Revealed: 189 Councils failing to meet five-year housing land supply (5YHLS)

As the housing crisis worsens across England, Labour’s recent planning reforms have reintroduced mandatory housing targets, placing renewed pressure on local planning authorities (LPAs). 

These reforms, marking a significant departure from the advisory targets scrapped in 2023, compel LPAs to ensure adequate land availability through the demonstration of a five-year housing land supply (5YHLS) – a crucial requirement for meeting local housing demands.

The reforms also mandate councils to review their Green Belt boundaries, with plans to release less desirable areas, referred to as ‘grey belt’ land, for housing development.

This article presents a detailed overview of the councils currently falling short of their 5YHLS targets, highlighting the challenges they will face in meeting Labour’s planning reforms and ambitious target of building 1.5 million homes.

We'll explain what a 5YHLS means, show which councils don't have enough housing land, and explore two planning options this creates.

You'll discover how savvy developers are leveraging these shortages, both as compelling evidence for the very special circumstances test in Green Belt applications and as the essential gateway criterion for the new grey gelt policy that's revolutionising how underperforming Green Belt land can be thoughtfully released.

Let’s begin.

A five-year housing land supply (5YHLS) represents the amount of land identified by councils as being available and suitable for residential development over the next five years. To meet the 5YHLS requirement, councils must identify deliverable sites that can accommodate housing development to match their assessed local housing needs.

Here’s the important part: If an LPA cannot demonstrate a sufficient land supply for five years, it is considered to have failed its 5YHLS obligation. This can lead to significant consequences for the council, including the application of the ‘presumption in favour of sustainable development’. 

But that’s not all. 

In such cases, developers often seize the opportunity to argue that housing needs should take precedence over local policies. This makes it easier for them to secure planning permission, even in protected areas like the Green Belt. 

Want to know more? 

After we cover the list of councils failing to meet their five-year supply targets, we’ll take a closer look at these implications and their impact on housing developments.

The authorities currently unable to demonstrate five-year supply targets, listed in alphabetical order, are:

