1. Workshop 3: What can be done about slow housing delivery, and who do we hold to account?
29th March 2017

2. The proposals: Considerations in planning decisions
The consideration of the realistic prospect of delivery where there is evidence of non-implementation of earlier permissions (Question 22)
Will this enable developers to side step brownfield development in favour of greenfield development?
Power to refuse applications based on past delivery rates of the applicant (Question 23)
Is this practical given that permission is granted to a site, not developers? Would it undermine development of brownfield?
Expanding the network?

3. The Proposals Speeding up implementation
Shortening the time scales for developers to implement a permission (Question 25)
This should be sufficiently flexible to take local circumstances into account
Streamlined completion notices (Question 26)
The revocation of planning permission could hinder the development of brownfield sites and/or sites allocated within local and neighbourhood plans
Expanding the network?

4. The proposals: The Housing Delivery Test
Year
If housing delivery falls below x% of target
Action
2017
95% 
LPAs will need to develop an action plan to address shortfall
85%
LPAs will need to plan for a 20% buffer in their annual housing land supply calculations
2018
25%
The presumption in favour of Sustainable development will automatically apply.
2019
45%
2020
65%
CPRE agrees with the principle having a test that focuses on the delivery of new homes, as opposed to the supply of land.
However, in its current guise we believe that it places both designated and undesignated countryside at increased risk from development, does little to kick start the development of suitable brownfield sites and will not get homes built.
Campaigns project management

5. National Office analysis
Over 2/3 of LPAs will be affected by the proposal
On the whole, the proposals will affect slightly more local authorities with a local plan that without
65% of the local authorities that would be required to add 20% buffer to housing land supply have areas of Green Belt
290 LPAs analysed
Expanding the network?

6. Analysis of consultation response
“We would consider empowering councils to refuse permission to a developer with a poor delivery record as a positive, the most important point is whether councils would be empowered to reduce their housing targets and not build on greenfield land.”
CPRE Buckinghamshire
“There is also an issue as to what constitutes the commencement of development. Should there be any failure to follow the approved development delivery plan, the developer should be penalised and if necessary the planning permission should be revoked.” CPRE Gloucestershire
“The principle of the Housing Delivery Test is appropriate. The question is what the appropriate remedy for a failure to deliver should be.”
CPRE Worcestershire
“We advocate a planning consent should specify the phasing of the build-out in time intervals appropriate to site circumstances over the entirety of the delivery of the consent…. At the end of each phase the LPA would review progress. If progress at the end of each phase were unsatisfactory the LPA would be empowered to exercise a sanction (see below) if the developer was unable to provide an explanation as to the delay.”
CPRE Lancashire
Expanding the network?

7. Other proposals to speed on the delivery of new homes
Planning Fees
Skills
Pre-commencement conditions
These should enable developers to deliver homes in a more timely way, whilst increasing the resources of local authorities to process applications quickly.
Expanding the network?

8. Questions
We want developers to be held to account and for local authorities to be empowered to do so. How could a housing delivery test specifically deliver this? If no developer has come forward to build on an allocated site in a Local Plan, what can councils do to bring the site forward? (For example: The presence of these sites should be a “strong” reason to refuse development on greenfield/ unallocated sites elsewhere.) Do you have any local examples of stalled sites, and if any attempt has been made to hold the developer to account on why they’ve stalled?
Expanding the network?

9. End