NPPF Changes Consultation 2015

Ensuring Housing Is Delivered On Land Allocated In Plans - Page 2

What do you consider should be the baseline against which to monitor delivery of new housing?

We disagree with making the LPA solely responsible for fulfilling the housing delivery test.  While the NPPF requires the LPA to have a continuing 5-year supply of land for housing and to use its planning capacities to ensure timely approval of permissions, it has no control over the commercial objectives of house builders to whom the permissions are granted.  House builders will only build if the economic conditions indicate they can sell at a profit, otherwise they will ‘land bank’ the permissions.

Under such prevailing circumstances, we believe the LPA should have the capacity in statute to rescind unbuilt permissions after two years in order to incentivise house builders to build out granted permissions as fast as possible.


Rather than introduce a housing delivery test that would require local planning authorities to release land for development, introduce a condition to planning permission that developments must be completed (not just started) within five years or house builders face financial penalties. This would encourage them to complete developments within a fixed period. Local authorities should also be allowed to set realistic housing targets based on local need that are likely to be delivered over 20 years - instead of the current approach, which is failing to deliver the housing we need in the right places.

  • We propose the number of permissions against local plan targets is a fairer basis of monitoring than completions.
  • Delivery is often outside the control of the local authority. Account has to be taken of delays by the developer and other bodies responsible for providing the supporting infrastructure. The local planning authority should not be penalised if delays in implementation are outside its control.
  • There should be mechanisms in place to stop developers sitting on land with planning permission, or identified in SHLAAs as developable, whilst they wait for an increase in land values. There should be powers or policies to enable local authorities to compulsorily purchase land at a reduced value if developers are not being constructive. Section 106 agreements or bonds relating to starts and completions could also encourage development on time.

2017 Guildford Local Plan

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