1. Allerdale

2. Amber Valley

3. Arun

4. Ashfield

5. Ashford

6. Barrow‑in‑Furness

7. Basildon

8. Basingstoke

9. Basingstoke and Deane

10. Birmingham

11. Blaby

12. Blackburn with Darwen

13. Bolton

14. Bournemouth, Christchurch and Poole

15. Bracknell Forest

16. Bradford

17. Braintree

18. Brentwood

19. Brighton & Hove

20. Bristol

21. Bromsgrove

22. Broxbourne

23. Broxtowe

24. Buckinghamshire

25. Burnley

26. Calderdale

27. Camden

28. Cannock Chase

29. Castle Point

30. Charnwood

31. Chelmsford

32. Cheltenham

33. Cherwell

34. Cheshire East

35. Chichester

36. Chiltern

37. Chorley

38. Colchester

39. Copeland

40. Cotswold

41. Craven

42. Dacorum

43. Darlington

44. Dartford

45. Dorset

46. Dover

47. Ealing

48. East Cambridgeshire

49. East Hampshire

50. East Hertfordshire

51. East Northamptonshire

52. East Riding of Yorkshire

53. Eastbourne

54. Eastleigh

55. Elmbridge

56. Epping Forest

57. Epsom and Ewell

58. Exeter

59. Fareham

60. Fenland

61. Forest of Dean

62. Gravesham

63. London Borough of Greenwich

64. Guildford

65. Halton

66. Hambleton

67. Harborough

68. Harlow

69. Harrogate

70. Hartlepool

71. Hastings

72. Havant

73. Herefordshire

74. Hertsmere

75. High Peak

76. High Wycombe

77. Hinckley and Bosworth

78. Horsham

79. Hyndburn

80. Isle of Wight

81. King’s Lynn and West Norfolk

82. Knowsley

83. Lancaster

84. Leicester

85. Lewes

86. Lichfield

87. Maidstone

88. Maldon

89. Malvern Hills

90. Mansfield

91. Medway

92. Mendip

93. Mid Bedfordshire

94. Mid Suffolk

95. Mid Sussex

96. Milton Keynes

97. Mole Valley

98. New Forest

99. Newark and Sherwood

100. North Devon

101. North Dorset

102. North East Derbyshire

103. North East Lincolnshire

104. North Hertfordshire

105. North Kesteven

106. North Lincolnshire

107. North Norfolk

108. North Somerset

109. North Tyneside

110. North Warwickshire

111. North West Leicestershire

112. North Wiltshire

113. Oldham

114. Pendle

115. Preston

116. Purbeck

117. Redbridge

118. Redditch

119. Reigate and Banstead

120. Ribble Valley

121. Richmondshire

122. Rochdale

123. Rochford

124. Rossendale

125. Rugby

126. Runnymede

127. Rushcliffe

128. Sandwell

129. Scarborough

130. Sedgemoor

131. Sefton

132. Selby

133. Sevenoaks

134. Shropshire

135. Somerset West and Taunton

136. South Bucks

137. South Cambridgeshire

138. South Derbyshire

139. South Gloucestershire

140. South Hams

141. South Holland

142. South Kesteven

143. South Lakeland

144. South Norfolk

145. South Northamptonshire

146. South Oxfordshire

147. South Ribble

148. South Somerset

149. South Staffordshire

150. South Tyneside

151. Spelthorne

152. St Albans

153. Stevenage

154. Stockport

155. Stoke‑on‑Trent

156. Stratford‑on‑Avon

157. Stroud

158. Swale

159. Swindon

160. Tameside

161. Tandridge

162. Tendring

163. Test Valley

164. Tewkesbury

165. Thanet

166. Thurrock

167. Tonbridge and Malling

168. Torridge

169. Tunbridge Wells

170. Vale of White Horse

171. Walsall

172. Warrington

173. Warwick

174. Watford

175. Waverley

176. Wealden

177. Welwyn Hatfield

178. West Berkshire

179. West Devon

180. West Lancashire

181. West Oxfordshire

182. Wiltshire

183. Windsor and Maidenhead

184. Woking

185. Wokingham

186. Worcester City

187. Wychavon

188. Wycombe

189. Wyre Forest

The above list of authorities that are unable to demonstrate a five-year supply target is accurate at the time of writing. It is also worth noting this list is not exhaustive and there may be even more councils than the 189 we’ve identified here.

Now, let’s take a look at how landowners and developers use the 5YHLS to their advantage.

Under the National Planning Policy Framework (NPPF), development in the Green Belt is considered inappropriate unless the harm to the Green Belt is outweighed by other considerations. One such consideration is when an LPA cannot demonstrate a 5YHLS, which can allow developers to use the argument of very special circumstances to justify development on Green Belt land.

Developers often argue that the inability of councils to provide enough land for housing, combined with a housing crisis, creates a situation where the benefits of new housing outweigh the harm to the Green Belt’s openness.

At its core, the key to successfully arguing very special circumstances lies in demonstrating that the proposed development would help to address the shortfall in housing supply while causing the least possible harm to the Green Belt’s core purposes.

In such cases, the architects and town planners of the proposed development must present clear evidence of the housing need and show how the scheme would meet local housing demands. They may also argue that the proposal aligns with sustainable development goals, providing affordable housing or contributing to local infrastructure improvements, which further strengthens the case for very special circumstances.

Ultimately, the success of a very special circumstances argument relies on balancing the 5YHLS shortfall against the specific harm to the Green Belt, with a strong emphasis on demonstrating public benefits that outweigh the development’s impact. Councils facing housing supply deficits are more likely to accept such arguments, particularly when their local plans are out of date or under revision.

Moreover, the new NPPF introduced the grey belt as an alternative pathway that doesn't require proving very special circumstances. This new designation identifies land within the Green Belt that makes limited contribution to Green Belt purposes, allowing development when unmet housing need is demonstrated.

Through this mechanism, developers can now use 5YHLS shortfalls as a gateway criterion that, when combined with suitable grey belt land, creates a presumption that development is not inappropriate in planning terms.

This approach has gained significant traction since implementation, with numerous applications being approved in just the first few months of 2025, as developers and local authorities quickly adapt to this more streamlined pathway for addressing housing shortages in constrained areas.

However, in cases where councils turn down planning applications, developers frequently pursue planning appeals. The presumption in favour of sustainable development becomes a key factor in these appeals, as the NPPF advises that planning permission should be granted unless the adverse impacts ‘significantly and demonstrably’ outweigh the benefits of the proposal. As a result, the lack of a demonstrable 5YHLS often tilts decisions in favour of developers, who are capitalising on this to secure planning permission to build in the Green Belt. 

If you have Green Belt land you'd like to develop by leveraging your council's 5YHLS shortfall, then don't hesitate to get in touch with our team.

We are a multidisciplinary group of architects and town planners who have a 97% success rate when it comes to achieving planning permission for our clients. We also have plenty of experience working on Green Belt projects and recently even wrote our very own book on the topic, ‘Green Light for Green Belt Developments’. 

Of course, the Green Belt isn’t all we specialise in. If you’d like to discuss your project, no matter how big or small, we’d love to hear from you. Get in touch today.