Reflections on Housing Delivery Test 2019

In advance of the official updates to our guide and templates, I thought I would share where I got to with my thoughts on the Housing Delivery Test and the very first set of Action Plans.

These thoughts are the result of the dozen workshops we held throughout spring and summer with representatives from 60 councils, along with some follow-up work on a mixture of action plans.

We will be doing some more robust testing and thinking when the councils action plans are published. This is a “seat of the pants” reaction to the many and various thought-provoking conversations I had with the wonderful delegates over the last 5 months.


To start with a few weasel words. This is the first ever cohort of action plans, and the timetable for their production couldn’t have been much worse. The clock started with without any proper lead-in on February 19th, and the six month deadline is therefore in mid-August.

Not only is August just a dreadful time to get sign-off and agreement on documents, but the fact that meaningful actions require the agreement and consultation with various other stakeholders means that the first iteration of these plans is likely to be low-key. Expect lots of “investigate further the reasons behind …” and “explore options with stakeholders” without much actual stakeholder engagement.

Part of what we asked councils to do was to understand their land supply and the causes behind slow and stalled sites. And it won’t be a surprise to anyone close to the work that the world of monitoring is not a happy place, with much of it manual, painful, and difficult to marshall into something useful at short notice. #plantech please come back all is forgiven.

Lastly, and this may be an obvious thing to say, there just isn’t a bunch of silver bullets lying around waiting to be fired by LPAs to “fix” the delivery of housing in a single bound. All councils are already trying a variety of approaches to boost housing, and most action plans will recount projects that are already to some extent underway.

Causes of housing under-delivery

“All happy families are alike; each unhappy family is unhappy in its own way.”

Tolstoy – Anna Karenina

I can’t now remember where I read it, but I was expecting to find that while there may be broad macro reasons for under-delivery there would be a local and specific story for each unhappy major site. I was expecting a complex patchwork of causes making my job of drawing out some common themese difficult.

Instead what I found was that many councils view is that the cause of failing the test is that the test is using standard method numbers, rather than locally appropriate numbers.

[as a slight aside, what I took away from many of these conversations is that the approach of Part 1 strategic policies / Part 2 allocations is a bad idea for many places. The regulatory goalposts move too quickly – the higher level plans move too slowly – the electoral cycle revolves. The allocations appear late (or not at all) which makes it difficult to bring forward big sites and leads to appeal friction. Far better for many LPAs to move to a simpler all-in and review every 4 years approach in my view.]

Slightly depressingly, when taken at face value, this suggests that the cohort are behaving towards the test in a predictable way. Don’t like the test result? Change the inputs to the bottom of the fraction and get a better result.

In the longer term I’m sure a more nuanced picture will emerge. It’s possible that lots of it will never appear on public documents but we have had many fascinating and slightly hair raising conversations about how delivery is tested at examination and how the various incentives align to create a conspiracy of optimism that quickly unravels.


This is the first time around the HDTAP loop and we were all learning together. I’m afraid I was quite unflattering about some of the action tables in draft plans. I struggled to articulate something more helpful until we had a very useful debate in Manchester about who the audience was for the action plan. Once the audience and purpose of the plan is clear, many other questions become easier to answer.

In short – you are not writing the HDTAP for the benefit of a civil servant in MHCLG. There are no marks for completeness, and no one is interested in your “list of things to do”. However, if the purpose of the action plan is to get some people to do things differently, write for them in their language and keep it tight so they don’t get bored.

In our KHub you can see my “top tips” that I delivered at our final “grand finale” event at AECOM’s office in London on the hottest July day ever. As someone said at the time, it would have been good to know them at the outset rather than the close but that is not the way inventing the art works.


It is obviously early days for the Housing Delivery test as a policy. My informal canvassing at our workshops suggests that while the policy attracts criticism for being one-sided, the requirement to understand delivery from other perspectives [and, importantly, away from the context of a local plan examination] has been extremely useful.

The test could lead to a culture change more generally, where planners are forced to confront the fact that delivery is a team game that requires local knowledge, intervention and creative thinking. It might also have a useful knock-on effect on local plans – framing them more clearly as delivery plans.

However all good projects start with evaluation and I worry that the most important voice of all is missing. Taken simply – the purpose of the test is to push councils into taking action to enable and facilitate development that might not otherwise have happened. The people who are in a position to judge this are developers. We need some way of capturing their perspective to ensure that the HDTAP isn’t just another annual report that no one reads.

