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Digest of comments received following consultation on Draft Revised NPPG3 of March 2002
DELIVERING HOUSING LAND
Paragraph 66
AC: It should be clarified that the completion of quality dwellings and the creation of sustainable mixed residential environments are the objectives housing policies within development plans, not of development plans themselves.
There is a need to outline the role and content of both Structure Plans and Local Plans in relation to housing issues.
BH: Append, 'within the plan period' to the 1 st sentence, to clearly articulate the importance of delivery of housing.
CAA: (Also applies to paragraphs 77 & 79) Strongly believe it is wrong ' to ensure that the housing land requirement for each housing market area is provided for in full'. The main reasons are:
- Census 2001 data to base forecasts is unavailable until 2003.
- The methodology for calculating housing demand and associated forecasts of land requirements lacks certainty and is open to challenge.
- There is no national policy for the equitable distribution of growth to appropriate areas throughout Scotland that would facilitate the achievement of the correct balance between sustaining housing/economic growth and safeguarding the quality of life derived from the natural and built environment
Recommend a more holistic, equitable and balanced approach is adopted in the formulation of housing land requirements.
CALA: Subscribe to objective of delivering housing land through development plans, provided such Plans are kept up to date.
CEC: The text is not sufficiently clear on what structure plans and local plans are separately expected to do, perhaps this is due to the Review of Strategic Planning and possible changes to the development plan system.
CLACK: Confirms the role for planning authorities. This is important and fundamental to the current ethos of planning. Several practitioners may express concern that the industry is being given extra strong powers of challenge but this should not be the way forward.
DCC: The important role of the development plan in assessing housing land requirements and bringing forward sites to meet this, is emphasised in the draft NPPG
ELC: Despite its worthy intentions, there is little evidence that the revised NPPG will lessen the hugely time-consuming and sterile debate over the "numbers game" that continues to afflict the land use planning process. Indeed, it may intensify this as the introduction of longer timescales for structure plans and housing land audits may further increase the uncertainty element.
The finalised NPPG should explore how more innovative ways to assemble land for new housing/redevelopment can be brought forward.
ERC: Guidance does not distinguish between Structure and Local Plans. The removal of this distinction is premature pending the review of strategic planning in Scotland that is currently underway. It is important that this distinction is retained to ensure that there is no confusion and unnecessary debate at inquiries.
FIFE: Change of housing land requirement (HLR) allows less flexibility in determining if the HLR can be met elsewhere within the same Structure Plan area. This change is not welcome.
Throughout NPPG little or no reference made in Local Plans or Structure Plans but just to the "Development Plan". This is not helpful as specific guidance is necessary pending the outcome of the Review of Strategic Planning.
GCC: The draft guidance refers to development plans rather than structure and local plans in anticipation of the Review of Strategic Planning. However, full structure plan coverage will continue to be required for some time yet and even in the new system that is proposed clear guidance on the respective roles of strategic and local planning will be required. The draft guidance needs to be amended to reflect this.
GCVSPT: Removing the distinction about what matters are appropriately dealt with in Structure Plans as opposed to Local Plans; this will allow matters to be reopened at Local Plan inquiries that have been properly addressed at the Structure Plan, or require the Structure Plan to become involved in too much detail.
It is anticipated that as the Review of Strategic Planning has still to be finalised and will also require a legislative change, that full structure plan coverage will continue to be a requirement for some time yet. The new system that is proposed will have a two tier planning arrangement in the city regions. It is important to clarify the responsibilities of each tier. Without clear guidance for development plans there will be unnecessary uncertainty, debate and legal challenge.
The need for guidance about the strategic and local planning roles will continue after the Review of Strategic Planning. The proposed guidance therefore needs to be amended to reflect this. However as is a matter that would introduce new material to that which is in the published draft, it is essential that there is further consultation with the Joint Committee on the appropriate text that would meet this concern.
MLC: Unlike the current guidance, draft NPPG3 does not distinguish clearly between the role of structure and local plans.
M&M: Subscribe to the objective in delivering housing land through development plans.
NLC: Lack of distinction made between Structure and Local Plans, references often made solely to the Development Plan. May lead to difficulties where certain issues are of a strategic or local consideration.
PCS: Policy H2 of the Scottish Borders Structure Plan 2001-2011 implies that if developers exhaust the planned building land supply before the end of the plan period then the supply has to be increased on a pro-rata basis. There would be unplanned developer-driven expansion even though much of the housing requirement or demand in the South Tweeddale is externally generated. Uncontrolled developer-driven growth would destroy the attractive built and natural environments upon which the future prosperity (sustainability) of Peebles depends. The draft NPPG does not seem to have resolved this issue. Numerous statements appear to require planning authorities to take account of constraints upon housing development. However paragraph 79 implies that it is only exceptionally that they will constrain provision of the full housing land requirement. Indeed the Summary and paras 66 and 77 say: "Planning authorities should ensure that the housing land requirement for each housing market area is provided for in full". On the other hand references to phasing in paras 51 and 68 indicate a duty or an ability of the planning authority to control the rate of housing development.
The NPPG needs to clarify and reconcile this problem.
RH: Subscribe to the objective in delivering housing land through development plans.
RTPI: Suggest a clearer indication be given as to the requirements of strategic and local plans with regard to policies for housing land. Subject to such changes as can be anticipated from the review of strategic planning.
SCCL: There is a direct correlation between the "location" and "delivery" of housing land. This relationship requires to be recognised in a revised NPPG3 and, subsequently in development plans.
Major concerns relate to the front-end assessment of development sites, which has, in the recent past resulted in:
Long standing allocations of constrained/ non-effective sites.
Substantial delays in site delivery
Failure to understand the commercial reality and providing choice in a market environment.
Therefore transparent site assessments, Green Belt reviews and monitoring reports are especially important. The progress of sites in marginal areas should be addressed early on and not left unattended for the plan period.
SEPA: In allocating sites for residential use in development plans, SEPA would like to see encouragement for a greater degree of site assessment prior to allocation. For example, Clackmannanshire Council as part of their assessment of site options conducted a brief but informative environmental evaluation, which was then used to inform decision making on which sites should be allocated in the Local Plan. Such approaches are considered to be very good practice in identifying, and planning for environmental and other constraints at the earliest possible stage in the allocation process.
SLC: Lack of distinction between structure plans and local plans.
STARK: Principle difficulties that arise from planning practice:
- Structure plans often fail to identify sufficient land to last their lifetime.
- Local plans take longer to adopt than do structure plans to approve, thus exacerbating the problems of insufficiency.
- Structure plans are too detailed at a settlement level, which drags them into largely irrelevant controversy, exposes them to future uncertainties and unduly constrains local plans
- Local opinion is often anti-development, Simply requiring more housing to be identified will add to the difficulties of LAs, resulting in political paralysis.
