Guidance

Housing Delivery Test: 2020 measurement technical note

Published 19 January 2021

Applies to England

Introduction

This document sets out the process used to calculate the 2020 Housing Delivery Test measurement in line with the published Housing Delivery Test rulebook.

This document should be read alongside the Housing Delivery Test rulebook.

All terminology in this document mirrors that in the Housing Delivery Test rulebook.

The Housing Delivery Test measurement is published annually by the department. The Housing Delivery Test period covers the previous 3 financial years; in the case of the 2020 measurement, the years are 2017/18, 2018/19 and 2019/20.

The Housing Delivery Test compares the net homes delivered over 3 years to the homes required over the same period.

Housing Delivery Test (%) =
Total net homes delivered over 3 year period
divided by
Total number of homes required over 2 year 11 month period*

*For the 2020 measurement, there is a reduction in the period for measuring total homes required – usually this would be measured over a 3-year period but an 11-month period has been used for the 2019/20 monitoring year. This is to account for disruption to housing delivery and monitoring caused by restrictions announced on 23 March 2020, in response to the COVID-19 pandemic.

The calculation uses published statistics and data collected by the department from local planning authorities, National Parks and Development Corporations for this purpose.

Calculating the homes required

To calculate the total net homes required over the Housing Delivery Test period, the calculations draw on:

• Annual average household growth over a 10-year period. This is calculated for one of the test years by authority, based on household projections^{[footnote 1]}. The household projections used are the 2014-based projections for the 2017/18 test year.

• Local housing need. This is calculated in line with the Housing and economic needs assessment planning practice guidance. For the 2020 HDT, the test years 2018/19 and 2019/20 use local housing need instead of annual average household growth for the calculation of the housing requirement. In order to calculate the minimum annual housing need figure using the standard method, MHCLG use the following inputs:

  • The projected average annual household growth over a 10-year period based on 2014-based household projections for both 2018/19 and 2019/20 test years.
  • For the 2018/19 measurement year, adjustment for affordability using the 2017 affordability ratio (affordability ratio for the previous calendar year) published 26 April 2018. For the 2019/20 measurement year, adjustment for affordability using the 2018 affordability ratio published 28 March 2019.
  • An appropriate cap based on the local authority’s plan status at 1 April 2018 for 2018/19 measurement year and at 1 April 2019 for 2019/20 measurement year (where relevant).

• Local plan information^{[footnote 2]}; both the most recent local plan and the previous local plan. Only local plans which set out an authority’s housing requirement are used. Data collected include: the adoption date, start date, end date, housing requirement including trajectories, joint plan requirements, traveller site requirements, any unmet need which has been given to or taken from other authorities (agreed in a local plan), and whether the plan has been reviewed and the outcome of this review (see Plan Reviews).

• Current London Plan annual borough targets 2015-2025.

• Plan Reviews - for determining whether the requirement for a plan review^{[footnote 3]} deeming that policies do not require updating has been satisfied, for the purposes of Housing Delivery Test, the authority must have^{[footnote 4]}:

  • Published assessment of the strategic housing requirement policy (or policies) within 5 years of adoption of such policies; and
  • As part of the review concluded that such policies do not require updating.

• Once the requirement data has been identified, we also consider whether the authority are to be treated jointly (as part of a joint plan), or if the authority has recently re-organised to form a new local planning authority. Further details are provided below.

COVID-19 adjustment for the 2020 Housing Delivery Test measurement

To reflect the temporary disruption caused by the first national lockdown announced on 23 March 2020, the period for measuring the homes required in 2019/20 has been reduced by 1 month. As ‘homes required’ data (detailed above) can be calculated by the day, the 19/20 ‘homes required’ measurement period has been reduced by 31 days.

Given the wide-ranging status and characteristics of local plans across England, the exact process to calculate results varied. Below sets out the steps taken for all authorities and then goes through individual steps taken contingent on the plan status and characteristics which affect the application of the Housing Delivery Test.

For every local planning authority, the following steps were taken:

1. Annual average household growth over ten years is calculated based on the household projections available as at 1 April in 2017 (for 2017/18 year) and local housing need, using the standard method (as set out above) in 2018/19 and 2019/20 respectively.

