Checking the housing land supply position of an authority
A stated five year supply usually rests on two or three large sites. Here is where the figures are published, how to test the site list against the deliverability definition, and how the position changes a decision.
An authority's housing land supply position decides how much weight its own policies carry, so it is the first thing to check before promoting a site that conflicts with them. Two published figures matter: the council's current five year housing land supply statement, and its Housing Delivery Test measurement, which is published annually by government. Find both, note their base dates, and read the supply statement site by site rather than taking the headline number.
The headline is where the argument starts, not where it ends. A stated supply of 5.2 years often contains two or three large sites doing heavy lifting on assumptions that will not survive scrutiny.
Where the figures are published
The five year supply statement is a council document, usually published annually with a base date of 31 March or 1 April. Look for it under planning policy, monitoring, or the local plan evidence base, with titles such as five year housing land supply statement, housing land availability assessment or housing trajectory update.
The Authority Monitoring Report is the other council source. It is often more candid than the supply statement, because it reports completions, permissions and losses without having to reach a conclusion about adequacy.
The Housing Delivery Test measurement is published centrally, as a single spreadsheet covering every authority in England, and it is the figure an inspector will use. Note the measurement year, because the published result lags the period it measures.
Two habits save time later. Download the PDF and the spreadsheet rather than reading them in a browser, since councils replace files at the same URL without changing the link. And record the base date and version of everything you download, in the same way you would with version control when downloading the statutory biodiversity metric, because a supply argument built on last year's statement collapses at the first hearing.
Reading a five year supply statement critically
The statement is built from a list of sites, each with an assumed number of completions in each of the five years. The disputes are almost always about that list.
Work through it against the definition of a deliverable site in the Framework's glossary, and treat these categories differently.
| Site category | What to test |
|---|---|
| Full permission, small site | Usually accepted as deliverable without further evidence |
| Outline permission or allocation | Needs clear evidence that completions will begin within five years |
| Large sites with full permission | Lead-in times, phasing and annual build rate assumptions |
| Sites subject to a resolution to grant | Whether the section 106 is agreed and how long it has been outstanding |
| Windfall allowance | Whether it is justified by compelling evidence of past delivery |
| Communal accommodation | Whether student or older persons schemes are converted to dwelling equivalents transparently |
Then look at the arithmetic around shortfall. Where past under-delivery is being made up across the whole plan period rather than within the next five years, the supply position looks stronger than a five year catch-up would allow, and which approach the authority has taken should be stated plainly in the document.
Annual build rates on strategic sites are where most of the exaggeration sits. A single outlet delivering a high number of completions a year, on a site with one access under construction, is the assumption to challenge first.
The Housing Delivery Test and what each threshold does
The test compares homes delivered over three years with the homes required over the same period. The consequences step up as the result falls, and the current thresholds and consequences are set out in the Framework itself.
The long-standing structure has three steps. Below 95 per cent, the authority publishes an action plan. Below 85 per cent, a larger buffer is added to the five year supply requirement. Below 75 per cent, the presumption in favour of sustainable development applies to decisions on housing applications.
State the edition of the Framework whenever you cite this. The Framework was renumbered in December 2024 and reissued on 17 August 2026 with policy-coded chapters in place of paragraph numbers, so a reference copied from an older appeal decision will not match the document an officer is reading. Quote the policy reference from the edition in front of you and say which edition that is.
How the position changes a decision
Where the presumption applies, the authority's development plan policies most important for determining the application are treated as out of date, and permission should be granted unless the adverse effects would demonstrably outweigh the benefits, or unless specific policies indicate development should be restricted.
That last exception does a lot of work, and it is where most schemes in this position fail. Green Belt, designated heritage assets, National Landscapes, flood risk in the wrong zone and protected habitats all sit within it, so a shortfall in supply does not open up a constrained site.
What a shortfall does reliably do is shift the weight given to the housing benefit. A scheme refused on landscape character grounds in an authority with a healthy supply may be granted in the same authority two years later on the same drawings, and the difference is the trajectory rather than the design. A Planning Statement that sets out the supply position, with the source documents and their base dates, is doing something the officer cannot easily dismiss.