Both the draft NPPG and the PAN are much too timid in their approach and a more radical approach is required before any progress can be expected towards a less confrontational system. The key lies in restricting structure plans to truly strategic issues, meaning those relating to the functions and inter-relationship of places, and leaving issues that affect only the locality to local plans and development control.
The necessary actions are:
1. The development plan should identify sufficient land so that there remains, at the end of each phase, an adequate supply of land for housing in each market area.
2. The development plan should maintain a 7-year established supply of land for housing in each housing market area. Planning authorities should be prepared to grant consents from within the established supply so that a 5-year supply of effective housing land is maintained at all times.
3. The supply should be identified in detail to guide consents until the plan is next reviewed; should give reasonable indications of where land is likely to be identified in the next generation of plan; and should give a context for subsequent development.
4. Fewer demands should be placed on the level of detail required in strategic plans, to make it easier for LAs to prepare and gain political acceptance for them, and to permit easier adjustment should monitoring indicate the need to adjust the detail, but not the strategy, of housing distribution.
5. Structure plan policies should not distinguish between land already identified for housing and land to be added to the current supply.
6. Having secured a long-term strategic context, it ought to be easier to explain and defend the extent of land to be identified by a local plan, which in turn should guide development control decisions.
7. Where major new areas are to be opened up, the local plan should be able to address a longer time horizon in order that outline consents may be granted covering a whole department.
8. Development control decisions that cannot be made within a local plan context should be guided by the strategic plan.
UNITE: Reference should be made to the fact that student and key worker accommodation is indeed a form of housing that meets a local need and planning applications for such development should be treated accordingly. Student and key worker accommodation should have its own separate section, such as that given to affordable housing. Provision should be made for a housing type suitable for universities, colleges, and NHS Trusts
Specific development plan policies for student and key worker accommodation should be required.
WDC: As a result of the uncertainty of the future of strategic planning and the new system of local housing strategies not being fully implemented, there is some confusion about the particular roles of development plans, and their relationship with local housing strategies and other policy documents. There is no 'action required' section making clear what structure and local plans respectively are required to do. It should be made clear that the Structure Plan is the primary mechanism for assessing private sector housing land requirements within city regions.
Paragraph 67
ACC: Perhaps there should be a reference highlighting the important role of community planning consistency between plans and strategies. There may, however, be some tension between 5-year Local Housing Strategies and the proposed requirement to maintain a 7-year supply of land that is effective.
SLF: The new system of local housing strategies deserves strong support.
SNH: First sentence. In view of the importance the NPPG 3 places on the transport and open space aspects of new developments, reference should also be made here to local transport strategies and open space strategies.
Consideration should also perhaps be given to key issues raised in SNH's Settlements Prospectus including them as part of the material on development plans in the 'Delivering housing land section', which also addresses the related issues of housing demand and housing land.
WDC: It needs to clarify how the provision for housing in development plans is informed by the needs assessment undertaken in support of local housing strategies.
Development plans
NLC: Note between paragraphs. 67 and 68 describes anticipated Development Plan system revision. This appears to have heavily influenced the document and lead to a lack of clarity. Possibly more appropriate to promote the note at the front of the document and clearly set out which guidance may be affected if the revision to the development plan system took place.
PKC: The reference to the review of strategic planning leaves it unclear as to the possible division of responsibilities which might result, for example, in areas outwith the city regions; will the " local development plan" be the vehicle for assessing future housing land requirements?
RTPI: It is likely that this NPPG will require significant revision once the new provisions for Strategic Planning come into force. While it may be anticipated that the timing of a Planning Bill with its necessary changes to primary legislation may trigger many future changes in the system, the development of the debate about the planning system in parallel with the preparation for this bill may well identify earlier opportunities for changes in policy, particularly in anticipation of a National Planning Framework, which may not require primary legislation.
Paragraph 68
AC: We consider that the proposals for the reform of the development plan system proposed should be promoted through a revision to NPPG 1. The issue of a "locational strategy for future development over a period of 20 years" is not a housing issue.
There is considerable concern over the issue of the proposed requirement to provide a 7-year supply of effective land. No case has been made as to why this change is necessary and it is submitted that such a proposal is unworkable due to the long term planning horizon. While we could support the concept of a 7-year established housing land supply, the adoption of a 7-year effective supply requirement is inappropriate in most parts of the country. In the North East we have adopted a process of continuous plan making which will require review of housing land requirements on an annual basis and review of the allocations accordingly. This is similar in some ways to the English experience. Alternative solutions to the problems of "overheating" in the central belt should be explored (such as a specific "Edinburgh Housing" NPPG) rather than imposing a solution on all local authorities which will not facilitate or support confidence in planning for housing.
We support the proposal for an implementation action plan but question whether such action plans will carry sufficient weight to influence the spending priorities of other bodies and agencies. Without such support an Action plan is likely to be more aspirational than visionary.
ACC: If the proposal for a 7 -year supply of effective land is adopted, the method of calculating the land supply will clearly have to be clarified to ensure that proper emphasis is placed on including sites "likely to become effective". (No case has been made for a 7-year effective supply). The longer time period will make it harder to reach agreement as uncertainty increases with longer time horizons. Also, there is no indication of what happens if agreement isn't reached. Will there be some sort of arbitration? ( Cross reference with Draft PAN 38 comments)
ANGUS: There are benefits to the housebuilding industry, investors and infrastructure providers of identifying the effective housing land supply over a seven year period. The NPPG should also explicitly state that the 7 year supply of land which is effective should be maintained at all times to ensure the roll forward of an effective land supply. This is stated in PAN 38 at paragraph 28 but not in the policy document itself. However, the requirement that development plans need to give an indication of the scale of the housing land requirement over the 8-15 year period is less clear. This element of the 20 year forward planning process requires to be qualified in some way perhaps indicating that the level of the housing land requirement in year 8-15 will be subject to review and will be confirmed through careful monitoring of the effective 7 year housing land supply.
BH: Support the comments of the 1 st bullet, suggest insert, 'by the local authority and Homes for Scotland' after 'agreed', in order to provide a greater degree of certainty over the deliverability of housing land.
Support pro-active approach towards resolving of land supply constraints via Action Plans. Suggest that Action Plans form the implementation Section of Local Plans.
Liaison and assistance with private sector in forming Action Plans will assist in ensuring that the wider objectives of the NPPG3 are achieved. Need to reaffirm the importance of CPO powers within approach.
BETT: Contents are a very positive step in the right direction. However it is important that a system is set up through the housing monitoring process which determines that effective land must be agreed between the developer and the LA.
CALA: Fully support the proposition of the effective year supply of land to meet planned housing requirements in full as part of a 20 year locational strategy. Action Plans will allow for considered debate and agreement on the likely effectiveness of specific sites. Overriding aim should be that household projections have to be met via household completions and not merely allocations, in order to provide, 'roofs over heads'.