Looking forwards

As mentioned at the top we learned alot along the way and we know how to make our guides and templates stronger. And even without any more input from us I’m sure the cohort of councils repeating the HDTAP process in November 2019 will be able to produce a better document than they could first time around, jut by virtue of having more time for meaningful consultation and input.

There is the updated PPG too, with a fairly clear suggestion of “assessment and delivery groups” and some other changes that need a bit more thought. The change of stance on annual position statements makes it clearer in my mind than ever that we need to rethink monitoring more generally, and get the most possible value from the least possible work. The current situation with a mishmash of different timetables and requirements is intolerable – I will ask some of my new, geeky, monitoring friends how we might reorganise and improve this shortly.


GDPR and planning: anyone home?

I get asked to come along to regional meetings of planners around the country [thank you – I find it really helpful even thought I can’t get to them all] and for the last year or so I have to sheepishly begin with an apology. Our guide on GDPR hasn’t been published beyond an initial draft and my initial blog post.

I’m not entirely sure that I understand what the cause of the delay is – and I don’t think it is helpful for me to speculate. It is essential that the new guide has the blessing of various important stakeholders and is robust. So instead I offer up a presentation I gave a little while ago to one of those regional meetings. As always, more interesting than my slides is the conversation and debate they led to.

I was on my feet for the discussion and couldn’t take notes, so I can only summarise what I thought were the most important themes:

People want rules, but they can’t have them

Quite properly people were expecting the replacement for the PARSOL guide to contain updated rules in line with the GDPR. These rules then get folded into every DM procedural manual and life can continue. But this is not going to happen – or at least not so that people can switch off their brains and behave like robots.

Instead of rules there are principles. In practice the distinction isn’t very important, because the principle of fairness (as the most obvious one) means generally to follow the rules except in situations where that wouldn’t be fair.

This isn’t something that we seem to be very good at in local government. Certainty and rules are easy, discretion and pragmatism are hard. Too bad – there is no short cut for this. The good news is that data protection isn’t particularly difficult and is not much beyond common sense.

Planning is a public task – let’s do it in public

I started in the wonderful world of planning in 2005 in the white heat of e-planning and the digital agenda (although we didn’t call it that at the time). We spent lots of energy turning planning from something that happened in case files that sat on someones desk into something that happened online and accessibly.

Let’s not lose that progress.

My view is that planning is a democratic process that needs to be seen to engage with the sometimes competing views of what is, on balance, in the best public interest. That’s why my view is that comments on planning applications *should* be published (suitably redacted).

[I seem to recall that this led to a discussion about an application for a exploratory well for fracking that attracted several thousand very similar comments. In that case I would *not* publish comments. Why ? – common sense. ]

Do not shred everything!

It is probably overdue that we wake up to the fact that keeping every scrap of information from everyone for ever in some kind of online case file isn’t very helpful (or proper).

Document and data retention is important, and deciding to automatically shred all consultation responses after X weeks is a one-way process that cannot be undone. Let’s be thoughtful about this.

I have found it very useful to remind people that there is a common sense difference between the impact and long-term importance of a neighbour’s viewpoint on a kitchen extension and the advice from a statutory consultee on a major development. I have heard some people suggest that the safest approach is to delete everything and keep only the statutory register – this is lunacy.

Can we all just chill out a bit?

Over the course of the conversation we returned several times to the basics of what data protection is about. The purpose of these regulations is to stop unscrupulous reuse of data by megacompanies the like of which has never been seen before.

We inhabit a very different space. Actually our risks are pretty straightforward and manageable. We just need to mitigate the love of complexity and regulation that many of us have as part of our workplace backdrop. Trust me – accept that managing data is not something that happens once at the beginning of the process by validators following rules and is instead a set of basic principles that everyone needs to understand and you will be fine.

Exceptional Circumstances

In preparation for publishing some councillor briefings on housing numbers I have been doing some thinking about methodology. In the topsy turvy world we now inhabit, the new national method that hands-down numbers to local planning authorities is known as the Local Housing Needs Assessment:

NPPF Feb 2019

side note: I have been calling this the LHN figure but I notice that some others call it some variety of OAN / SOAN.

The LHN process uses a combination of population projections and affordability indices to provide a starting point for plan-making. The NPPF suggests that alternative approaches might be required in exceptional circumstances, so it is worth setting out some basics to see how such an argument might be mounted.