Illustrative example: an authority publishes a 5.1 year supply. Removing one strategic site of 400 homes, where reserved matters have not been submitted and the spine road is unbuilt, takes the figure below five years. That single site is the case, and the evidence needed is its planning history and a realistic lead-in, not a general argument about optimism.
Challenging an authority's figures
Challenges succeed on specifics. Take the supply list, pick the five or six sites carrying the most completions, and build a short evidence file on each: planning history, current status, outstanding conditions or agreements, site visit photographs with dates, and any public statement by the landowner or housebuilder.
Where you can get it, written confirmation from the site's promoter about expected start and delivery rates is the strongest material available. Housebuilders are sometimes willing to provide it, particularly where their own scheme elsewhere in the authority benefits.
At appeal, expect the authority to produce an updated position and expect the base date to have moved. Agree a statement of common ground on the sites that are not in dispute, so the inquiry time goes on the ones that are. Supply arguments that range across forty sites rarely persuade; arguments about four sometimes do.
The evidence to assemble before you rely on the position
- The current five year supply statement, with its base date and the published version noted
- The Authority Monitoring Report for the same year
- The Housing Delivery Test measurement, with the measurement period stated
- The housing trajectory from the adopted plan, for comparison against actual delivery
- A site-by-site file on the disputed sites, with dated evidence
- Recent appeal decisions in the same authority where supply was considered, with the base dates those decisions used
Point six is the most useful and the most often skipped. An inspector who found the supply to be 4.6 years eighteen months ago has already done part of your work, provided you are honest about what has changed since. Do not present an old decision as binding, because it is not, and inspectors are quick to say so.
Keeping the position under review
Supply positions move annually and sometimes mid-year, when a plan is adopted, an appeal is decided or a large site gains permission. Diarise the authority's usual publication month and check for a new statement before any hearing or committee date.
The same discipline applies to a scheme in the pipeline. A site promoted on a supply shortfall can find the shortfall closed by the time it reaches committee, and an application that rests entirely on that argument has no fallback. Our companion note on finding housing land supply and delivery test figures covers where each document lives and how often it changes.
This is general guidance, not legal advice; check the current Framework text and the authority's published position, or take advice from a qualified professional, before relying on any of it.
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Frequently asked questions
Where do I find an authority's five year housing land supply statement?
On the council's own site under planning policy, monitoring or the local plan evidence base, usually published annually with a base date of 31 March or 1 April. The Authority Monitoring Report for the same year is worth reading alongside it, because it reports completions, permissions and losses without having to reach a conclusion.
Who publishes the Housing Delivery Test result?
Government publishes the measurement centrally as a single dataset covering every authority in England, and that is the figure an inspector will use. Check the measurement period, because the published result covers a three year window that ends before publication, so the most recent year of delivery is not in it.
Which sites in a supply statement are worth challenging?
Large sites relying on optimistic annual build rates, sites with outline permission only, allocations without permission, and sites subject to a resolution to grant where the section 106 has been outstanding for a long time. Take the five or six carrying the most completions and build a dated evidence file on each.
Does a supply shortfall mean permission should be granted?
Not by itself. Where the presumption applies, the most important policies are treated as out of date and permission should follow unless adverse effects demonstrably outweigh the benefits, or specific policies restrict development. Green Belt, heritage, flood risk and protected habitats all sit within that exception.
Can I rely on an earlier appeal decision about supply?
Only as an indication of how an inspector approached the evidence, never as binding precedent. Base dates move, sites gain permission and plans get adopted. Cite the decision, state the base date it used, and be explicit about what has changed since, because inspectors test that quickly.
Why does the edition of the Framework matter here?
Because the numbering has changed. The Framework was renumbered in December 2024 and reissued on 17 August 2026 with policy-coded chapters in place of paragraph numbers. A reference copied from an older decision or template will not match the document the case officer is reading, which undermines the rest of the submission.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.