CEC: 1st Bullet- It appears from this passage that plans need only provide a definitive land supply for the first seven years of the plan. There is no reference in the NPPG to the need to maintain land supply at all times. PAN 38 however is contradictory on this point. In paragraph 27 it defines effectiveness only in terms of the first seven years of the plan, but in paragraph 28 it requires a seven year supply to be maintained at all times.
This objective seems to be proffered as best practice rather than Government policy. If there is to be a reference to maintaining a constant seven-year land supply it should be in the NPPG rather than the PAN as it was in the original 1993 NPPG. Alternatively, it may that the Executive considers that the aim of a constant land supply is at odds with the overall intention to give less weight to the quantitative aspects of housing land. Either way the position should be clarified.
Whilst the glossary defines "effective" as "free or expected to be free", this bullet requires a "7 year supply of land which is effective or agreed as likely to become effective". This repetition is unnecessary and confusing. In PAN38 the criteria used to define effectiveness (paragraph 27) have been refined and "programming" have rightly been removed since this was never a criterion of effectiveness as such, more a qualification on how much of a site could be treated as effective. It is also suggested that the wording clarifies which parties should be in agreement on what is likely to become effective.
2 nd Bullet - Whilst the third bullet does not require plans to be specific post year 15, it is unclear what local plans are to do with structure plan statements regarding years 8-15. It appears that they should safeguard such land for release in the medium to long term subject to monitoring but this is not clearly stated. PAN38 does little to clarify the NPPG. Planning authorities are encouraged to forecast requirements only for the first 7 years of the plan (paragraph 13). Beyond that, "the emphasis should be on reaching consensus on the overall scale of the requirement and the direction and pattern of future housing development rather than precise figures". It is not clear how one can come to a view on requirements for years 8 to 15 without making some sort of forecast for this period.
3 rd Bullet - Whilst the approach to have a long term housing strategy for 20 years is supported, it should be noted that population and household forecasts do not extend this far so it is not possible to be other than indicative in these latter years.
Last sentence - The introduction of a requirement for action plans (as also proposed in the Review of Strategic Planning) is supported as a helpful concept provided they are used management tools and do not form part of the statutory plan.
CLACK: The continued role for Development Plans is welcomed and in our opinion crucial. The longer-term view for housing land supply is agreeable providing it is set within the Development Plan framework.
D&G: Given the current infrastructure constraints in Dumfries and Galloway, achieving a seven year effective land supply could be significant challenge which is largely outwith the control of the Council to deliver.
DCC: Setting out locational strategy for future development over a period of 20 years offers greater certainty to developers and communities over the scale and direction of future growth. However, household projections do not look far enough ahead to inform this process. Information on other factors is more open to challenge over this extended timescale.
7 -year supply of land giving additional certainty welcomed, but there is a need for clarity in the NPPG whether the 7-year supply of effective land is to be available at the stage of Local Plan adoption or should be maintained throughout the Local Plan period.
In term of land supply issues, a criticism of the current approach is the focus on housing land supply and the lengthy debates on issues of effectiveness that are a common element of Local Plan inquiries. Whilst the draft NPPG represents a positive step towards this, there remains a danger that debates on the effectiveness of housing land will continue to divert attention away from creating sustainable, vibrant residential communities.
EAC: The adjustments to planning horizons are strongly supported as a means of assisting the long-term planning infrastructure provision. However the guidance is most applicable to major growth areas rather than East Ayrshire. It is recommended that the NPPG should be amended to make specific reference to the fact that the requirement for the preparation of Action Plans applies only to those settlements where major growth is expected. The NPPG should also be amended to stipulate that development plans must clearly indicate those areas where housing development would be expected in the 8-15 year period. Any earlier release of land on these sites would require to be justified against the demand and supply conditions at the time. The phasing of development should therefore become a material consideration. These measures will help to promote the orderly release of housing land in line with demand requirements.
EDC: Unwelcome element of confusion by referring to a requirement for "at least a seven year land supply", thereby departing from the established auditing process. Clarification is required of the effective land supply requirement (7 or 5 years)
ELC: There is little justification in the draft document for the need for a 20-year vision for housing land provision. The current Structure Plan system provides a 10-15 year vision and no evidence is presented to suggest that this fails to meet requirements. The proposed vision bears no relationship to any existing planning or related documents. There seems little need for a time horizon change, particularly into one based on an increasing level of forecasting uncertainty.
Housing audits dominate the housing land delivery process. The proposal to extend audits of effective housing land to 7 years introduces yet more uncertainty into the process of predicting house completions in the latter years. It is difficult enough to do this over a period of for 5 years.
The use of an action plan to set out implementation may be useful, but it should be presented as supplementary guidance rather than as a part of the development plan. A 20-year structure plan vision may be incompatible with the timescales of many infrastructure and service providers making accurate programming in later years difficult.
EG: Encouraged to see the time horizon for development plans being increased to 20 years. This is proper planning and will negate the slavish adherence to the provision of the exact number of houses in an identified land supply shortfall.
It is also essential that the 7-year effective land supply is guaranteed. The agreement on the 7 year effective supply is still subjective and it is preferred that the original definition of effective should be used, namely in the control of a developer and with the benefit of a detailed consent, before it can be included in an agreed effective supply. Therefore, to ensure effective delivery, Scottish Water's priorities must be adjusted to meet the direction of development in approved plans. There are major concerns about the provision of water and sewerage services.
ERC: The proposed requirement for at least a 7 year supply of land that is effective lacks justification. The introduction of this extended period would require the Joint Structure Plan Committee to consider a 9 year supply period with all the attendant uncertainties involved with the longer term view of the criteria for establishing the effectiveness of sites. The approach adopted by the Joint Structure Plan Committee provides a more appropriate model for guidance purposes.
The introduction of a requirement for "agreement" implies that the housing providers are being given a veto on the effective housing supply. Any reduction in the authorities discretion related to this matter is likely to lead to an increasing level of dispute with the house builders. It is considered that the existing guidance, coupled with the advice on housing land audits prove an adequate framework for the delivery of housing land. The longer-term time horizon will lead to additional uncertainty and dispute thereby undermining a plan-led approach.
FC: This assumes that it is possible to make housing market predictions 20 years into the future and that the central planning problem is the under supply of housing land. The NPPG3 does not recognise that the over supply of housing land can also present land use planning problems. It is difficult to forecast for 20 years, though it is relatively easy to increase land supply, in practice it is difficult to reduce it.
A 7-year effective housing supply also presents difficulties. It is extremely difficult to identify with any degree of accuracy phasing and house completions for more than 3 years in advance. Analysis of previous Council Housing Land Audit projections and what actually is built bears this out. Housebuilders will always overestimate their new build intentions to maintain pressure on Councils for further housing land releases. In calculating the 7-year supply of housing land, no allowance is made for building at faster rates then planned in popular market areas, resulting in increased development pressure.