2. In some cases, annual average household growth / local housing need may be negative for one or more of the years being tested. In these instances, all 3 years of the household growth including negative values are summed. If the 3-year summed result is a negative value, this is set to zero. If the sum of the 3 years of annual household growth is positive (despite one or more negative years), the figure is not changed.

3. Net unmet need is calculated for each authority by summing all the need taken (the authority becomes responsible for delivering this housing) and taking away all need given (the authority is no longer responsible for this housing).

4. To convert this into an annual figure, the number of years the plan covers is calculated by taking the difference between the start date of the plan and the end date of the plan, by classifying both the start date and end date as days the plan covers. The total net unmet need figure by authority is then divided by the total plan period.

5. The annual net unmet need for each authority is then added to the annual average household growth in 2017/18 and to local housing need in 2018/19 and 2019/20.

In addition to steps 1 to 5, for an authority without an ‘up to date’^{[footnote 5]} local plan the following steps were taken:

6. The housing requirement is based on the household growth / local housing need, plus unmet need figure, set out in an adopted plan, (as calculated in steps 1 to 5 above) for each year. Since there is no ‘up to date’ local plan, the ‘lower of’ policy does not change the total number of homes required. The exception to this is where the authority is covered by a Spatial Development Strategy (SDS), see ‘London boroughs’.

In addition to steps 1 to 5, for an authority with an ‘up to date’ local plan for the entire Housing Delivery Test period the following steps were taken:

7. The housing requirement is based on the annual target from the most recent plan for each year. If the local plan includes a stepped requirement then the annual target from the stepped requirement corresponding to the relevant period is used.

8. The number of homes required each year is based on the lower of the housing requirement in local plans or household growth / local housing need plus unmet need, this is carried out for each of the 3 years.

9. The final number of homes required sums each year’s lower figure to calculate the 3-year total number of homes required.

In addition to steps 1 to 5, for an authority with a plan which is partially ‘up to date’ during the Housing Delivery Test period the following steps were taken:

10. The housing requirement is based on the annual target from the most recent plan for each year. If the local plan includes a stepped requirement then the annual target from the requirement corresponding to the relevant period is used, and the steps below are applied in the same way.

11. If the plan becomes ‘out of date’ then from this point onwards the housing requirement is based on annual average household growth / local housing need plus unmet need depending on the test year.

12. If the plan becomes ‘out of date’ midway through a year, a weighted average for that year is calculated. This means that for as many days that the plan was ‘up to date’ within a test year, the annual target is used. For the remainder of the year, annual average household growth / local housing need plus unmet need is used.

13.The number of homes required each year over the 3-year period is based on the lower of the housing requirement or household growth / local housing need plus unmet need for each year.

14. In this instance, the housing requirement in a given test year could be:

a. The target from the plan (if the plan is ‘up to date’ for the full year)

b. A weighted average of the target from the plan and annual average household growth (for the test year 2017/18) or local housing need (for the test years 2018/19 and 2019/20) plus unmet need (if the plan is only ’up to date’ for part of the year)

c. Household growth plus unmet need for test years 2017/18 (if the plan is ‘out of date’ for the full year); or

d. Local housing need plus unmet need, for test year 2018/19 and 2019/20 (if the plan is ‘out of date’ for the full year)

15. For each individual year that the annual target is greater than annual average household growth plus unmet need or in the case of 2018/19 and 2019/20 the local housing need plus unmet need, the lower figure is used.

16. The final number of homes required sums each year’s lower figure to calculate the 3-year total number of homes required.

17. As above, if an authority adopts a plan which covers the latter part of the Housing Delivery Test period then prior to the period the plan covers, annual average household growth / local housing need plus unmet need is used. From the point following the plan start date, the housing target from this is used (using the relevant stepped requirement where appropriate). The ‘lower of’ policy is applied in the same way, comparing the housing requirement in each year to either annual average household growth plus net unmet need or in the case of 2018/19 and 2019/20 local housing need plus net unmet need.

In addition to steps 1 to 5, for an authority with a previous plan which was ‘up to date’ for part of the Housing Delivery Test period and whose current plan was ‘up to date’ for part of the Housing Delivery Test period the following steps were taken:

18. If the previous plan is ‘up to date’ for part of the Housing Delivery Test period, but the current plan start date encompasses the Housing Delivery Test period that the previous plan covered, the most recent plan is used and the previous plan is not.

