21 Jan 2022
The Housing Delivery Test (HDT) provides an insight into national and regional housing delivery in 2021 against the number of homes required over a rolling 3-year period in each local authority. It also allows delivery from the preceding year to be monitored. It is more than just a monitoring tool and has far-reaching implications for many districts in the North West, with escalating planning sanctions applied depending on the scale of any shortfall.
HDT scores in the North West indicate that the region has been broadly improving in its delivery of housing as 79% (30) of the 38 districts in the North West have delivered more homes in percentage terms than the preceding rolling three-year period (2017/18-2019/20). It should be noted, however, that the 4-month reduction in requirement for 2020/21 has impacted these figures. Despite these mitigating circumstances, 6 authorities in the North West have experienced a regression in housing delivery over the past three-year period as reflected in their HDT score. It is clear that there are repeat offenders in the North West that contain to fail to meet their minimum housing requirement and this has been accentuated by a consequence in presumption in favour of sustainable development from a baseline of 75% as opposed to the former 45% threshold.
The consequences in a failure to meet an HDT score of 95% are apparent as 3 authorities (Warrington, Rossendale and Bury) are now subject to a presumption in favour of sustainable development despite the reductions applied to account for the national lockdown. This is the first time that any authority in the North West has received this consequence since the introduction of the HDT in November 2018 and is clearly a result of the increased severity of the new 75% threshold.
North West Results 2020/21
79% (30) of the 38 authorities in the North West are delivering sufficient levels or in excess of their housing requirement (defined as either the latest adopted housing requirement or the minimum annual local housing need figure/annual average household growth);
3 authorities (Oldham, Stockport and Tameside) require an Action Plan to address an unfulfilled delivery of housing in relation to their minimum housing requirement;
2 authorities (Bolton and Trafford) require a 20% buffer and an Action Plan; and
A presumption in favour of sustainable development has been triggered in 3 authorities (Warrington, Rossendale and Bury).
Key Changes from 2020 to 2021
The noteworthy changes within the region from 2020 to 2021 are as follows:
No authority required an Action Plan under the consequences of the 2020 HDT but Oldham, Stockport and Tameside now each require the preparation of an Action Plan to address their delivery issues. Interestingly, each of these authorities experienced an increase in their 2021 HDT score in comparison to their buffer consequence in 2020 to in excess of 90% of their housing requirement (Oldham 90%, Stockport 92% and Tameside 91%) but still require intervention with a failure to meet the 95% threshold.
Warrington were forced to implement a 20% buffer as a consequence of the 2020 HDT and despite an increase from 52% to 72%in 2021, the LPA are now subject to the presumption in favour of sustainable development which applies to delivery below 75%.
Despite being required to introduce a 20% land buffer under the 2020 HDT, Bury (52%) and Rossendale (57%) have both seen a reduction in their housing delivery between 2020-2021. Each authority is now subject to the presumption in favour of sustainable development.
Top performing Authorities include Copeland (932%), Burnley (434%) and Knowsley (410%) which have all seen a percentage rise in their results between 2020 and 2021.
An Analysis of Greater Manchester, Action Plans and Green Belt Release
Previous Planning Matters’ blogs have demonstrated the ineffectiveness of HDT Action Plans in the North West as although Councils are ‘expected’ to prepare an Action Plan when they deliver below 95% of their requirement, the effectiveness of the Action Plans are not scrutinised if a Council does not improve their HDT score in subsequent years. The Practice Guidance advises that Action Plans can take a number of steps to:
Identify the reason for under-delivery;
Consider methods of reducing further under-delivery; and,
Outline measures that will improve the rate of housing delivery.
However, as noted above, no additional sanctions will be placed on Authorities who continue to fail their Housing Delivery Test. Although Action Plans should be deemed as aiding performance outcomes rather than as a punishment for under-delivery, serious concerns still remain regarding the effectiveness that they actually have on housing delivery.
Of the 8 authorities in the North West failing to meet their HDT, 6 are located in Greater Manchester (including Stockport) and the Greater Manchester Green Belt and the failure to adopt progressive Local Plans in the sub-region are the most significant constraints to housing delivery. Though not located in Greater Manchester, Warrington has also failed once more subject to comparable Green Belt constraints. Former iterations of the Greater Manchester Spatial Framework (now Places for Everyone) became highly politicised on the grounds of Green Belt release to meet future development needs. This ultimately led to Stockport’s withdrawal from the GMSF and further delays to the preparation of the Plan.
It should be noted that Stockport, Oldham and Tameside each ascended from the 20% buffer zone to solely requiring the publication of an Action Plan under the 2021 HDT scores. However, Trafford and Bolton remain subject to a20% buffer. Trafford and Bolton both published Action Plans in July 2021 following the results of the 2020 HDT but each Action Plan focuses on elements such as delivering housing in the Town Centre as part of wider longer term regeneration projects, with no acceptance that additional Green Belt release will be required to meet longer term needs.
In addition, Bury’s performance continues to worsen with its HDT score reducing from 61% in 2020 to 52% in 2021. Paragraph 11d of the Framework states that the presumption in favour of sustainable development should be applied if an authority cannot demonstrate a HDT Score in excess of 75% but this does not explicitly provide a solution to an authority such as Bury where Green Belt constraints significantly restricts the Council’s ability to identify sufficient levels of housing land.
The HDT provides insight into broader narratives of housing delivery, but Actions Plans and the presumption in favour of sustainable development cannot be perceived as an effective and short term solution to housing delivery particularly where Green Belt constraints significantly restrict development potential of land currently outside the urban area.