FIFE: 7- year supply of land is which is effective or agreed as likely to become effective, is not supported. Recommends that guidance should reflect previous PAN of a continuous 5-year minimum supply with the possibility of looking to 7 years. A continuous 7-year supply will mean that Local Plans will have to allocate sites for a period of 12 years to ensure continuity in supply. The current approach fits better with the 5 year Local Housing Strategy and also with the 20 year Development Plan timescale where the first 10 years is identified in detail with the next two 5 year periods progressively more indicative.
GCC: Paragraph 68 uses the term 'effective or agreed as likely to become effective.' This seems to imply that the only sites that can be counted as effective are those on which there is agreement between the local authorities and Homes for Scotland. This, in effect, would provide Homes for Scotland with a veto on sites, thereby reducing the effective supply and increasing the requirement for additional land release. This approach to defining effectiveness would be completely unacceptable.
The finalised guidance on changes to plan periods will need to be more specific, but, potentially, these changes could have significant implications for the brownfield development strategy in the Glasgow & Clyde Valley Structure Plan. The strategy would be undermined if decisions on long-term land releases were required at the outset of the development plan. By its nature, a brownfield strategy relies on output from sites the location of which is difficult to predict over the long-term.
The proposed change in the requirement for a 5-year effective land supply at all times to a 7-year supply would seem to pose no problems for the authorities in Glasgow and Clyde Valley, as a 7-year view has been used for a considerable time. However, this approach was specifically developed to provide a minimum 5-year view when housing requirements were being reviewed every two years. Where a development plan contains a detailed comparison of supply and demand for only the first seven years, it would fail to meet the requirement for a minimum seven-year view at all times almost as soon as it is submitted. To overcome that, the Structure Plan would have to take a 9-year view to ensure a minimum 7-year supply at all times. The further into the future that judgements on site effectiveness and programming have to be made, the greater the uncertainty. The credibility of this exercise would be compromised if the period were extended to nine years. For example, the availability of GRO Grant is a crucial factor in the effectiveness of a significant number of sites in the City, but the funding programme only looks ahead three years. Extending the period over which judgements about effectiveness had to be taken to nine years would only serve to exacerbate the difficulties with this exercise. The draft guidance should be altered to reflect the approach used in Glasgow and Clyde Valley - that taking a 7-year view of effective supply relates to a minimum requirement of 5 years supply at all times.
The guidance is not clear on whether development plans will be required to identify specific land releases for the extended plan periods. The current 2000 Structure Plan considered the issue of supply in the longer term by using an urban capacity study to identify the potential for further brownfield development. It is not sufficiently clear whether that approach would conform to the new guidance. If not, it would inevitably result in substantial greenfield release across the conurbation. Identifying sites for longer-term development would be more appropriate in areas where most new development is on greenfield sites and new infrastructure needs to be planned well in advance.
GCVSPT: The proposed requirement for a 7 year effective land supply at all times, will in effect require a confirmed 9 year supply when preparing a Structure Plan compared with the current 5 year requirement. This will fundamentally undermine the recently approved Structure Plan. By extending this timescale there are clearly significant uncertainties involved in assessing the effectiveness of sites so far into the future. This needs to be amended to relate to the approach used in the Glasgow and Clyde Valley Structure Plan.
HFS: Welcomes the broad intention of the guidance in this paragraph. However, the reference to the effectiveness of housing land supply in the first bullet point does not give sufficient certainty, and we would wish the words "by the local authority and Homes for Scotland" to be inserted after "agreed" in that bullet point.
Welcomes the recognition in the revised draft of NPPG 3 of the need for housing land requirements to be provided for in full over a seven-year period. However, we do not subscribe to the view that this requirement can appropriately be tied to each housing market area given that some housing market areas may be held to extend beyond the boundaries of individual local authorities. Housing demand should be provided for in the area where it arises. We do not think it appropriate for local authorities to be permitted to use the existence of a wider housing market area as justification for a failure on their part to make provision for demand in their areas. We would wish this consideration to be reflected in the revised guidance.
Pleased to note that the guidance identifies the need for the participants in the process of determining land supply requirements to seek to adopt a consensual approach, for greater transparency and consistency in the methods to be promoted, and for house builders to be given confidence about the direction of development in the medium to long term. These are significant improvements on the existing guidance. It is important that the Executive stands firm on these matters.
Reference is made in the last sentence of this paragraph to the preparation of action plans on implementation. Homes for Scotland entertains serious doubts as to whether LAs would have the time, the expertise, or the staffing and other resources required to prepare such plans. Instead reference should be to the preparation of procurement plans. These should be part of the development plan implementation provisions and should be drawn up in consultation with the private sector with a view to showing what infrastructure provision would be publicly funded and what would be expected to be provided by developers. In the preparation of procurement plans consideration should also be given to the implications for the marketability of housing developments of the infrastructure burdens which developers would be expected to bear. We see procurement plans as being necessary to give developers confidence and certainty about their investment decisions.
Welcomes time horizon for development plans to be extended to 20 years.
HSE: Desire to reflect careful consideration of health and safety matters and the need to indicate to developers the location of hazardous installations and major accident hazard pipelines so that there are minimal speculative proposals that would have to be refused because of health and safety considerations.
KEPPIE: The role of Local Plans is crucial in the context of creating an element of flexibility in the supply over and above demand and supply calculations, as are issues of distribution imbalances within local authority areas which are currently of great concern in parts of Scotland. The need to create a balanced approach that promotes a range of house types, sizes, quality and geographical opportunity should be a prime aim of government advice.
MLC: The general principle of a 20-year planning horizon is supported. However, there are concerns that the explanation given of how this might work is not clear. Suggest that Development plans should take an informed long-term view on the provision of housing setting out a locational strategy for future development over a minimum period of 20 years
Structure plans should indicate how much land is required and its general location. They should identify a specific numerical housing land requirement for the first 15 years of the plan period, and provide for at least a 5-year supply of effective housing land at all times to meet this. The plan requirement should be sub-divided accordingly, with an indication given of the corresponding development phasing.
Structure plans need to be flexible enabling them to respond to changing circumstances. Plans should provide the following:
For the first 10 years, firm allocations of housing land. This could include assumptions regarding contributions made by windfall housing.
For years 11 - 15, safeguarding of potential housing land.
For years 16 - 20, identification of possible future directions for development.
Local plans should allocate and safeguard land within this context. They should also contain an action plan setting out how implementation will be achieved and such as infrastructure provision, and development briefs.
M&M: Fully support the effective 7 year supply of land and planned housing requirements in full as part of a 20 year locational strategy. Action plans will allow for considered debate and agreement on the likely effectiveness of specific sites. The overriding aim should be reiterated that household projections have to be met via housing completions, not merely 'allocations', providing 'roofs over heads'.