Circumstances where the standard method cannot immediately be used

There are several situations where the LHN inputs (of ONS projections and affordability) just don’t exist. These are listed out in paragraph 014 of the housing and economic development needs assessment PPG:

  • Planning authorities that are not councils (eg national parks)
  • Newly formed councils (eg following reorganisation)
  • Councils without enough sales data to generate an affordability ratio (one of the Somersets ?)
  • Development corporations [this isn’t listed in the PPG but must also fit the “LPA that isn’t a council” pattern]

In my view the newly formed council problem is quite easy to fix – and the LGA data team that run LG Inform have already recalculated the data points required for almost all the stats that councils need.

In national parks a slightly different strategy might be required but it should still reflect the two principles of population change and affordability. There is a bit of theoretical heresy because of the way the affordability indices are calculated but really life is too short to worry too much about taking an average of an average.

What other situations might be “exceptional” ?

There are some LPAs who point to their LHN result and know it cannot be delivered. Everyone has their favourite example of a result that is some combination of:

  • 3 x higher than has ever been achieved in the district
  • requires more land than can possibly come forward
  • generated for a tightly bound area surrounded by green belt (and/or sea, AONB, SSSI or similar no-go areas)

To what extent are these circumstances exceptional ? I think the answer is “not at all“. This is not the answer many councillors will be especially happy about. But, I think the job is to help them see that the process of planning may start with a standard number produced by LHN, but it certainly doesn’t end there.

The objective, of course, is to arrive at a plan that is deliverable. This means that the thinking must go beyond the “how much?” question and get into the “How?” and “where ?” questions. There are many examples of LPAs who have used some kind of capacity argument to demonstrate that a lower number is appropriate.

Might there be other exceptional circumstances ?

There are a couple of other questions floating around, and I don’t think I can do them justice because I don’t understand the underlying demographics well enough. One is to do with places with high student populations and how that interacts with mid-year estimates [generating low numbers?]. Another is the marvellously opaque “Unattributable Population Change“.

I’m very glad I don’t have to explain either of those things to councillors.

Remember more change is on the way

The LHN has had a short and quite eventful life. No sooner was it announced than MHCLG indicated that it would be replaced in due course – although I can’t find the reference just now. In my recollection I think I heard a two year replacement process for a newer, better, perhaps more nuanced take on assessing housing need.

If my memory is correct then we might expect a new version of a standardised method to appear in 2020, so to get heavily invested in an argument based purely on the mechanics of the current approach is possibly quite short-term. Not so the work done to establish how and where housing growth should best be directed.

Under the influence; remaining objective when emotions run high at planning committee

Guest Blog: Councillor Bill Stevens, Chair of Planning Committee, Plymouth.
I have recently been working with numerous councils helping them look at how public speaking is managed – how long to give each speaker? what order should they go in? how to keep them to time? etc. Most recently I was asked about how committee members, particularly the new or less experienced, can listen to the cut, thrust and emotion of public speakers, and remain objective and stick to matters of planning when making a decision.

As is the PAS way, I asked someone that knows about these things – Councillor Bill Stevens, Chair of Planning Committee, Plymouth. Here’s what he told me.

‘Conflicting loyalties’
As a preface to all of this we must remind ourselves of the sometimes conflicting local and political loyalties. Whilst everyone understands the political context of councillors judging planning applications, they must do the right thing and treat the process according to local and national policy etc. however hard that can be. The best Planning Committee Members/Chairs are those that have that in mind but see the wider picture and make policy-based decisions that benefit the community as a whole.

Emotions run high
The temptation for Councillors to get carried away with or emotionally ‘falling’ for what public speakers say is a very real one, especially on householder applications which deal with how individuals and families are supposedly affected day to day. The aim should be for us to get Committee Members to understand how to put comments like this in perspective. How we do that is the key!

Firstly, the thing to hammer home is that public speakers are biased. That’s not the same thing as saying that what they say is untrue though. People for and against planning applications will say what they want us to hear and it’s absolutely essential to remember we are not hearing from neutral, dispassionate people. Forgetting this is disastrous.

Secondly, our job is to consider planning applications against the local plan(s) and national statutes. If public speakers give genuine planning reasons to overturn recommendations, then fine, but that (and that alone) is what you’re looking for. We shouldn’t be afraid of going against what public speakers want.

