Savills : Impact of Housing Delivery Test results on the Midlands

As a result of restricted delivery, the number of homes required in the year to March 2020 has been reduced by one month. This has had a material impact on the results of the test for 19 local authorities. Staffordshire Moorlands is the only Midlands authority within this list. The national impact of the results has been assessed further in a separate Savills blog which can be accessed here.

In general, the Midlands has performed well in regards to delivering substantially more homes in the last 3 years than was required (requirement of circa 120,000 homes and delivered circa 160,000 homes). In the West Midlands, over 141% of homes were delivered compared to the requirement and in the East Midlands the figure was over 129%. However, out of the 52 local authorities in England which have failed to deliver over 75% of their housing requirement between 2017/18 - 2019/20, 5 of them are within the Midlands. These authorities will now face a presumption in favour of sustainable development (Paragraph 11d of the National Planning Policy Framework).

The table below sets out the 10 Midlands Local Planning Authorities that have failed to deliver enough housing and must now either prepare an Action Plan (delivery is below 95%), apply a 20% buffer to their Five Year Housing Land Supply calculation (delivery is below 85%) or there is a presumption in favour of sustainable development (delivery is below 75%).

Midlands Local Planning Authority	Total no. of Homes Required	Total no. of Homes Delivered	HDT: 2020 Measurement	HDT: 2020 Consequence
Ashfield	1,407	918	65%	Presumption
Bromsgrove	1,493	1,025	69%	Presumption
Broxtowe	1,024	847	83%	Buffer
Erewash	1,092	752	69%	Presumption
Gedling	1,251	855	68%	Presumption
Hinckley and Bosworth	1,277	1,172	92%	Action Plan
Newcastle-Under-Lyme	978	790	81%	Buffer
Sandwell	4,123	2,007	49%	Presumption
Walsall	2,532	2,230	88%	Action Plan
Wyre Forest	674	567	84%	Buffer

Source - MHCLG

Although the Housing Delivery Test Results above should provide applicants with a planning case for the 5 authorities that have failed to deliver 75% of their housing requirement, for the most part, this will probably not assist them significantly. All of the Midlands Local Planning Authorities listed in the table above, with the exception of Hinckley and Bosworth, are all constrained by Green Belt. In some cases, the whole authority is constrained by Green Belt outside of the urban area (Bromsgrove, Broxtowe, Gedling, Erewash, Walsall and Sandwell). For applicants, Green Belt sites bring with them a whole range of planning policy and political challenges that need to be addressed and the risks / costs associated with submitting a planning application for a Green Belt site still remain even with the presumption in favour of sustainable development.

The most risk averse option to develop a Green Belt site is to promote it through the Local Plan process for release from the Green Belt and allocation for development. Out of the 10 Midlands authorities, all but Wyre Forest are at the early stages of their Local Plan process so they are not expected to be adopted any time soon. Therefore it will be interesting to see if these authorities improve their housing delivery position in the coming years or whether they will continue to fail to deliver their housing requirement.