NAC: The longer-term planning period will in theory have benefits in relation to infrastructure provision, the removal of development constraints and provide greater certainty for developers and local communities but will require greater input of staff resources in assessing many more potential sites. In practice no indication is given as to how to secure drainage provision, social housing, education provision etc and thereby meet the social and sustainability agendas in the context of such long-term planning.
NLC: Extension of land supply from 5 to 7 years is a significant factor as it is necessary to include 2 further years of land supply at the outset. Due to the unpredictable nature of brownfield land fallout there are likely to be severe pressures on LAs to meet requirements from greenfield sites.
Draft points out that Development Plans should, in taking a view over 20 years, produce a 'locational strategy'. This introduces some inconsistency in Scottish Executive advice relating to the timescale of strategies. Existing guidance states that policy directions should be set out for a period of 10-15 years. Whilst PAN 37 has not been revised and retains references to a 10 year period.
Current NPPG 3 (paragraph. 83) states that Structure Plan policies should "provide for a minimum 5 year supply of land which is effective or capable of becoming effective to meet the Plan requirement." Draft NPPG has changed the word capable to agreed, this is a significant change. There is no reference to what an agreed site is. Sites that in the past that have been referred to as "Disputed Sites", at present these sites remain in the effective land supply but are highlighted at public enquiries as being disputed.
OHA: Support this Paragraph
PH: Relative to long-term views on the provision of housing through development plans is welcomed. But the first bullet point which states "agreed as likely to become effective" does not provide sufficient certainty and would concur with Homes for Scotland's response which states that the words " by the local authority and Homes for Scotland" is added to this sentence.
It is anticipated that the "action plans" will not be kept up to date or contain the necessary information to allow house builders sufficient certainty to back up investment decisions. It is therefore proposed that such plans should be statements of fact regarding the availability of infrastructure and burdens that will be anticipated to be met by developers. It is not anticipated that such plans will be prescriptive upon type and tenure of housing unless prepared in association with the private sector.
PKC: It is stated that plans should provide " at least a 7-year supply of land, which is effective or agreed as likely to become effective to meet the plan requirement." This represents a two-year increase from the current NPPG 3. The maintenance of an effective, or agreed as likely to become effective, housing land supply could prove to be difficult in many areas. The main obstacle to maintaining such a supply is infrastructure constraints, and the fact that many of the providers of infrastructure work to three-year budgets. No cognisance of this is taken in the Draft NPPG, and the disparity needs to be addressed.
RC: The overall requirement for a short, medium and long-term view is supported.
In order to maintain a 7-year supply over the 2-year update cycle it would be necessary to identify a 9-year supply of housing land. The current supply contains many more houses in the earlier period than in the later periods. This reflects the fact that house builders do not have comprehensive build programmes that extend 7 years let alone 9 years. It is essential that the NPPG takes account of this and it is strongly recommended that it endorse the procedure currently undertaken by the Glasgow and the Clyde Valley Joint Structure Plan. The Local Housing Strategies are only required to look 5-years ahead, local plans generally cover a 5-year time horizon and Communities Scotland normally only provide commitments for 3-year development funding programme. For consistency with other guidance and to remain robust forecasting, the programme period for the effective land supply should remain 5 years.
Existing policy guidance for structure planning indicates a 10-15 year period. Although it may seem desirable to lengthen this period out to 20 years, to give greater guidance for infrastructure investment, in reality, detailed predictions for this timescale for many areas would not prove sufficiently robust and may lead to inappropriate investment. It is suggested that consideration of urban capacity opportunities coming forward in a 5-10 year medium term period and, at most, a 10-15 year longer term period would provide a more realistic planning time frame.
Lack of clarity about what matters should be dealt with by structure and local plans. It is essential that developers and the public know what will be included in structure and local plans.
RH: Fully support the effective 7 year supply of land and planned housing requirements in full as part of a 20 year locational strategy. Action plans will allow for considered debate and agreement on the likely effectiveness of specific sites. The overriding aim should be reiterated that household projections have to be met via housing completions, not merely 'allocations', providing 'roofs over heads'.
RICS: Welcome the proposal that plans should now provide at least a 7-year supply of land.
RTPI: Support the increase in the requirement for development plans to provide a supply of land for at least seven years which should achieve the first objective of providing greater choice for developers.
Would strongly support two year housing land updates within the context of an action plan regime as strategic development planning is likely to be confined to the four main city regions and the areas of greatest development pressure. However are less certain with regard to the mechanism for identifying "the scale of housing land requirement and the direction and pattern of housing development" in years 8-15 and more broadly beyond year 15. In the first place, this can only be appropriate for strategic development plans. If the seven year supply of land should focus primarily on the effective housing land supply as defined in the glossary, greater incentives are required for developers and planning authorities to work towards the resolution of constraints on other sites within the established housing land supply. More attention will also require to be paid to the assumptions made in population and household projections for the longer period.
The key to the longer-term perspective on housing land supply will be the National Planning Framework, which, at the very least, should establish a consistent monitoring and projection framework for strategic development plans.
SAC: The 20 year time frame proposals are also to be welcomed as a basis for more effective planning. They allow for the consideration of a longer term framework and give greater certainty to the public, the development industry, utility service providers and other interested parties. It is also likely that these proposals will reduce the often highly resource consuming, yet sterile, disputes between local authorities and housing developers, often at appeal, over the precise nature and extent of the housing land supply for a particular area.
SBC: The move from a 5 year to a 7 year supply of effective housing land raises several concerns. It is not at all clear why this alteration is required and what it is intended to achieve.
In order to overcome the issue of over-allocating land in the Local Pan, this Council identifies "potentially effective" housing land as part of the annual audit of housing land. This is land that is agreed with the house builders as being likely to become effective as constraints are removed. This particularly concerns land that is identified in Local Plans to come "on stream" in years 6-10. Many LAs do this to avoid the over-allocation of housing land in Local Plans. This approach ensures that there is an incentive for landowners to take steps to remove existing constraints and to see these sites become part of the effective supply. There is a danger that the move to a 7 year supply of effective housing land will have a counter-productive effect on the removal of constraints, and will result in the over-provision of effective housing land.
There are already considerable problems associated with the identification of likely housing land requirements 5 years ahead and in agreeing with the house builders, as part of the housing land audit, what will be effective, potentially effective or constrained that far in the future.
Overall, it is considered that the move towards a 7 year continuous supply of effective housing land is not sufficiently justified and that a more flexible approach, based on the removal of constraints, would be more useful.
SC: Recognise the reasons for increasing the time period for an effective housing land supply to seven years, but this could lead to an increase in the incidence of appeals from developers on the basis of an identified shortfall in the land supply. Given infrastructure, land ownership and other constraints it often proves difficult enough to ensure a five year supply. Clarity should be given to whether this should be a continuos seven year supply and to how the planning authority should respond if having allocated sufficient land over this time period it is built out in advance. Is it suggested that detailed phasing should avoid this problem or that the planning system should simply respond to variations in the rate of uptake and completion of development by the housebuilding industry?