19. If the previous plan is ‘up to date’ for part of the Housing Delivery Test period and this period does not overlap with the current plan, then the previous plan is used for as long as it is valid. After this period the most recent plan is used.

20. If there is a period where there is no plan, then annual average household growth / local housing need plus net unmet need is used for this period.

21. Where the periods above do not align with a test year, a weighted average for that year is calculated. This means that for as many days that the previous plan was ‘up to date’ within a test year, the annual target from that plan is used. For the remainder of the year, either the current plan or annual average household growth / local housing need plus unmet need (depending on the status of the current plan) is used.

22. The ‘lower of’ policy for each year is applied based on the housing requirement and annual average household growth / local housing need plus net unmet need. The final number of homes required sums each year’s lower figure to calculate the 3-year total number of homes required.

In addition to steps 1 to 5, for a London borough including Development Corporations with full plan making and decision-making powers^{[footnote 6]} the following steps were taken:

23. London boroughs are treated the same as other authorities except where there is no ‘up to date’ plan the most recent adopted London Plan annual target^{[footnote 7]} is deferred to. In the instance where the London Plan becomes over 5 years old, household growth / local housing need would be used as the basis of requirement. If a London borough has a previous plan that was ‘up to date’ for part of the Housing Delivery Test period, then this plan is used for the period it applies for.

24. If the borough plan becomes ‘out of date’ midway through the year, a weighted average for that year is calculated. This means that for as many days that the plan was ‘up to date’ within a test year, the annual target is used. For the remainder of the year, the annual borough target from the London Plan is used.

25. Similar to step 24, if the borough plan and London Plan both become ‘out of date’ part way through the year, the requirement for the remainder of the year is either housing growth / local housing need plus unmet.

26. If the borough plan includes a stepped requirement then the annual target from the requirement corresponding to the relevant period is used, and the steps above are applied in the same way.

27. The number of homes required each year over the 3-year period is based on the lower of the housing requirement or housing growth / local housing need plus unmet need in each year.

28. In this instance, the housing requirement in a given test year could be one of the following:

a. The target from the borough plan (if the plan is ‘up to date’ for the full year)

b. Annual borough target from the ‘up to date’ London Plan (if the borough plan is not ‘up to date’ for the full year)

c. A weighted average of the target from the borough plan and annual borough target from the London Plan (if the plan is only ‘up to date’ for part of the year)

d. A weighted average of the target from the previous boroughs plan and the weighted average from the current borough plan (if the previous plan is ‘up to date’ for part of the period, and the current borough plan follows directly from this)

e. A weighted average of the target from the previous borough plan and the annual borough target from the current London Plan (if the previous plan is ‘up to date’ for part of the year and there is no current borough plan to cover the rest of the test year period); or

f. A weighted average of the target from the previous borough plan, the borough target from the current London Plan and the target from the current borough plan (if the previous plan is ‘up to date’ for part of the period, and the current borough plan follows indirectly from this meaning the London Plan is relied on in the interim period)

g. A weighted average of the target from the previous borough plan, the current borough plan, the borough target from the current London Plan and then either housing growth or local housing need; if the previous borough plan, current borough plan and London Plan are all ‘out of date’ for part of the period, then housing growth or local housing need is relied on to cover the rest of the test period

29. The final number of homes required is the sum of each year’s lower figure to calculate the 3-year total number of homes required.

30. The London Legacy Development Corporation’s housing requirement is based on their local plan or London Plan target in the same way as other London boroughs. Given there is no separately published annual average household growth or local housing need, the ‘lower of’ policy is not applied. Therefore, the target from their local plan is their final number of homes required.

In addition to steps 1 to 5, for authorities covered by a joint plan with a joint requirement the steps below were taken:

31. Where authorities have an ‘up to date’ joint plan and are being measured jointly for the purpose of the Housing Delivery Test the housing requirement set out in the joint plan is used.

32. If the joint plan becomes ‘out of date’ during the test period then a weighted average for the year is calculated; using the joint plan target up to this point and from then onwards the total household growth plus net unmet need across all of the component local authorities is used.

33. In test years 2018/19 and 2019/20, the local housing need figure for joint plan authorities plus net unmet need is used rather than household growth plus net unmet need.

34. For each individual year that the joint annual housing requirement is greater than the joint annual average household growth / local housing need plus unmet need, the lower figure is used.

35. The final number of homes required sums each year’s lower figure to calculate the 3-year total number of homes required.

