RE: 'Persistent Under Delivery' of Housing and Lack of published HDT results

2026-07-06T08:31:45Z

Hi Alan

We are in a similar, but opposite position in that with the last published HDT result we fail and fall into the penalty sections. However in recent years our delivery has spiked with a significant increase which would, I think, put us out of the penalty requirements. This is confirmed by the most recent projections by Pegasus. The failure of Government to publish these results in a timely fashion, as per the commitment, has significant real world implications given that, as you say, the HDT result is part of the 5 year supply consideration. The HDT result has crucial implications for decision making on planning applications involving the provision of housing through Footnote 8 and Paragraph 11 of the Framework.

The fundamental nature of the HDT result in decision making means that are the process of considering planning applications, reporting and taking them through planning committee means that if the HDT changes it could mean a complete re-write and delay in decision making on housing applications.

I note Lord Banner's question and the answer that the results for the two most recent years would be published 'as soon as possible'. There was a suggestion that the updated HDT results would be published with the new NPPF this summer. There is now speculation that the NPPF may not be published. Who knows? But the HDT results are factual and do not rely on a new NPPF unless the new NPPF changes the way the HDT is used?

I would be interested to know also how this affects Plan making. A 5 year supply is required on adoption of a new Plan. So if a Plan is at Examination and the LPA is calculating the 5YS (and the buffer), do they use the last published (and clearly out of date) HDT result or something more recent to determine the buffer?

'Persistent Under Delivery' of Housing and Lack of published HDT results

2026-07-02T14:48:30Z

I'm just wondering if anyone has come across anything relating to how the question of 'persistent under delivery' is being implemented in respect of demonstrating a five year housing supply in the absence of the last two HDT measurement results. Particularly any relevant appeal decisions.

We're in the position where the last published HDT had us comfortably over 100%, but the impact of the new LHN methodology now means that our result may well fall significantly below (even though actual delivery has remained fairly stable)

Footnote 40 of the NPPF ("will be measured against the Housing Delivery Test") is pretty clear - but it is also clear that it will be very tempting for applicants to seek to argue that the HDT is out of date and propose alternative estimates.