Delaying the Inevitable

Keeping to my new year resolution of blogging more, I’m continuing this week with thoughts on the delays to the release of the latest Housing Delivery Test results. The government announced in the last week that the release of the latest figures would be delayed until later in the year. So what are the implications of this? Why is the Housing Delivery Test Important? And is this just one more in a series of other delays we are currently experiencing from Government?   

Firstly, for those unfamiliar with HDT, it was introduced as part of the July 2018 revisions to the NPPF and first published in February 2019. We have had 6 instalments of the HDT since, with the last being released in December 2024. Whilst the exact date of publication has been somewhat erratic it has always been around the end of the year / early part of the following. Until now.

How is it calculated? Well, it’s pretty simple. The HDT just compares the net homes delivered over three years to the homes that should have been built (the housing requirement) in that same period.

The implications for the % achieved as set out in the NPPF has varied over the years, but paragraph 79 of the current NPPF sets out the following:

• Over 95%? – you’re fine. Nothing to see here.

• Below 95%? - part a of para 79 tells the authority to prepare an action plan to assess the causes of under delivery and identify actions to increase delivery in future years;

• Below 85% - the authority should apply a 20% buffer to their supply of deliverable sites and prepare an action plan.

• Below 75% - presumption is applied and the 20% and the action plan.

  
  

But it doesn’t stop there. What about establishing demonstrable unmet need for the purposes of a Grey Belt application? Well footnote 56 states that where an application involves provision of housing then that means a lack of five year housing land supply OR an HDT result of below 75%.

The problem with the HDT results is that they were always a bit behind. I always felt it was a bit like a football team basing its current league position on how they did a few seasons ago. The last results published in December 2024 were for the three years leading up to end of financial year 2022/23. So effectively a year and a half had elapsed since that data. Continuing that football analogy it would mean that Spurs would currently be 4^th in the premier league table based on performance at the end of March 2023 rather than their current woeful position of 14th!! Are we in danger of applying the same approach to housing delivery in local authorities?

Even when the most recent HDT results were published back in December 2024, the government had already started talking about future changes and stated alongside the publication that:

Stakeholders will be aware that we are currently operating to a delayed publication timetable for HDT as a result of planning reforms and associated consultations. We recognise that authorities, developers and others rightly expect the HDT to be published according to a regular timetable. We are therefore, considering options for expediting future HDT collections, including the possibility of combining the data collections for the 2024 and 2025 HDTs. We will update in due course.    

One year on, we are still basing fundamental decisions on housing delivery data which is now effectively 34 months old. The data is certainly out there and, in many instances, paints a different picture to what is on public record as part of the HDT. Many authorities have published their delivery data as part of their Annual Monitoring Reports or Housing Action Plans.

The most recent HDT result for Mole Valley showed a delivery of 709 dwellings against a requirement of 903 giving a result of 78%. So, presumption applied an 20% buffer needed. But not presumption.

Years	Homes Required	Homes Delivered
2020-21	226	244
2021-22	339	248
2022-23	339	217
	903	709 (78%)

Mole Valley did the right thing and published the Housing Delivery Test Action Plan in June 2025 alongside the Annual Monitoring Report for 2023-24 which showed a delivery of just 153 dwellings.

Assuming requirement stays at 339 dwellings and adding on a year to the HDT gives a different picture:

Years	Homes Required	Homes Delivered
2021-22	339	248
2022-23	339	217
2023-24	339	153
	1,017	618 (60%)

I know it, you know, they definitely know it. So less than 75% and therefore in presumption right? Well……….. no. Para 80 of the NPPF is clear that until the new HDT results are published, the previously published result should be used. So we just carry on then do we and pretend like what is actually happening on the ground should be treated as "alternative facts?" We all know where that gets us……

So, in the case of Mole Valley and many areas, Grey Belt arguments cannot be made out and presumption is not applied in decision taking when it should be (they have a relatively up to date plan and demonstrable five year housing land supply). In a world where data is at our finger tips is it realistic to be making decisions on the basis of old data? Surely this flies in the face of a government which promised us it would build baby build. In the current draft NPPF consultation, the government has retained all provisions relating to the HDT and shows no sign of a wider climb down on its application.

Furthermore, the HDT is not the only thing where the government have dithered, delayed and equivocated. The media has fast picked up in recent weeks on another aspect of delays from the government in the form of cancelled local elections.

Delays from government are hardly a new thing and we shouldn’t be surprised, but we were told by this government to expect great things on housing delivery. The government has come under further flack for the delay in publishing the Long Term Housing Strategy which is now approaching a year after we were told to expect it alongside the Spending Review last Spring.

 There can be no doubt that the rhetoric coming out of Marsham Street is the most pro-development we have seen in a generation, but the industry is acutely aware that this will not last forever. On that basis it is surely not unfair to expect that strategies are published in a timely manner but more importantly that the government plays by the rules of the game they set in the first place. It is more important than ever that this government meets clear under delivery of housing with the consequences that we were told they would.

AB – My own Thoughts.