SEG: Support the policy to ensure that sufficient housing land becomes available.
SLC: The change to a 7 year effective land supply, in reality equates to a 9 year effective supply for authorities to conform to the Glasgow and Clyde Valley Structure Plan Housing Land Requirements. This will allow developers to introduce an array of sites which they believe can be made effective within the 7-9 year period regardless of whether these have been identified as potential housing sites through the development plan process.
Changes to the definition of effectiveness, particularly the introduction of the word "agreed" could be interpreted as affording a veto on sites by housing providers thereby increasing the potential level of dispute. The use of the term "agreed as likely to be effective" is a departure from the previous NPPG, which stated that it is "land capable as becoming effective".
SLF: A realistic and flexible approach is critical for success, and this paragraph underlines this requirement.
SMH: With regard to the reference to preparation of action plans on implementation, we have severe doubts about the expertise or staffing resources available to LAs to prepare such plans, particularly if they are to be part of the development plan process itself, to which objections can presumably be made and heard at Local Plan Inquiry.
SSDP: The most significant change proposed in the revised draft is that this requirement for 5 years is in fact increased to 7 years without any clear justification which could result in the distortion of an agreed Structure Plan Strategy which will guide allocations in Structure Plans and Local Plans. Greater clarity is required as to what the key objective of housing land supply sequencing ought to be. Reference to the proposed new Planning Bill should be made in the light of the longer time periods for which development plans should be prepared.
There is a danger in promoting a 7-year effective supply, as this would reduce the incentive to remove the constraints on constrained land and develop on brownfield sites. There are also currently problems in estimating land requirements and supply for 5 years, for a 7 year period these problems will be exacerbated.
SW: Implementation of proposals in paragraph 68 is strongly supported. This process will assist the management of infrastructure capacity in relation to demand and facilitate liaison between LAs and SW. The process is further reinforced in paragraphs 69 - 71 where matters that have been causes for concern to Scottish Water, in relation to development constraints, are highlighted. The management of development plans, with regular review and liaison, will provide SW with an informed projection of location and magnitude of future demand that could be linked to 4/5 year Quality and Standards periods for Capital Investment. A seven year Housing Audit, reviewed annually, will provide a tool for SW to link legislative investment drivers and demand when developing business cases for schemes to be incorporated in the Capital Investment Programme.
WDC: Current guidance states that development plans should aim to ensure a 5-year supply of effective land for housing to meet the plan requirement. In order to meet this, planning authorities within the Glasgow and the Clyde Valley Joint Structure Plan area currently programme the land supply for 7 years to allow time for plan adoption. For a 7 year supply, the land supply will have to programmed for 9 years ahead. This is impractical, given the information available to assess and programme effective land on a site by site basis. Also, how does this change relate to current Local Plan periods?
WLC: The concept that structure plans should give a clear indication of where future requirements will be met in the next structure plan is unworkable. This would, in effect, mean that a development strategy for a 40 year period would have to be included within development plans. If there is the need to identify a strategy beyond the structure plan period, this should be done in very broad terms rather than as a clear indication.
The draft gives no guidance on, or support for, sequential testing which should be carried out prior to releasing greenfield sites for development. This will be a particular issue if LAs are required to identify a seven year effective land supply. A seven year land supply will increase the demand side of the equation, but it will be difficult to prove that sites will be effective so far in advance. Consequently, a seven year land supply will, in itself, not increase the supply of the land but will make an effective supply more difficult to prove. The inevitable consequence of this is that authorities will find it increasingly difficult to resist releasing new allocations, to defend sequential testing policies and to deliver constrained sites. It is also likely to increase planning by appeal. For these reasons a change is sought to require a five year land supply to be identified rather than a seven year supply.
The requirement that the seven year land supply must be agreed as being effective is a significant change from the previous NPPG, which allowed local authorities to include, disputed sites within the land supply calculations. A requirement for all sites to be agreed as effective will make it beneficial for the house building industry to dispute the effectiveness of as many sites as possible, thereby forcing the early release of additional land for housing. For this reason a change is sought to allow disputed sites to be included in the effective supply. There is no reason why disputed sites cannot be identified separately in the supply (as in the Lothian Housing Land Audit) which would then allow any debate at future appeals or enquiries to focus on these sites rather than review the effectiveness of all sites in the supply.
Paragraph 69
BH: Support contents.
CLACK: The land use planning requirements for brownfield development etc. largely do not occur with the housebuilders desired sites. This is often at the root of non-agreement of the annual audit. Therefore, a strong emphasis on brownfield sites and suitable expansion is essential.
DCC: Concerns over the increasing detachment of infrastructure providers from the development planning process need to be addressed and in particular the lack of a strong relationship between the development plan and investment plans. The increasing reliance on developers to fund infrastructure has the potential to undermine proper planning.
HCC: Mentions consultation about structure plans, but not involvement in the terms of NPPG1 in relation to community involvement.
HFS: The second sentence should be amended to make it clear that the "latter part of the 20-year period" relates to years 15 to 20, if that is, indeed, what is intended.
NLC: It is stated that "… structure plans should give a clear indication of where future requirements will be met if new land is required in the next Structure Plan". This could involve looking forty years ahead, which is not realistic. The guidance should maybe refer to Structure Plan Alterations or Reviews.
Critical that clear guidance is incorporated on what role different parties play in the provision of infrastructure.
PH: There is a requirement to incorporate some clarification on the period to which it refers as "latter part of the 20 years period". Is this year 7 onwards or as assumed years 15-20?
PKC: The third sentence mentions " structure plans", despite the note on strategic planning review appearing to indicate that there will not be structure plans, in their current form at least, after the review of strategic planning is completed.
Paragraph 70
ACC: Agree with regular monitoring.
BH: Support contents - regular monitoring of land requirements. Suggest this be conducted on a biennial basis, to tie with monitoring and review of local plans.
CAA: Recommend that the first sentence is replaced as follows: 'Demographic forecasts and consequential housing land requirements must be monitored on a regular basis''.
CEC: The guidance includes house prices as means of monitoring for circumstances which will lead to the release of future phases of housing land. This raises concerns as the level of house prices is determined as much by interest rates as by local demand and it could therefore be difficult to separate the two. Also, a policy that specified a certain level of house prices would quickly become outdated and one that referred to a rate of change would risk being over-complicated.
ELC: Example of infrastructure accepted that the relationship between house prices and land supply is most certainly not a direct one. It is influenced as much by the economics of interest rates and wage levels as it is by planning factors. No justification is given for its inclusion and this reference should be removed.
