This document provides guidance for local authorities in developing action plans to address under-delivery of housing identified through the Housing Delivery Test. It discusses lessons learned from the first round of action plans, forecasting housing delivery, key components of effective action plans, dealing with the presumption in favor of sustainable development, and engaging with developers. The document emphasizes keeping action plans concise, focused on outcomes, and framed in a way that various audiences can understand. It also provides templates and examples of good action plans that address both immediate and long-term actions to increase housing delivery.

1. Housing Delivery Test
Action Plan Support
Shelly Rouse, PAS
Richard Crawley, PAS
March 2020 www.local.gov.uk/pas

2. Introductions
• You will be a “mixed ability” group
– Some expert monitoring people
– Others … ?
• Informal, friendly
• Frank
• Learning environment – no stupid questions
• Who are you?

3. Why are we here?...
1. What we learned from the first cohort
2. Forecasting and scenarios
3. What a good Action Plan is
4. Lessons learnt (save time and hassle!)
5. Dealing with “presumption”
6. Talking to developers
7. ? Anything else ?

4. Hot off the press!

5. Remember our Councillors guide
• Find the whole thing online
• https://local.gov.uk/pas/pas-
topics/monitoring-and-delivery
• Steal it all
• Suggest improvements

6. Advice for your younger self
● Good bits of your action plan ?
● Pointless bits of your action plan?
● Make a new friend

7. Make a friend
Think about
• Good / bad bits of your action plan
• Missed opportunity?
• Waste of time ?
• Key messages
• Key audiences
• Summarise the story of your new friend

8. Group Therapy

9. Break ?

10. How to forecast HDT results
Three step proposal:
1. Forecast your rates of delivery
2. Understand your local plan position
3. Guess what is going to happen to LHN
Plug the numbers into the LGA’s model, and let it take the
strain

11. How to forecast HDT results
1. Forecast your rates of delivery
You may need to break down types of supply ?
Use these figures in columns O, P and Q
[hint: use the name box]

12. How to forecast HDT results
2. Understand your local plan position
Turns 5 ?
New plan ?
Plan “review” ?
[for London boroughs] new London Plan ?
Use these figures in column D

13. How to forecast HDT results
3. Guess what is happening to LHN
The 2018 set of ONS household projections is out in
September [we are still using the 2014 set. the 2016 ones
were mostly lower. Smart people think the 2018 ones are
going to be lower again]
There is a review of LHN coming (probably in September)
What do we think Govt will do ?
Use these figures in column I

14. How to forecast HDT results
How was that ?

15. PAS support
• We are in year two
• https://local.gov.uk/pas/pas-topics/monitoring/housing-
delivery-test-action-plans

16. What we have for you
1. A guide (it’s quite good !)
2. Two templates
3. Some things we learned – the next guide will be better
• Take it all away – save yourself some angst

17. A guide

18. A guide
• Broadly speaking – it’s all good straightforward stuff
• We’re going to update it
– More numbers, scenarios
• Projections (eg “do nothing”)
– Be clearer about purpose
• Preferably before you start
– More focus on creating a material planning consideration ?
• Discuss…

19. Template 1 - actions

20. Template 2 – land supply
• Identify typologies
• Quantify options
• To be updated as part of APS
work

21. What we learned + TOP TIPS
• AP must reinforce your strategy not undermine it. Think about
how it might be used against you.
• Think about how you will revisit your actions and demonstrate
progress
– it doesn't need to be a complete record !
• Identify key decisions and caveat them if you don't have council
sign-off
• Ensure that actions really are connected to delivery
– and your existing strategy

22. Sketch out the strategy, demonstrate the
link to actions

23. Lunch

24. Action Plans - What does ‘good’ look like?
• Content and Coverage
• The right audience
• HDT result looks back - Action plan looks forward
• Lessons learnt

25. Content and Coverage - Keep It Simple
• Try and make it straightforward and framed in terms that
allow [normal] people to understand what you're trying to
do and why it matters to them
• Would the CEx or resident recognise the narrative ?
• Is it a neat parcel that links back to what matters ?
– think of a busy reader

26. Numbers and the direction of travel
• Projections
• Scenarios
• Predictions
• HINT: many peoples results will get worse because of the
way LHN is phased in - the perception that your actions
are making things worse is not good