In addition to steps 1 to 5, for authorities that have recently reorganised to form new unitary or single-tier authorities, the steps below were taken:

35. Local authorities who formed new authorities (unitary or new lower-tier authorities) have their Housing Delivery Test published on the former authorities basis for the first year following reorganisation; for example Buckinghamshire who formed in April 2020 have their results published at the former/legacy (predecessor) local planning authorities. Every result after this (the second year following reorganisation onwards) is published at the new (reorganised) authority boundary. This year’s Housing Delivery Test will be the second set of results published for those authorities who reorganised on 1 April 2019, and therefore are published at the reorganised authority level.

36. In order to calculate the ‘homes required’ for these areas, steps 1 to 5 (and as appropriate steps 6 to 34) were carried out based on the predecessor authority boundaries. The homes required for the predecessor areas was then added together to produce a ‘homes required’ for the whole of the reorganised authority. Following reorganisation national statistics are published at the new authority level, however affordability ratios at predecessor authority levels were published by the ONS; these were used to calculate Local Housing Need for the test year 2019/20 (as of 1 April 2019).

37. The exceptions to the approach set out in paragraph 35, are the unitary authorities of Dorset, and Bournemouth, Christchurch & Poole, who have had their Housing Delivery Test published at their predecessor authority boundaries. This is because the predecessor authorities of East Dorset and Christchurch have a joint plan with joint plan requirement (adopted in April 2014), straddling the two new unitary areas, this requirement cannot be disaggregated and therefore requirements cannot be attributed to the new authorities. This means that the summing of the predecessor authority requirements set out in step 36 has not been applied for these authorities.

The housing requirement for travellers:

In addition to steps 1 to 5 and the relevant process depending on local plan status, where applicable the requirement for traveller accommodation^{[footnote 8]} is added to the housing requirement.

This addition takes place prior to the application of the “lower of” policy which compares the housing requirement (containing the travellers housing requirement) and the annual average household growth / local housing need plus net unmet need, choosing the lower for each year as the number of homes required for that test year.

The travellers housing requirement is calculated through the steps below:

38. The traveller accommodation requirement is based on the traveller’s annual target from the most recent plan for each year. If the local plan contains no traveller’s requirement then no adjustment is made.

39. Where there is a traveller’s requirement, and the plan becomes no longer ‘up to date’ then from this point onwards the traveller’s adjustment is no longer made.

40. If the plan is no longer ‘up to date’ midway through a year, then for as many days that the plan was ‘up to date’ within a test year, the travellers annual target is used (apportioned based on how many days this was ‘up to date’). For the remainder of the year, no travellers housing requirement is added.

41. If the local plan includes a stepped requirement for the traveller’s requirement, then the annual target from the requirement corresponding to the relevant period is used, and the steps above are applied in the same way

Reducing the requirement for test year 2019/2020

42. In line with the decision to reduce the requirement for the test year 2019/2020 as a result of COVID-19 lockdown in March 2020, all housing requirements that utilise current local or borough plans, the London plan and/or previous plans are only measured up until the 1 March 2020.The remaining month is discounted from the housing requirement for this test year.

43. Housing requirements that utilises local housing need plus unmet need are weighted to account for 11 months of 2019/2020.

44. Where the requirement for the test year 2019/20 is a combination of any number of local plans, borough plans, previous plan and local housing need plus unmet need, the appropriate weighting is applied as per the time of the test year each requirement represents.

Calculating the homes delivered

To calculate the total net homes delivered over the 3-year period the calculations draw on:

• Net additional dwellings^{[footnote 9]} by local authority district, England 2001-02 to 2019/20^{[footnote 10]}.

• Housing supply; communal accommodation, component flows of by local authority district, England 2017/18, 2018/19 and 2019/20 (published as part of the Housing supply; net additional dwellings, England release^{[footnote 11]}).

• Number of students in student only households by the number of bedrooms where all students are aged 18 and over, Office for National Statistics based on 2011 census^{[footnote 12]}.

• Age of Household Reference Person by number of adults in household where all household reference persons are aged 16 and over, Office for National Statistics based on 2011 census^{[footnote 13]}.

