Council housing land supply positions and where to find them

A council housing land supply position is published in at least three places, and the three rarely agree. The authority's own five year housing land supply statement gives its case. The Authority Monitoring Report gives the completions data behind it. And the most recent appeal decision on a site in the area gives an inspector's view of whether the case stands up.

For anyone promoting a site, the third of those is usually worth more than the first two, because it tells you which parts of the authority's trajectory have already failed under cross-examination.

What a land supply position statement contains

A five year housing land supply statement sets out the housing requirement, the supply of deliverable sites, any shortfall or surplus carried forward, the buffer applied, and the resulting supply expressed in years.

The components to read closely are these. The base date, which is usually 1 April and determines which completions and which permissions count. The requirement figure, which is either the adopted local plan figure or the standard method figure depending on the age of the plan. The site schedule, which lists every site contributing to the five year supply with its capacity and its assumed delivery by year. And the assumptions: lapse rates, windfall allowances, and the lead-in times and build-out rates applied to large sites.

The site schedule is the document that matters. Everything else is arithmetic performed on it.

Where the figures are published

Seven sources, in roughly the order they are worth checking.

1. The five year housing land supply statement or housing land supply position paper, published annually on the authority's planning policy pages.
2. The Authority Monitoring Report. Authorities must publish monitoring information at least annually under the Town and Country Planning (Local Planning) (England) Regulations 2012, and the report carries completions by year, permissions granted and progress against the plan's trajectory.
3. The national Housing Delivery Test measurement, published by the department, which gives the three-year delivery percentage and the consequence attached to it.
4. The strategic housing land availability assessment, or housing and economic land availability assessment, which shows every site the authority has considered and its judgement on each. Useful for understanding why your site was discounted.
5. The brownfield land register, published annually in two parts, which identifies sites the authority considers suitable for residential development.
6. Appeal decisions. The Planning Inspectorate's casework records are searchable, and a decision that examined the supply position in the last eighteen months is the most reliable account of it available.
7. For a plan under examination, the examination library, where the authority's supply evidence and the objections to it sit side by side.

Add planning.data.gov.uk for brownfield registers and site allocations where the authority has published them in the national format.

The Housing Delivery Test and its consequences

The test compares homes delivered over the previous three years against homes required over the same period and expresses the result as a percentage. Three thresholds attach consequences.

Below 95 per cent, the authority must publish an action plan setting out the causes of under-delivery and the measures it will take.

Below 85 per cent, a 20 per cent buffer is applied to the five year supply calculation, which has the effect of requiring 5.6 years of supply rather than five.

Below 75 per cent, the presumption in favour of sustainable development applies to decisions on housing applications.

That last consequence is the one with teeth, and it operates regardless of whether the authority can otherwise demonstrate a five year supply. An authority with an adopted plan, a healthy trajectory and a delivery test result of 71 per cent is in the presumption.

How a shortfall changes decision making

The presumption in favour of sustainable development, long familiar by its paragraph 11(d) numbering in earlier editions of the Framework, directs that where the policies most important for determining the application are out of date, permission should be granted unless adverse impacts would significantly and demonstrably outweigh the benefits. An inability to demonstrate the required supply is one route to that conclusion.

The current Framework was published on 17 August 2026 and is organised by policy codes rather than paragraph numbers, so verify the code, the buffer and the current wording against the published document rather than carrying forward a citation from an earlier scheme. Local plan policies restricting housing in particular locations are the ones most often found out of date.

What the presumption does not do is guarantee permission. Green Belt, heritage harm, flood risk in the wrong zone and highway safety can each outweigh the benefit of housing even in an authority with a two-year supply. The practical consequence is a change in the weight given to a conflict with the spatial strategy rather than a change in the planning balance on technical matters. The note on housing land supply and what it changes for applicants works through that distinction.

Challenging the authority's figures

Five lines of attack recur, and the site schedule is where all of them land.

Deliverability. The Framework defines deliverable, and sites without permission, or sites with outline permission only, need clear evidence that completions will begin within five years. A large allocation with no promoter, no access agreement and no reserved matters application is routinely removed from the supply on appeal.

Trajectory on large sites. An authority that assumes a single outlet delivering 100 homes a year on a site with one access and one housebuilder is assuming something the market does not do. Lead-in times from permission to first completion, and build-out rates per sales outlet, are the figures to test.

Windfall allowances. The Framework requires compelling evidence from historic delivery, and a windfall allowance that includes the same small sites already counted individually is double counting.

Treatment of the shortfall. Where a shortfall has accrued, making it up within the next five years, commonly called the Sedgefield approach, produces a lower supply figure than spreading it across the remaining plan period. Inspectors have generally preferred the former.

Non-housing counted as housing. Student accommodation, extra care and C2 accommodation can count towards supply, with a conversion ratio, and the ratio used is frequently generous.

Evidence used in appeals

A supply case at appeal is built on the schedule, site by site, with a short statement for each disputed site explaining why it should come out. Supporting that with land ownership searches, the absence of a reserved matters application, correspondence with the promoter, and the authority's own committee reports is what moves an inspector.

Be proportionate. Removing enough sites to take the supply below the requirement is the objective, not removing every site you disagree with. A case that disputes 40 sites and succeeds on four looks weaker than one that disputes six and succeeds on all of them.

And check whether a neighbourhood plan covers the site, because a made neighbourhood plan can affect how the presumption operates in a shortfall area, as the note on checking whether a neighbourhood plan covers your site explains.

Timing an application against the position

The supply position is assessed at the date of the decision, not the date of the application. A position that is weak when you submit can be repaired by a monitoring report published during determination, and a strong position can collapse if a major allocation stalls.

Three practical consequences follow.

Submit when the evidence is at its weakest rather than when your drawings are at their best, if the supply argument is central to the case. Keep the supply section of the Planning Statement as a standalone chapter that can be updated without rewriting the document. And where the authority is close to adopting a new plan, the window before adoption is usually the one that matters, because adoption resets the requirement and often restores the supply.

Where the scheme is of a scale that engages affordable housing policy, the supply argument and the viability argument interact, and an Affordable Housing Statement that offers full policy compliance strengthens a case made on a shortfall considerably.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. To see which documents a housing application is likely to need, enter your postcode on PlanScope. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.