GCC: Introduces the concept of house price increases as a measure of change in demand and bringing forward land release on that basis. PAN 38 (paragraph 17) also includes house prices as a factor to consider in assessing housing demand. This is a significant issue that requires further justification than is provided and, given the lack of an agreed methodology, requires further research and discussion.
GCVSPT: Suggests that house price increases can be used as a measure of change in demand and as a basis for making land release. It is however clear from the consultation on the Glasgow and Clyde Valley Plan there is no agreed methodology on this issue. There is a danger that it could be used to merely reinforce further releases of green belt land by focusing upon inevitable differential price changes in localised areas. This factor should be dropped or expressed in a way that will not undermine the plan led system, for example in terms of the national relative position of the Housing Market Area as a whole.
HC: The importance of careful and regular monitoring is emphasised but needs to be a more integral part of planning for housing and carried out to a consistent national standard.
MLC: It is not agreed that increases in house prices should provide the basis for additional housing land releases. Aside from house price being an extremely variable factor, the correlation with demand is not clear-cut.
RICS: It is important to carry out effective monitoring in order to take account of any changes in the market place, i.e. to identify if more land is needed to take account of changes such as new job creation. The guidance in paragraphs 70 and 71 is particularly relevant in this respect. Essentially, a "rectification" process is vital. Monitoring is also required to ensure that allocated sites are being developed. Once sites have been identified in the local plan, it is important that they are delivered during the period of the plan. Many local authorities have been criticised in the past for simply allocating land as opposed to bringing it forward for development.
SLC: The use of house price increases, as a measure of change in demand is dangerous since it may focus on specified localised areas and result in further releases of greenbelt land.
SMH: Add in 'publicly transparent' before 'capacity studies' in the last line.
SSDP: The reference to the use of changing house prices as a measure of demand, on which additional land release might be based, requires further research and discussion prior to its being included in national guidance. More research is required to find new mechanisms to determine housing supply land.
WDC: States that the development plan should be capable of responding to demand, and cites a significant increase in house prices as being a trigger for the release of additional land, without specifying how this trigger will work. This should only be relevant to the HMA as a whole, and over a reasonable timescale.
WG: No minimum period is stated for monitoring. Suggest it should be at least every two years.
Paragraph 71
AC: The recognition that alterations to the housing elements of plans may be necessary is welcomed. Support should be given for the use of expedited plan procedures to ensure that this process is not bogged down and devalued by procedure.
ACC: States if development plan progress doesn't keep up with the need for land, planning permission should be granted in advance of local plan adoption if proposals comply with other plan policies. This could be problematic in demonstrating openness of the decision making process.
States that account should be taken of the need for affordable housing as identified in the local housing strategy, but more advice is required on the mechanisms for achieving the required amounts of affordable housing
BH: For clarity, delete, 'requirements are met' and replace with, 'the requirement for at least a 7-year supply of effective land is met in full'.
Green belt boundaries are inflexible and would not permit development in this instance prior to local plan review. Delete, 'other policies', replace with 'policy objectives'.
CALA: Delays and prevarication on behalf of LAs in preparing local plans is no longer acceptable and the guidance in this paragraph is welcome.
ELC: The inclusion in development plans of a mechanism whereby planning permission for housing can be granted in advance of Local Plan adoption is supported. The NPPG should be specific about the circumstances where this is appropriate.
GCC: This is consistent with the Executive's Draft Modification 41 of the 2000 Structure Plan, in that it allows local authorities to grant planning permission in advance of local plan adoption in order to meet the Structure Plan requirements for housing land. The final version of NPPG 3 should be more explicit in setting out the circumstances in which such consents could be granted
HFS: Welcomes the recognition in the first sentence of the need for alterations to the housing elements of development plans in the light of the guidance given in paragraph 68. It seems to us, however, that there will be very few, if any plans which do not require alteration in this respect. Therefore, suggest that, for the avoidance of doubt, the first sentence should be amended to read "Alterations to the housing elements of plans should be prepared as quickly as possible to ensure that the requirement for at least a 7-year supply of effective land is met in full." In addition we would suggest that the words "other policies of the development plan" (line 7) be replaced with the words "policy objectives".
In the interests of clarity, a sentence should be added at the end of paragraph 71, to read "The total requirement for land for affordable housing should be shown separately from that for mainstream private housing ."
MLC: Suggest replacing the text as follows:
"It is critical that housing land is brought forward quickly enough to meet requirements. If shortfalls in the 5- year effective supply of housing do arise, then planning permissions may be granted in advance of local plan adoption provided that the proposals do not prejudice the objective of securing a coherent and sustainable development pattern in line with this guidance. In circumstances where structure plans rely upon windfall as a component towards meeting housing land requirements, account should also be taken of the likely provision from that source over the 5-year period under consideration. Predictions of windfall should be based on robust analysis, including assessment of urban capacity. The housing requirement…"
M&M: Delay and prevarication on behalf of local authorities in preparing local plans is no longer acceptable and the guidance in this respect the paragraph is welcome.
OHA: Support this Paragraph
PH: Recognises the fact that the housing elements of plans do not always keep up with the requirement to maintain a 5-year supply never mind a 7-year supply. Should a 7-year supply become the norm it should be met in full rather than local authorities relying upon planning consents being granted in advance of local plan adoption.
RH: Delay and prevarication on behalf of local authorities in preparing local plans is no longer acceptable and the guidance in this respect the paragraph is welcome.
SMH: Agree that the need for affordable housing should be identified through the Structure Plan in order to avoid the ridiculous situation whereby the need for affordable housing can be greater than the overall requirement as is currently the case in East Dunbartonshire for example.
SS: Affordable housing simply appears to be tacked on to the end of section on delivering housing land. It merits more than this.
WDC: It is unrealistic to suggest that the housing requirement assessed through the structure plan should also take account of any need for affordable housing, as identified in the local housing strategy, given the different emphasis and timescale of each document.
Local housing strategies and housing market context statements
Paragraph 72
CAA: Strongly support the direction to LAs to develop their strategies in partnership with others, including the voluntary sectors and communities.
CLACK: Housing land supply and housing needs are to be agreed. What is to be done when agreement cannot be reached? Does the Scottish Executive mediate an amicable and timeous resolution of matters relating to land supply, types of housing and locations required? This is particularly sensitive when considering the potential input from "windfall" sites. Welcome that the importance of the wider community involvement is stressed and authorities must ensure all stakeholders have equal consideration in the planning process.
D&G: The requirement that the Local Housing Strategy should include an assessment of need and that this should inform the Development Plan is also a significant change. This will require closer corporate working between the Local Housing Strategy and the Development Plan.