There is a clear trend of rural authorities with comparatively lower housing requirements performing well. For instance, the highest performing authorities were Copeland (932%), Burnley (434%) and Eden (376%), all of which are predominantly rural.
It is clear that some of the Green Belt authorities within and surrounding Greater Manchester perform particularly poorly in meeting the need for new homes. Oldham, Tameside and Stockport each demonstrate a requirement for the publication of an Action Plan as they failed the HDT, whilst Bury, Warrington and Rossendale are subject to a presumption in favour of sustainable development.
Although authorities such as Manchester and Salford meet their housing requirements, this does not inherently suggest that much needed dwellings in the form of affordable houses, executive homes and family housing are being appropriately delivered.
Bury is the worst performing authority in the region with a HDT score of 52%, a score which has deteriorated despite the Council preparing an Action Plan last year. This would appear to demonstrate that the Housing Delivery Test and its associated consequences provide little impact in quickly addressing delivery issues.
Overall, the performance of authorities in the North West is strong with many authorities delivering well in excess of their minimum housing requirement. North West authorities outperformed the national average as 79% of authorities received no consequence as a result of the latest HDT. In addition, only 3 authorities in the North West are subject to a presumption in favour of sustainable development, equating to 8% of the North West authorities, which is half the national average.
Our historic high streets and town centres have been dominated for decades by retail uses, and while retailing is still an integral part of what they offer, the pressures facing traditional retail have resulted in the average vacancy rate nationally rising to just under 14%. This has left many high streets and town centres in need of regeneration and investment. Fortunately, they have huge potential for improvement, adaptation and reuse, and many benefit from heritage assets that can serve as focal points for regeneration.
Historically, high streets and town centres were places where communities would live, congregate, learn and work, not just shop. They were built to support a diverse range of uses and they are very well positioned to do the same in future if investments are made in restoration and reuse. Indeed, repurposing redundant floorspace offers exciting opportunities to rebalance what our high streets and town centres have to offer.
It appears that things are about to come full circle as the high streets of the future, as envisaged by Government, are places where more people live and work and where community uses are more prominent, as was the case in the past. The Government’s ‘Levelling Up’ agenda is primed to support this vision with significant amounts of funding, which could result in some of the most positive changes to our town centres seen in generations.
In July, Lichfields published ‘Moving on up?’, an Insight that reviewed the initiatives for levelling-up of town centres in the north of England. It analysed over 100 bids to three key funding streams aimed at achieving town centre regeneration, including the £3.6bn Towns Fund, the £1bn Future High Streets Fund (of which £95m is set aside for High Street Heritage Action Zones) and most recently the £4.8bn Levelling Up Fund. This revealed six key themes underpinning these bids; unsurprisingly heritage-led regeneration was one of them.
To understand why there is such interest in heritage-led regeneration in our town centres, it is worth noting that almost half of buildings in retail use and 33% of office buildings were built before 1919. Many of these buildings have been neglected or poorly adapted in response to various cycles of economic and social change. The idea behind heritage-led regeneration is that targeted investment in the restoration and reuse of heritage assets can deliver wider economic and social benefits. This is not a new-fangled idea, but the way that heritage-led regeneration is being implemented has evolved over time and is now far more complex and multi-layered.
For many years there was a tendency to think that simply restoring historic buildings and providing new shopfronts and usable floorspace would be enough to deliver regeneration and attract new occupiers, despite there being little empirical evidence to support that assumption. Now, following studies into the effectiveness of heritage-led regeneration projects, such projects are increasingly based on clearer business and investment strategies and form an embedded part of wider programmes aimed at improving local economies through investment in infrastructure, new industries and technologies. Embedding heritage-led regeneration in this way can both harness heritage investment’s potential to inspire action and promote initiatives, as well ensure that it produces more effective, sustainable and long-lasting regeneration results.
Heritage-led regeneration projects are also focused more than ever on reusing heritage assets in ambitious and creative ways to respond to changes in the way that people live, work and shop. For the high street, this means adapting historic buildings to respond to changes in retail and growing demand for leisure activities, creative and flexible workspaces, and housing in sustainable and accessible locations. It is also about bringing the history of places to the surface, engaging communities in heritage projects and enhancing places with the aim of attracting new businesses, visitors and residents.
The role of heritage-led regeneration in reimagining and repurposing our high streets for the future is reflected in the literature produced around the latest rounds of Government funding aimed at levelling-up towns across the country. Lichfields has been at the forefront of Government funding activity in the north of England, inputting into various Towns Fund bids. We were involved in preparing the Future High Streets Fund bid for Bishop Auckland and we are currently involved in supporting the development of several potential Levelling-Up Fund bids. We have also been appointed to develop business cases for schemes in Blyth, which have secured in principle funding from the Towns Fund. Bringing together our combined expertise in planning, heritage and economics, Lichfields is well placed to assist with high street and town centre regeneration in a variety of ways, including navigating the planning policies that cover heritage-related works, developing evidence-based investment strategies and business cases, and preparing Statements of Significance, Heritage Impact Assessments and Conservation Management Plans.
Lichfields’ Insight, ‘Historic Opportunities’ aims to shed light on the environmental, economic and social contributions that heritage-led regeneration can make. It looks at how this is being achieved across the country in areas benefitting from the various funding streams designed to support the Government’s Levelling-Up agenda.