When perspective is lost… how to approach this
I think officers, with or without committee member’s involvement, need to express concerns to the Chair(s) or possibly the Council leader if they feel that the committee is going against officer’s recommendations without strong justification/planning reasons. This is a political problem and requires political solutions. The Leader needs to be clear in their mind what they require from the Chairs and Committee members, every bit as much as they would have expectation of all other appointments.

Next, we need to ask ourselves if our Ward Councillors are working with objectors during the process from start to finish? If the first involvement objectors have is at the Planning Committee meeting, the system is failing. Ward Councillors need to be in touch with objectors throughout, liaising with the Case Officer and advising locals what may or not be achievable. It’s also good practice for Ward Councillors to liaise with the Chair (or Lead Opposition Councillor) to ensure their advice is sound. Keeping these walls up is always unhelpful.

If you are tempted….
Committee members should consider, if they’re tempted to agree with objectors, what the context is. Have they been working with Councillors? Have they met with Planning Officers? If not, why not? What advice and input comes from Planning Officers at Committee meetings? There are occasions when Councillors feel bullied or patronised into supporting officer recommendations so react against them. If that’s happening in your place, then officers will have to have a hard look at their approach.

And finally… the role of the Chair
A good Chair will appreciate their conflicting roles of championing Committee members, defending Officers’ political independence and allowing the public to feel they have a stake in the process. If Officers feel this is out of balance, they need to have fostered a strong enough relationship with the Chair to raise this.

Some really good advice here from Bill. Many councils will have new committee members just starting out and this is just the sort of advice that can help them in those early days. Please share your thoughts and ideas on this topic here.

PAS thanks Councillor Bill Stevens

Planners and mental health

One of the things we do alongside the work we do for MHCLG is small, bespoke pieces of review work for councils. We are asked to provide an impartial and external review – sometimes it ends up being a full peer challenge and other times a narrow and quite specific part of the planning department. One week it is with a big London Borough, the next in a little rural district.

Because we are sometimes dealing with quite sensitive issues, and we are often making friendly and constructive criticisms, we don’t tend to talk about it very much. It is fascinating and valuable and very good personal development so I do some too- especially if there is a sense there might be more going at the council than meets the eye.

Occasionally there are broad themes that emerge from the review work that are worth saying something about. It might be about problem solving, or innovation. This post is about mental health in planning departments – and how we might need to up our collective game.

The way we run a review is very simple. We sit the staff in a room, sometimes in groups and sometimes individually and we listen to them. Very occasionally we might ask a simple question, but really the art is listening carefully and then finding a way to reflect back in a structured way what we’ve heard to the organisation. It often feels like group therapy. Almost always at least one person breaks down in tears. Usually this seems cathartic.

On a recent review the team met someone who caused a bit more concern. No tears, but a conversation that revealed a mind under enormous stress. We are not really therapists, so we can’t do much more than set “the work” to one side and have a frank conversation about mental health with this person. We offered an early warning, and tried to explain how sometimes stressed minds get to a point where “more thinking” is not going to work. During this conversation the team learned about each other that we had both had serious episodes of stress in the past.

Working away from home and staying in a hotel delivering a piece of support means you have space and time to review what happened each day. That evening the team compared notes – in the course of most reviews it is apparent that there are people (often senior people) under too much stress. It is obvious why – the process of Development Management is relentless, the forces at play are enormous and the political component means you are never sure when something is going to blow up in your face.

Acknowledging the inate stress in DM leads natually to the question – “what are we all doing about it ?”. What is our equivalent of the Samaritans phone workers helping each other decompress after a shift ? The answer seems to be nothing beyond trying to fix people after things have got too much. This is not good enough.

Given that the battle for the “hearts and minds” of the general population on development is so far from being won, and the way some anti-development groups are using social media to harrass people in planning the potential for stress is going to increase. This is something that requires an organisational response, and most of the answer is probably no more complicated than recognising it as a real thing, hanging together as a team and supporting each other.

I am confident that you will have noticed someone around the office who appears to be under great stress. Perhaps you have thought about saying something at some point. My unscientific straw poll suggests it is most likely a planning enforcement officer. I can tell you that these conversations are easier than you think.

Like me you probably have a poster about mental health in the office kitchen. They go some way to helping normalise it, and they certainly made me more confident about explicitly bringing the topic into our work on planning reviews. But if I am right DM is almost uniquely tough and a generic council poster is not enough. What does (should ?) your organisation do to look after you ?