• Data supplied to the department by local planning authorities and National Parks about the number of homes within a local planning authority boundary that were delivered in a National Park, 2017/18, 2018/19 and 2019/20; and

• Data supplied to the department by the Greater London Authority about housing completions in the London Legacy Development Corporation that was within different local authority boundaries, Residential Completions between 01/04/2019 and 31/03/2020 by planning authority from London Development Database.

To calculate the homes delivered, the steps taken were:

1. For each local planning authority, net additional dwellings for the test years are used as the starting point. These are then adjusted in a number of ways.

2. For each authority, there is an estimate of the number of net dwellings that would be freed up from the net additional student and other communal accommodation built over the 3-year period. This is calculated by dividing each authority’s student bedrooms annual net change by the national ratio (2.5) and each authority’s other communal bedrooms annual net change by the national ratio (1.8).

3. Adjust the net additional dwellings for each authority by the annual estimate of the number of dwellings which would be required in the absence of the net communal accommodation bedrooms change. For the local planning authorities whose local authority boundaries overlap with a National Park^{[footnote 14]}, either:

a. Remove the net additional homes delivered in the National Park^{[footnote 15]} each year from the net additional dwellings statistics, where the local plan contains a district-specific housing requirement which excludes the National Park area; or

b. If tested against household growth / local housing need (when the plan is ‘out of date’ or by virtue of the ‘lower of’ policy), or their local plan has a joint housing requirement with the National Park, do not apply any adjustment to the net additional dwellings statistic for the local authority.

4. For those authorities who have a Joint plan, with a joint requirement and have chosen to have their Housing Delivery Test calculated jointly, in addition to Steps 1 to 4 above the ‘homes delivered’ (for the individual local authorities) was summed to provide a delivery total for the whole joint plan area.

5. For the local planning authorities whose boundaries overlap with the London Legacy Development Corporation, for the periods that the local planning authority’s delivery is based on the London Plan, the net homes delivered in the London Legacy Development Corporation are removed from the net additional dwellings statistics based on the data provided to the department by the Greater London Authority.

6. For those authorities who reorganised in April 2019 steps 1 to 3 (and step 4 if appropriate) were followed:

a. in years 1 and 2 of the measurement net additional dwellings statistics were published at the predecessor authority boundaries, so these were summed to give delivery for the newly formed authority in these years; and

b. in year 3 the net additional dwellings statistics for the new unitary or single-tier authority was used - this was published at the new authority level.

7. For Dorset, and Bournemouth, Christchurch & Poole, the homes delivered was also published at the predecessor authority level (see homes required paragraphs 35 to 37) meaning:

a. For years 1 and 2, steps 1 to 3 above were followed, with net additional dwellings not being summed (maintained at former authority levels);

b. For year 3, a separate data collection was provided by the local authorities to MHCLG, which disaggregated the net additional dwellings statistic (published at the unitary boundaries) for the 2019/20 year; and

c. For any joint plans with joint housing requirements at the predecessor authority levels (for example East Dorset and Christchurch; and West Dorset and Weymouth & Portland) Step 5 was followed i.e. the delivery from the individual predecessor authorities was summed for those joint plan areas.

8. Borough plans which pre-date the formation of the London Legacy Development Corporation do not give a requirement broken down into dwellings in the borough and dwellings in the London Legacy Development Corporation; however the London Plan does give separate plan numbers. This means where the borough’s requirement is based on the London Plan this will not include the homes to be delivered in the London Legacy Development Corporation. However, when the requirement is based on their own plan it will include these homes. Therefore, for the adjustment to net additional dwellings, removing those homes delivered in the London Legacy Development Corporation should only be applied for the period where the requirement is based on the London Plan. For these periods, neither the housing requirement nor the net additional dwellings include the homes in the London Legacy Development Corporation.

9. If the borough’s requirement is based on different sources within a test year (for example, the borough plan and then the borough target from the London Plan) then the removal of net additional dwellings each year is scaled to the proportion of the year that the London Plan is relied upon for the housing requirement.

10. The final measure of the homes delivered is the sum of the annual net additional dwellings adjusted for National Park and Development Corporation delivery and the estimated net change in the dwelling stock due to the change in communal accommodation bedrooms.

Calculating the results

The final result for each authority is based on their number of homes required over the 3-year period and the adjusted net additional homes delivered over the same period.

