Counting Houses - Public forum - Planning Advisory Service (PAS)

I just wanted to share a couple of thoughts about land supply/monitoring in the context of continuing changes to the planning system.

Our monitoring system looks both forwards and backwards. We count actual completions and we look forward and produce a housing trajectory and update a 5 year housing supply. We monitor against our recently adopted local plan requirement. I know that some authorities don't have this and are required to monitor against needs in other ways.

The Housing Delivery Test has been introduced and has implications for local authorities (especially if they fail). We went through an enormous process of evidence base building and debate and discussion and through Examination to set our housing requirement in our local plan and we measure our 5YS and our 'plan progress' against that. But the HDT is calculated by Government and is not measured against our housing requirement (se in our plan). It seems to be measured against something else but I'm not exactly sure what. It's clear to me that the HDT is not a correct indicator of housing delivery. I have seen local authorities that have a three year supply of deliverable sites, that are way behind meeting their housing targets and that have got well over 100% in the HDT. This can be for a number of reasons but one is that it only looks back three years. For example you can have under delivered against your housing requirement for years but as long as you met the requirement for the last three years, you're doing great. Likewise, you might have over delivered for a number of years and then for some reason delivery in the last three years has been slightly lower...so you've failed, even though over all you might be meeting your planned requirement and on target. Anyway, it doesn't work (in my view).

However, the HDT also comes along with a rule book which sets out how MHCLG are going to count your housing delivery. Although I'm not exactly sure how they count what you need each year of the three, they do set out reasonably clearly how they are counting what you have actually delivered. MHCLG will count how many homes have been delivered from your housing flow reconciliation returns (HFR). And in those returns they will also take account of communal student accommodation and communal C2 (eg Residential Care Homes). Communal student accommodation will be counted at a rate of 1:2.5 units (so 250 communal student beds = 100 dwellings towards HDT). C2 uses will be counted at 1:1.8 and so an element of C2 care homes will count towards your housing delivery test result.

If these Communal uses are being counted as resi units towards your actual housing delivery (in the past) then it's its correct and logical that they should be factored in the forward supply at the same ratios. This will mean that in your forward housing trajectory and 5 years supply (as long as they are 'deliverable') you will count C2 uses and Student Accommodation at the relative ratios. I believe that the NPPG guidance suggests this also. This could look a bit strange in your housing supply (counting a C2 residential care home) but given that when it's built it will contribute to your HDT return it is logical.

On the student ratio, this is for 'communal' student accommodation. But many areas, particularly University cities will also have non-communal student accommodation. These usually come in the form of self-contained residential units where an occupier can liver completely independently (no shared facilities, study rooms etc). These are 'self contained' units or 'dwellings'. As I see it they meet the definition of a 'dwelling' and so should be counted 1:1 both in the forward trajectory and 5 year supply. They will be counted 1:1 in the HFR because they are not 'communal' ands so they will be counted 1:1 in the HDT return.

The HDT has muddied the waters a bit in some ways but actually clarified things in others. It seems to be inconsistent with monitoring against your planned requirements as set out in a Sound and adopted plan but gives more clarity on exactly what you can count and to what degree.