• Issue 50

  • Sep 2019

The Source

Only 3 out of 9 LPAs submit their Annual Position Statements on housing land supply in time

The Planning Inspectorate (PINs) published guidance on 20th August listing which Local Planning Authorities (LPAs) had submitted Annual Position Statements (APS) on time this year.  A month or so previously, the process was set down in more detail in the Planning Practice Guidance (PPG) under the section ‘Housing Supply and Delivery’, headed Confirming 5 year housing land supply.  This reinforced Paragraph 74 of the 2018 National Planning Policy Framework (NPPF), allowing LPAs to obtain ongoing confirmation that they can achieve a five-year housing land supply.

The process consists of four main stages:

  • An authority must register interest in having its 5-year supply position confirmed for the year by 1st This year 9 authorities registered their interest to PINs: Boston, Durham, Fylde, Mid Sussex, North Devon, North Somerset, Sefton, Torridge and Wyre.
  • Between registering interest and submitting the statement the LPA should engage with stakeholders including developers, promoters, land owners, infrastructure providers, neighbouring authorities.
  • The statement must be submitted to the Planning Inspectorate by the 31st July of the same year. Only 3 authorities have done so this year: Fylde, Mid Sussex and Wyre.
  • The Planning Inspectorate will then assess the APS and issue their recommendation in October of the same year. Assuming the Planning Inspectorate agree, and the LPA agree with any recommendations from the Inspectorate the LPA can then confirm their land supply until October the following year.


The guidance states that once the APS is received, the Planning Inspector’s assessment will be made on the basis of the material provided by the authority and the Inspector may not refer back to the LPA or other stakeholders to seek further information or to discuss particular sites. It is therefore important that the authority has carried out a robust stakeholder engagement process and that adequate information is provided about disputed sites.

Authorities need to engage with stakeholders who have an impact on the delivery of sites. The aim is to provide robust challenge and ultimately seek as much agreement as possible, so that the authority can reach a reasoned conclusion on the potential deliverability of sites which may contribute to the 5-year housing land supply. Those authorities who are seeking to confirm a 5-year housing land supply through an annual position statement can also submit their engagement statement to the Planning Inspectorate.