In all cases, the requirement for the number of homes is based on the lower of their annual housing requirement (based on the local plan status and characteristics) and annual average household growth adjusted for net unmet need or the local housing need adjusted for net unmet need (for tests years 2018/19 and onwards). The lower figure in all years are summed to calculate the number of homes required over the total 3-year period for the purpose of the Housing Delivery Test.

However, for the 2020 Housing Delivery Test, to reflect the temporary disruption caused by the first national lockdown which was announced on 23 March 2020, the period for measuring the homes required in 2019/20 has been reduced by 1 month. As ‘homes required’ data (detailed above) can be calculated by the day, the 19/20 ‘homes required’ measurement period has been reduced by 31 days. As a result, the reduced requirement means that each authority’s requirement will be calculated from 01/04/17 to 01/03/20, totalling 35 months, in contrast with the 36 month requirement used to calculate the 2019 Housing Delivery Test.

The annual net additional dwellings statistic adjusted for National Park and Development Corporation delivery, and the change in communal accommodation bedrooms are summed to calculate the total number of homes delivered over the 3 years for the purpose of the Housing Delivery Test.

Comparing these two totals gives the individual Housing Delivery test for a given authority, joint plan, merged authority or development corporation:

Housing Delivery Test (%) =
Total net homes delivered over 3 year period
divided by
Total number of homes required over 2 year 11 month period

In cases where the total number of homes required is zero (or less), the Housing Delivery Test result is undefined, and no consequences apply.

1. Household projections as available at the 1 April of the corresponding test year, for example in 2019/20 year this will be 1 April 2019. Annual average household growth is calculated by calculating the total household growth between the test year and 10 years in the future, then dividing by 10. For the test year 2017/18 the 2014 household projections are used. The total household growth over this period is calculated by taking the difference between the number of households in 2017 and 2027. This is converted into an annual average by dividing this total change by 10. ↩

2. The department collected local plan information from authorities using DELTA webform. In some instances, the information as submitted was adapted for the Housing Delivery Test 2020 measurement and decisions about what information to use were decided on a case by case basis. For example, where plans were adopted following the submission of data from local authorities, information has been sourced from the published plans. ↩

3. Regulation 10A of The Town and Country Planning (Local Planning)(England) Regulations 2012 (as amended) requires local planning authorities to make an assessment of whether their local plan remains up to date at least every 5 years from adoption. ↩

4. Please note: any conclusion reached on a plan review relates solely to whether a review has been carried out, so that MHCLG can calculate the Housing Delivery Test, (as set out in paragraph 12 and footnote 8 of the Housing Delivery Test rule book). Any such conclusion does not indicate that the Secretary of State for Housing, Communities and Local Government endorses or makes any other judgement on status of a particular plan, or review for decision or plan making purposes. ↩

5. An ‘up to date plan’ for the purposes of the Housing Delivery Test is a plan with an adopted housing requirement which is less than 5 years old, or is older than 5 years old and has been reviewed and found not to require updating. An ‘out of date’ plan for the purpose of the Housing Delivery Test, is a plan with an adopted housing requirement which is 5 years old or older and: has not been reviewed or a review has been carried out after the 5 year deadline or a plan review has found that the strategic housing policies require updating. ↩

6. There is no 2020 Housing Delivery Test result for Old Oak and Park Royal Development Corporations as they have been recently created and do not have published targets against which to be measured. ↩

7. The London Plan figure remains valid for 5 years from the date of adoption, even where the plan is undergoing a revision. ↩

8. Meeting the definition in Planning Policy for Traveller Sites (August 2015). ↩

9. As defined in the Housing Flow Reconciliation guidance. Net additions measure the absolute increase in stock between one year and the next, including other losses and gains (such as conversions, changes of use and demolitions). ↩

10. Net additional dwellings live table 122. ↩

11. Housing supply: net additional dwellings - communal accommodation (bedspaces) 2017-18, 2018-19, 2019-20 live table 124. ↩

12. Used to calculate the national average number of adult students living in a student only household where all students are aged 18 and over (2.5). This table, specifically commissioned for this purpose, is published by the ONS. ↩

13. Used to calculate the national average number of adults living in a household where all Household Reference Persons are aged 16 and over (1.8). This table, specifically commissioned for this purpose, is published by the ONS. ↩

14. Household growth and local housing need are set at local authority level, containing the district local planning authority and part of National Park planning authority. ↩

15. As provided to the department by local planning authorities and National Parks. ↩