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Council makes housing delivery action plan after failing on targets

Lewisham Council has created a housing delivery action plan after failing to meet its targets. 

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Lewisham Town Hall
Lewisham Town Hall (picture: Google Street View)
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According to a new council report, Lewisham failed the Housing Delivery Test (HDT) by delivering 386 homes in 2021-22, instead of its target of 1,667.

This latest government data on the council’s delivery shows that it has fallen below the 75% threshold, meaning it must prepare an action plan and identify a 20% buffer on its five-year land supply, and that the presumption in favour of sustainable development applies.

The government introduced the Housing Delivery Test (HDT) in 2018 through the National Planning Policy Framework (NPPF). 

It measures the amount of housing completed against the number of homes that are required for an area, over the preceding three years. 

The annual target for Lewisham is 1,667, however it only delivered 23% of this figure in 2021-22. The target for the two preceding years was reduced because of the pandemic.


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In 2020-21, it delivered 523 out of a target of 1,110. In 2019-20, it delivered 1,283 out of 1,526. Over the three years, it delivered 2,192 out of a target of 4,303 (51%). 

Where delivery falls below 95% of the requirement, the council should prepare an action plan to assess the causes of under-delivery and identify actions to increase it.

Where delivery falls below 75% of the requirement over the previous three years, the presumption in favour of sustainable development applies. 

The five-year housing land supply, which sets out housing sites deliverable within the next five years, must include a buffer of 5% to ensure choice and competition in the market for land. 

This must be increased to 20% if there has been significant under-delivery of new homes in the preceding three years. 

From 2015-16 to 2017-18, Lewisham hit 95% of its delivery target, followed by 101% from 2016-17 to 2018-19. 

According to the council report, going before the mayor and cabinet next week, Lewisham, “like many other councils”, has “seen a significant reduction in housing delivery since the COVID-19 pandemic due to stalled sites, rising construction costs, changes in fire safety regulation”. 

Inside Housing reported in December that Lewisham had revised its development programme amid “challenging” economic conditions.

The council report said: “Lewisham is not alone. Thirty-two per cent of local authorities across England failed their HDT to some degree. The South East saw the greatest proportion (48%) of local authorities fail the HDT to some degree, with 32% facing presumption in favour of sustainable development. 

“In London 51% of local authorities failed the HDT to some degree, with approximately 36% in the presumption of sustainable development.”

The report said that the council “continues to demonstrate more than a five-year housing land supply” and has granted consent for more than 14,000 additional new homes.

It said: “Delivery of housing is expected to improve with several large sites under construction or nearing completion, such as Lewisham Gateway, Silver Road, Heathside and Lethbridge.

“There is also a good pipeline of development sites identified through the housing trajectory in the submitted new local plan. 

“However, due to the way the HDT is calculated using preceding years of delivery, Lewisham is likely to be subject to all three penalties until at least the 2026 HDT result.”

At present Lewisham has more than 7,500 homes with detailed planning permission, or resolution to grant permission, which are yet to be built. A further 6,500 homes have outline planning consent. 

According to the report, while “many sites within the borough do start to deliver homes in a timely manner” after an application has been granted, “others do not”. 

“This is where Lewisham and other councils across England need private developers to step up and deliver and/or new powers need to be introduced by the government to penalise private developers who fail to deliver in a timely manner to an agreed development programme,” it said. 

The council’s action plan aims to enable “swift determination of planning applications through an efficient, proactive service and effective engagement” with applicants.  

It seeks to maximise the amount of housing in applicable developments and “in particular strive for higher amounts of genuinely affordable housing”.

Other aims include improving partnership working and ensuring the “efficient operation of S106 and CIL so that infrastructure can be delivered in a timely manner alongside housing growth”. 

A Lewisham Council spokesperson said: “The Housing Delivery Test sets a challenging target of over 1,600 new homes a year in Lewisham. 

“Over recent years the borough has had a good track record at delivering new homes and as recently as 2020 we were delivering over our target. 

“However like many areas, Lewisham has seen a significant dip in the number of homes being completed since the pandemic, due to a number of reasons impacting the industry, including rising construction costs and changes in fire safety regulations, and we have granted permission for over 14,000 homes that developers have yet to build. 

“As a consequence we have drafted an action plan, in line with government requirements.

“Over half of London boroughs are in a similar position. However, Lewisham is in a strong position in that we have more than a five-year land supply and we have a new local plan which, if approved by government, will set out the areas suitable for development.”

In March, it emerged that Islington Council scrapped seven schemes and a planned block on an estate from its homebuilding programme amid “intense cost pressures and significant risks”.

In April, Newham scrapped plans for an affordable housing scheme after significant construction cost hikes and delays in securing the necessary statutory consent.

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