While the NPPF is intended to be a plan-led system, only 24% of local planning authorities (LPAs) outside London and National Parks have local plans adopted post NPPF. A greater proportion, 51%, have no adopted plan but are working with recently published strategic housing market assessments (SHMAs). That 25% have neither an adopted plan nor up-to-date SHMAs ought to be cause for alarm.
However, the biggest concern is that housing targets adopted by local planning authorities to date represent only 80% of the level indicated by the appropriate SHMA.
The disparity is even wider where the housing requirement is greatest. The target in the London Plan is 42,000 new homes a year despite a needs assessment of between 49,000 and 62,000.
The allocation of sufficient sites for development also needs addressing even where plans have been adopted. Our research shows that 31% of English local authorities (90 of the 293 excluding London and the National Parks) have acknowledged that they do not have a five year supply of housing land as required by the NPPF.
Furthermore, the lack of definitive methodology for calculating five year land supply, leaves room for interpretation and a lack of certainty as to whether enough land is being allocated to housing. While 175 local authorities state they do have a five year land supply, our own calculations (see Our Calculations) suggest 43% of these do not and 26% are borderline cases.
As a result of these issues, housing shortfalls are at risk of becoming embedded in the planning system, storing up problems for future.