Timing is Everything; Quality Designation Measure

“For quality of decision-making, your performance is being assessed ‘now’ based on data that is well over a year old.”

I have had several goes at explaining the Quality measure and how it works, but I’m still to be convinced that everyone understands it and how it works, and right now feels like another good time to raise the subject again. I’ve also (see the foot of this blog) created a ‘Quick Guide’ to the Quality designation measure).

Sometime in June 2019 MHCLG will publish the latest performance data for its ‘Quality’ performance indicator (Live Table 152). This set of data will be used to assess which councils are in danger of being designated under the government’s performance regime.

Think about the timetable; in June 2019, councils will be considered for potential designation for the appeals upheld against decisions made on applications in the period April 2016 – March 2018. That’s a full 15 months on.

The calculation behind the quality assessment is convoluted to say the least – there are 2 periods at play; a 24 month period of decisions made on applications, and an additional 9  month period to allow appeals to go through the system. So it was not until December 2018 that all of the appeal numbers at play were known. Add into the mix another 6 month period for all of that data to make its way from PINS to MHCLG and you end up with the June 2019 decision time.

And in the meantime the next designation period for decisions made has started and finished (!) April 2017 – March 2019. So, if you are not careful with monitoring your performnace, it always feeld like your performance is being assessed ‘now’ based on data that is well over a year old (which is why it’s so important to keep ahead of what is happening by using the PAS ‘crystal ball’ available in the KnowledgeHub).

I have given up trying to explain what the ‘current’ designation period is (until June there are arguably 2 at play), but with the help of some PAS friends, I have created a ‘Designation Quick Guide’ to the quality measure – it helps explain how the measure is calculated and what is included and when:




Have fun with it and let me know if it’s helpful/can be improved?

Simon Says

The first of two reflections from me following our “Head of Planning” conference a couple of weeks ago. To be entirely frank it didn’t get off to the most spectacular start with our special guest speaker having to cancel at short notice.

Life in PAS is full of twists and turns so I decided to embrace the space we had inadvertedly generated for ourselves and run a short session called “Simon Says” – where we imagined the speech that we would have wanted our special guest to have made. In time-honoured fashion we got our tables to use it as an ice-breaker and scribbled it up the results on flip chart paper.

What an amazing mixture

It was always going to be quite a challenging set of asks, especially from heads of planning. As a matter of historical record, here is the list very lightly edited to remove a bit of duplication:

  1. One size does not fit all
  2. Spatial Planning – what are your thoughts on how this works?
  3. Explain the CIL / s106 debacle
  4. When will the CIL regs be published ?
  5. Encourage greater recognition of planning across government departments. Treat it with a more positive outlook rather than an obstacle
  6. Remove PD office to resi – this is creating the slums of the future
  7. Infrastructure delivery before the building of new homes
  8. Letwin review – what is government’s response ?
  9. Require more flexibility for housing delivery test and interpretation
  10. Consider squeeze on affordability and viability
  11. S73a – simplify
  12. Audit of 20% should be required then there would be no pressure from the finance department
  13. Viability – it’s frustrating as this is an exercise of smoke & mirrors and emphasis on viability by government makes it dangerous
  14. Minister talks about good design but PD rights are hypocritical to this
  15. Is government listening ? And / or moving ?

In my own view, once lots of complaints about a lack of responsiveness and general perceptions of unfairness are set to one side the most important points were made by the very first table.

One size does not fit all

It is a very basic question: where on the spectrum between central and local control should planning sit ? It is a question that doesn’t have a correct answer, and it may be that different parts of the planning system should sit at different points [as is already the case with NSIP]. However many of the other points in this list about infrastructure, quality and delivery suggest to me that the application of a single national policy to a complex pattern of local markets is leading to what we might call sub-optimal outcomes.

Spatial Planning – how does this work?

The preparatory moves required to shift planning policy from “very central” towards “more local” is I think starting to happen – slightly unsteadily and unevenly for sure. It is evident in the aspirations of some of the Combined Authorities and in the work that we have begun to scope out as part of our own strategic planning programme led by Nicola.

We are starting work with some regions (there, I’ve said it) shortly, and helping them articulate the added value of strategic development strategies. If done well, in ways that add value and deliverablity, these types of plan may well be part of the process of loosening the central control of key policies. More on this, no doubt, later this year.