27. The right audience
Who are you expecting to read this thing?
• Hint: it's not going to be government / an inspector
– unless it is ! in a topic paper supporting your plan !
• Your developer community ? Your leader ?
• Why do they care ?
– No one wants to read your “things to do list”
• Think “inside” / “outside” [the council]
• Think “big up Bolton” = promotion and intent
• Think “paint a picture” to support your team

28. Looking in both directions
HDT HDT HDT Yr 1 Yr 2 Yr 3 Yr 4 Yr 5
Now
Looking backward 3yrs Looking forward 5yrs

29. Actions - Bang for your buck
• You are the author and most likely reader
• What can only you do ? What can others do?
• Where are the biggest and quickest wins ?
• Look forward to the 5YHLS for solutions
• Weaponise your Action Plan - make it a tool to
work for you

30. The Actions
• Actions like being in a table
– what is the best table ?
• Framed in ways your audience connects with
– outcomes on their terms
• Not enormous leaps but steps along the way
• Realistic timescales
• With previous completed steps still visible

31. Shelly’s Take on ‘Good’ Action Plans
● Concise
● Respond to the ‘Wake Up Call’ the HDT is
● Have immediate actions as well as
short/medium/long term
● Look beyond planning
● Are written for yourselves as a tool to use

32. Good Action Plans
• Addressing both general and site-specific issues/barriers
and providing solutions tailored to those
• Critical evaluation of current council led processes
• Acknowledgement of issues that are outside of council’s
control but still attempting to influence
• Providing estimated timelines for further steps
• Communication with neighbouring local authorities with
better HDT results for advice
• Feedback gathering from the communities and
developers

33. Good Actions
• improve/adopt local plan
• improve monitoring process
• address delays in commencement after planning permission
• prompt engagement with early stalling site
• improve planning application process (provide pre-planning
application advice; check list and ‘model’ information)
• attempt to retain skill and labour force
• pursue funding (such as HIF)
• identification of land (launch Call for Sites, update Brownfield
site register)
• Influence the wider housing market

34. A few good reads
Sevenoaks, Great Yarmouth, South Holland, Basingstoke
and Deane, Bracknell Forest, Havering, Huntingdonshire,
Mid Suffolk, Pendle, Sefton, Thanet

35. Or does it really matter?
There are some options available
1. Do the minimum to update the Action Plan
a. Short term blip
b. Plan imminent
2. Make it a useable tool - mat con
a. This is an ongoing trend
b. Presumption already applied?
3. Maximum effort - move, move, move
a. Dynamic tool and real culture change
Don’t make it pointless

36. “Presumption”
In this section
1. How is it different to 5YHLS presumption?
2. Planning research
3. https://www.bailii.org/ew/cases/EWHC/Admin/20
20/518.html

37. How is it different to 5YHLS presumption?
• Honest answer?
• We don’t know yet
– Need to see how PINS behave
– And how appellants behave
– And how planning committee behaves

38. How is it different to 5YHLS presumption?
• Looks backward not forward
– Could it be the numbers (yrs1-3)
– What's happened - is it a specific thing
– Is the future bright?
• Unlike 5YHLS it's a simple sum and may not
involve dissecting sites
• Fixed for a year – different risk profile ?

39. https://www.planningresource.co.uk/article/1674517/seven-
key-factors-differentiate-successful-unplanned-housing-
appeals-unsuccessful-ones
Focus was land supply, but principles apply

40. Planning research found …
1. You are not necessarily doomed
2. Harm matters more than benefit
3. Impact (on landscape) is critical
4. Green belt proposals must demonstrate no harm to
openness or purpose of GB
5. Proposals that reduce gaps must leave enough gap
6. Transport impact and Highway objections matter
7. If heritage harm, benefit to public crucial

41. Mr Justice Holgate has today handed down judgment
in Gladman Developments Ltd v SSHCLG & Corby BC &
Uttlesford DC [2020] EWHC 518 (Admin), a rolled-up
hearing in two linked challenges under s288 of the Town
and Country Planning Act 1990. The Judge refused
permission, concluding that all four issues were
unarguable.

46. • Does this judgement provide a useful framework for
describing one useful version of a HDTAP ?
• ie to describe how you will approach a doubly balanced
decision ?

47. Why are we here?... Did we succeed?
1. What we learned from the first cohort
2. Forecasting and scenarios
3. What a good Action Plan is
4. Lessons learnt (save time and hassle!)
5. Dealing with “presumption”
6. Talking to developers
7. ? Anything else ?

48. pas@local.gov.uk
@Pas_Team
web www.local.gov.uk/pas
phone 020 7664 3000