allocations,
·
continuing to improve planningperformance on speed and
qualityof decision making,
·
refining the Planning DM computer softwareand procedures to
enhance agile / paperless working in DM; and to
·
constantly reviewing the discharge of planning conditions
(after planning permission has been granted) to speed up the
process.
3.4
The
Action Plan identifies future actions to boost housing delivery,
including the need to ensure the Local Plan is adopted by the end
of 2025. The Council’s assets offer a positive opportunity to
boost housing deliveryfurther moving forward (which will be done in
partnership with others), however barriersto development will need
to be reduced. Once adopted, the Local Plan will
providemore certainty as to the Council’s housing land supply
and will help to deliver housing to meet the Borough’s
development needs.
3.5
We
have reviewed our Action Plan against other Local Planning
Authorities and best practice and details are contained in Appendix
B. A further analysis will be undertaken in 2026.
4.
Financial management
comments
4.1
There is a need ensure the Local Plan is adopted
by the end of 2025, in order to provide greater certainty to
developers, to avoid further delaysin meeting the Borough’s
housingneeds and to reduce the
risk of potentially costly appeals where applications are overturned or
refused and then allowed on appeal. There is no specific
budget set aside for such eventualities – all these costs come out a
reserve which will diminish over time. A HDT of below 75% will also provide an
increased financial risk associated with the costs of defending
planning appeals.
5.
Risk management comments
5.1 There are no known
consequences if Spelthorne failsto produce an action plan when
required to. The government will not intervene if our housing
delivery test level (%) does not increase, this only happens at
present when there is poor performance in the speed and quality
measurements of major and non-major applications. Consistent
under-delivery could harm the authority's reputation in terms of
housing delivery impacting public and private sector
investment.
5.2 However,
Spelthorne is at the highest (worst) level in the
‘consequences’ of the housing delivery test regime.
A 20% housing buffer is applied to our 5 year housing land
supply figures for consistent under delivery. We are also
required to produce an Action Plan to demonstrate how seriously we
seek to address this issue. Finally, there is a presumption
in favour of approving development in our decision making process.
This presumption will remain even when the Local Plan is
adopted and we have a 5 year housing land supply as we are required
to meet both targets.
5.3 If the HDT
remains below 75% (we are at 61%) the presumption in favour of
sustainable development will remain and this will carry significant
weight in the determination of planning applications for housing
developments.
5.4 A HDT of below 75%
will also provide an increased financial risk associated with the
costs of defending planning appeals, particularly the more costly
Hearings and Local Inquiries. Local Planning Authorities are
required to fund their own costs in defending planning applications
at appeals, including the cost of counsel. These costs can be
significant and can extend to over £100,000 for very large
and complex appeals.
5.5 A HDT of below 75%
will give housing delivery “very substantial weight” in
decision making, thereby increasing the risk of development being
allowed on unsuitable sites within the borough. An increase in
approval of speculative development on unsuitable sites could lead
to strain on local infrastructure and services through an
“unplanned” and not strategic approach to
infrastructure delivery.
5.6 The
anticipated adoption of the new Local Plan in September 2025 will
support the delivery of new homes in the borough, through the
allocation of development sites and the release of Green Belt for
family homes. The new Local Plan projects the delivery of almost
10,000 homes up to 2039, which will improve the Council’s
Housing Delivery Test result. However given the nature of the
Housing Delivery Test, which takes an average of the past three
years of housing delivery, it may take some time for the impact of
the new Local Plan to filter down into the results of the
HDT.
5.7 Whilst the Council
has identified actions to address past under delivery in housing,
it should be noted that there are factors beyond the
Council’s control that may negatively impact housing
delivery, for example market forces or developer priorities. These
may limit the impact of the Council’s actions set out in the
plan.
6.
Procurement comments
6.1
There
are no procurement issues.
7.
Legalcomments
7.1
The
National Planning Policy Framework requires that, where the HDT
indicates that delivery has fallen below 95% of the local planning
authority’s housing requirement over the previous three
years, the authority should prepare an action plan in line with
nationalplanning practice guidance (PPG), to assess the causes of
under-delivery and identify actions to increase delivery in future
years.
7.2
Once
approved, the Action Plan demonstrates not only the council’s
commitment to responding positively to the challengeof increasing
housing delivery but also is a measure of good practice to identify
ways to support delivery. However, most importantly it provides
compliance with the framework’s and the PPG’s
requirement for an action plan.
8.
Other considerations
LocalPlan
8.1
The
Local Plan 2024-2039, will guide development in the Borough to
2039/40. Ensuring timely progress on the Local Plan will help the
Council to boost its housing delivery by givingcertainty, address
some of the issues raised in the HDTAP and give the Council more
decision-making powers. Failing to meet our housing needs
means we will continue to be subject to the most severe sanctions
of the HDT.
Local Government Reorganisation
8.2
Changes to the HDT will occur with LGR as there will be
different geographical areas covering housing needs and delivery
with the forthcoming amalgamation of boroughs and districts.
However, this has not yet been agreed by Government and
consequently it is too soon to say how this will fall out.
This matter will be updated in 2026.
9.
Equality and Diversity
9.1
This
reportdoes not have any directequality and diversity impacts
although the LPA will continue to require all housing schemes to
have regard to equality and diversity issues.
10.
Sustainability/Climate Change
Implications
10.1
This report does not have any directsustainability/climate change
implications although the LPA will continue to require housing
schemes to comply with current policy guidance on
sustainability/climate change issues.
11.
Timetable for Implementation
11.1
The
agreedplan should be made available to the publicvia the websiteas
soon as possible.
11.2
The
agreedplan will be reported to the PlanningCommittee for
information as soon as possible.
12.
Contact
12.1
Russ
Mounty, Principal Planner
r.mounty@spelthorne,gov,uk
or
Jane
Robinson, Interim Strategic Planning Manager j.robinson@spelthorne.gov.uk
Background papers:There are none.
Appendices:
Appendix A HousingDelivery Test ActionPlan 2024
Appendix B Planning Practice Guidance
– areas for review and suggested
actions
Environment and
Sustainability Committee