As the new NPPF comes into force, many LPAs have seen major swings in land supply positions, bringing the presumption in favour of sustainable development into play across much of England
Local Plan Status
Plans progressing as planning authorities shift gears and adjust to new rules
With the Government’s planning reform agenda well underway, the anecdotal evidence “on the ground” is that planners are scrambling to adjust to the revised National Planning Policy Framework (NPPF) and higher housing requirements. This will take time, however, and the result in the meantime is a slowdown in plan adoption, with five Local Plans adopted in the first three months of 2025.
More positively, and reflecting the strength of activity, a majority of authorities (56%) are currently reviewing their Local Plans. Further boosting coverage, a total of 26 new Local Plans were adopted in 2024, surpassing the five-year average of 21 plans per year. This pickup in activity has helped increase the proportion of local planning authorities (LPAs) with an up-to-date plan from 22% in May 2024 to 29% in April 2025.
Significant gaps remain, however: 42 LPAs (14% across England) both have out-of-date plans and have not made any progress towards adopting a new one. This remains a concerningly high proportion of out-of-date plans, but is at least an improvement on last year, when 54 LPAs were in this category. Furthermore, the number of LPAs that have not adopted a Local Plan since the NPPF was first introduced in 2012 continues to fall (if very slowly), from 52 in May 2024 to 40 this year.
Transitional arrangements
When the new NPPF was introduced in late December 2024, local authorities (LAs) could, under certain conditions, take advantage of a transition period which allowed them to progress emerging Local Plans under the previous framework. Faced with an average increase in housing targets of c.80% under the revised standard method, many LPAs had a significant incentive to accelerate the process.
By the time the 12th March deadline arrived, 47 LPAs had submitted plans for examination under the previous version of the NPPF, and a further 23 had published Regulation 19 plans, suggesting many authorities were indeed keen to take advantage of the arrangements.
Those publishing Regulation 19 plans would be allowed to progress their emerging plans if their emerging housing target was at least 80% of the new Standard Method requirement. Only 7 of the 21 authorities met this threshold, however, meaning that the remaining Regulation 19 plans will require further revision before submission for examination.
Of the 47 plans currently at examination, their housing targets are on average 34% lower than what is called for by the new standard method housing assessment. If adopted in their current form, these plans will have a combined annual shortfall of nearly 15,000 homes between what is being planned for and what the standard method housing assessment is for those LPAs. This assumes that all these plans are accepted in their current form; Savills previously estimated that around 15 plans were likely to pass examination and be adopted, but ultimately the number will depend on the decisions of Inspectors.
The Government required all LPAs to submit revised timeframes for adopting a new Local Plan in March 2024. Anecdotally, nearly all those LPAs, either due to undertake a review or with a review in progress, set ambitious timelines to adopt a plan by 2028 or 2029. This, in many cases, would mean a four-year plan production process, substantially quicker than the ten years that typically elapses between the adoption of successive plans. The consequences for resourcing and implications arising from local government reorganisation might well impact these timeframes.
Five-Year Land Supply
Stark consequences from the new Standard Method, as three in five LAs do not have a five-year land supply
Ensuring an adequate supply of land to meet the prescribed housing requirement is becoming increasingly challenging for LPAs. Savills analysis of published land supply positions shows that LPAs have identified 4.4 years’ worth of land for housing on average across England, a sharp fall from the 2024 average of 6.4 years (noting that the 2024 average was based on the previous NPPF and Standard Method).
Between May 2024 and May 2025, the proportion of LAs that lack a proven five-year land supply has increased from 33% to 61%. This includes LAs that have published a statement acknowledging less than five years of supply has been identified, those that have a land supply less than five years according to Savills calculations, and those that have recently lost at appeal on the basis of land supply.
The revised Standard Method has increased the majority of LPAs’ housing requirements by a significant amount, meaning many are now failing to demonstrate a land supply sufficient to meet this need over the next five years. On top of this, the 5% buffer, which was removed in 2023, has been reinstated, and the threshold at which the 20% buffer applies has been tightened after being relaxed in 2023. This has made it even harder for LAs to prove a five-year land supply.
Furthermore, the Government has reversed changes made in 2023 that altered land supply requirements. The first change meant that LPAs with an up-to-date Local Plan were exempt from proving a five-year land supply. Secondly, LPAs that had made sufficient progress towards adopting a new Local Plan would only have to prove four years’ worth of land supply, rather than five. While many of those who were exempt would have passed the five-year test under the old Standard Method, 18 LAs passed due to the four-year rule. Fourteen of these LAs have failed to demonstrate an updated, robust five-year land supply, contributing to the rise in the proportion of LPAs failing to prove a five-year land supply.
Presumption in favour of sustainable development
The presumption in favour of sustainable development is activated under three specific circumstances. These are: (i) where the LPA does not have an up-to-date Local Plan; (ii) where the LPA is unable to demonstrate a deliverable five-year supply of housing land; or (iii) where the LPA has failed the most recent Housing Delivery Test (HDT) by delivering less than 75% of its identified housing requirement over the preceding three-year period.
By combining information on five-year land supply, Local Plan status and the HDT for 2023, we have counted the number of measures by which the presumption in favour applies in each LPA. Of the 296 LPAs in England, only 17% have an up-to-date Local Plan, can demonstrate a five-year land supply, and have delivered more than 75% of their housing requirement and therefore do not activate the presumption in favour of sustainable development under any circumstances. Meanwhile, 27% have failed on one measure, 39% have failed on two measures, and 17% have failed on all three measures. Those failing all three measures are concentrated in the South East of England and London; 28% of LPAs in the South East failed all three measures, as did 27% of LPAs in London.
When we ran a similar analysis in our 2018 Planning Paper, only 5% of LPAs failed all three measures. However, since then, the threshold at which the presumption in favour kicks in has been increased significantly from 45% of the LPA’s housing requirement to 75% of their housing requirement. This partly explains the deterioration between 2019 and now as rules became stricter from 2020 onwards.
Looking ahead to the 2024 Housing Delivery Test
The Government reinstated the HDT as part of the December 2024 revisions to the planning system. LPAs that do not meet housing requirements will face an escalating series of sanctions imposed upon them when making planning decisions. The HDT is essentially backwards-looking: the most recent version covers the period up to March 2023. We have modelled what the 2024 test may look like (which will be applied from November 2025).
Overall, ending COVID allowances (which had reduced overall targets) will land more authorities with a sanction. 157 LPAs – up from 105 in 2023 – are projected to fail the Test, with 99 likely to face losing control of the planning decision-making via the application of the presumption in favour of sustainable development.
Summary: Planning enters a period of change as new rules take effect
- Despite high levels of activity ‘on the ground’, changes to planning policy will take time to be reflected in Local Plans and the number of consents flowing through the system.
- A balance must be struck between minimising disruption to plan adoption, and ensuring Local Plans meet new rules as closely and as quickly as possible.
- Higher housing need figures and return of the HDT will leave many LPAs exposed to planning appeals, with three in five unable to evidence an adequate land supply.
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