The presumption in favour of sustainable development is growing in significance. The Housing Delivery Test (HDT) has become tougher in its second year, the implementation of the standard methodology has increased housing need in some locations, and increasing numbers of post-NPPF plans are now due for review. This all results in the presumption in favour of sustainable development applying in ever increasing numbers of local authorities. We project that by November 2019, 201 of the 325 local authorities in England could see the presumption in favour of sustainable development apply to all proposals.

When the results of the HDT are released for 2018/19 in November, we project that four local authorities will have delivered less than 45% of their housing need, and so will see the presumption in favour of sustainable development apply. This is a slight step up from the results of 2018, when no local authorities failed to meet the lower threshold of delivering 25% of housing need. More serious sanctions are likely in the third year of the test, when the delivery threshold will rise to 75% of housing need.

By November 2019, we project that 164 more local authorities could face the presumption in favour, either because they have not adopted a post-NPPF plan, or their current plan will be over five years old and need to be reviewed. Some 139 local authorities look set to pass the HDT and local plan hurdles, but 16 cannot presently demonstrate a five-year housing land supply. Three local authorities are projected to fail on all three measures, an improvement from our projection in 2018 when 14 were at risk of failing on each measure in 2019.

However, the emerging picture is that the majority of local authorities in England are at risk of losing full control of their planning policy. The pressure will be particularly felt in London and the wider South East – areas with the highest housing need. Given the requirement for homes in these areas, it is essential that local authorities become more proactive in identifying land for residential development, so that future development can be planned and delivered in the most sustainable way.

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