EDC: Links to housing strategies provides useful guidance. Local housing strategies (LHS) are welcomed as they indicate clearer relationship between the preparation of Local Plans and the need to take LHS into account within the local planning process
FMB: The construction industry is facing a severe skills shortage. LAs should be encouraged to stipulate that, as a condition of development on new housing sites over a certain size, craft training be required to be undertaken by developers. The "Planning Gain" for the local community would be the maintenance and nurturing of craft apprenticeships in their area.
GCVSPT: The corporate approach is welcomed as it will help to avoid possible inconsistencies in the housing data, and demand projections and assessments used within local authorities, particularly at public inquiries. In this context it is considered important to ensure that the primacy of the development plan is explicitly made in the guidance and advice related to housing land but also in the finalised guidance on the preparation of LHSs.
HCC: Mentions partnership with communities in developing strategies but the detailed procedures underplay it.
KE: Too much faith is put in the worth of the housing market context statements which, as guidance to LAs, completely fails to identify the private rented sector (PRS) as one of the main means whereby authorities might tackle their housing problems. The PRS is dismissed as being 'relatively small' and 'not well understood' - and is therefore ignored. This despite the fact that the PRS is larger than the RSL sector and the fact that SH Report No. 83 identified a great deal of worthwhile information about the rural PRS and landowners willingness to participate in providing affordable housing.
- Suggest that the NPPG refer to SH Report 83 as a reference in this section.
- Reference ought also to be made to the report of the National Steering Group of the Rural Partnership for Change. (NSG of the RPfC). That report made a number of recommendations about housing which are relevant to the NPPG.
Another important point is that there is no guarantee that the devolution of expenditure from central government to Local Authorities under the Housing (Scotland) Act 2001 will actually permit LAs to direct expenditure as they see fit. At present there is a government order that the PRS should not receive grant aid for development expenditure despite the fact that the PRS can deliver affordable housing more cost effectively than other means in some areas. Unless this situation changes LAs will not be able to work with the private sector as effectively as it otherwise could.
RC: Although the recommended corporate approach between housing and planning is to be welcomed, there is insufficient guidance that fully explains how Local Housing Strategies (LHS) should relate to development planning.
SBC: The role of local housing strategies in the identification of need, and the use of housing needs assessments to underpin them, is recognised and supported. However, there is a concern that the resource implications for local authorities, of the effective delivery of local housing strategies, have not been fully appreciated.
SLF: The paper should emphasise the need to ensure engagement of the private and the voluntary sectors as at present there is a very regrettable tendency to ignore them.
SPEOC: Refers to local housing strategies 'covering all tenures and the range of community needs' but makes no specific reference to the need to take into consideration the requirements of communities of interest within local communities. This is of particular concern in respect of people with disabilities and their need for adapted or barrier free properties.
SSDP: The link to Local Housing Strategies and the ability of having confidence in infrastructure providers investment plans should also be made clearer.
WLC: The link between Local Housing Strategies and development plans is supported.
Paragraph 73
BH: Update paragraph at point of publication of finalised NPPG3. Concerned that LHS are prepared outwith the statutory planning process, yet will be adopted verbatim without the opportunity for scrutiny at the Local Plan Inquiry. SEDD to consider ways in which the LHS can become more accountable, including consultation and agreement with Homes for Scotland.
SLF: The marginal note should include reference to the Scottish Homes and Scottish Executive Housing reports.
WG: Indicates that new guidance is emerging on local housing strategies and a perusal of the document referred to appears to indicate that this will also be allied with guidance on the housing needs assessments on which the strategies are based. Such latter guidance is badly needed.
Paragraph 74
AC: The issue of the relative weight that can be afforded to LHS should be promoted. Concern is expressed that Local Housing Strategies may not be able to deliver all that is being asked of them, lack public consultation, may hold less weight and are consequently less defensible than the development plan.
ACC: It would seem more appropriate to tie in the five year Local Housing Strategies with a 5 year supply of land which is effective or agreed as likely to become effective housing land requirement.
CALA: Housing needs assessment will evaluate the housing requirements of a community across all tenures. These should be clearly stated and calculated at a local level as detailed in this paragraph.
CLACK: It will not likely be possible for Clackmannanshire to plan or assess the market to settlement level, so an alternative spatial context will require to be applied. The industry is required to agree to the authorities' assessments and analysis and there is a threat that authorities may be toothless tigers acting in an enabling role. There is potential difficulty, when considering the requirements for providing "affordable housing" based upon local housing assessments and strategies.
ECA: Comments apply re paragraphs 29 and 60
ELC: The guidance is light on the practical implementation of Local Housing Strategy guidance.
GCC: The need for a corporate approach is acknowledged, but there needs to be greater clarity in the guidance on the respective roles of the development plan and the LHS in the assessment of housing needs. Paragraph 66 refers to the development plan being the main vehicle for assessing housing land requirements, but elsewhere in the guidance there are references to development plans being informed by the needs assessment in the LHS. It would be appropriate for the LHS to take the lead in, for example, the assessment of housing needs in the social rented sector generally, community care needs and requirements for subsidised affordable owner occupied housing. However, the assessment of overall demand in the private sector can only be considered in the context of the wider housing market area and in relation to the likely pattern of physical development and it is appropriate that this should remain part of the development plan process.
M&M: Housing needs assessment will evaluate the housing requirements of a community across all tenures. These should be clearly stated and based at a local level as detailed in this paragraph.
PH: States that local housing strategies will cover 5 years. Should this not be revised to 7 years to tie in with the 7 year effective land supply?
PKC: Close linking with development plans will be essential if local housing strategies are to be implemented effectively, although the differing time-scales for the two sets of plans may cause some difficulty in achieving this.
RC: The LHS requires to consider all tenures, but Housing Departments are not responsible for overall settlement strategies, nor are they responsible for allocating land for housing.
At present the 5-year period for the LHS and the period covered by any owner-occupied requirement identified in a Structure Plan could be completely different, as there is no requirement to relate them. It is strongly recommended that the specific roles and responsibilities of the two documents be more clearly defined, together with their relationships to each other.
RH: Housing needs assessment will evaluate the housing requirements of a community across all tenures. These should be clearly stated and based at a local level as detailed in this paragraph.
RICS: Concerned to note inconsistency between time periods of local housing strategies and the forecast for housing requirements in the Local Plan, both should be for a period of 7 years.
SBC: The link between local housing strategies and affordable housing provision is noted.
SLF: Timescales need to be integrated.
SMH: A LA's local housing strategy is not subject to anything like the scrutiny which development plans must pass before they are adopted. In that respect, local housing strategies should also cover a 7 year, not 5 year period, in order to facilitate "joined up" thinking and the opening line of the paragraph should be change accordingly.
WDC: The relationship between the local housing strategy (LHS) and the development plan must be clarified. This paragraph states that LHS will cover 5 years and address the need for housing in all tenures. This is contradictory to earlier statements in the NPPG that the development plan will produce housing land requirements. The Structure Plan and the LHS have differing emphasis and timescales - it will be necessary to ensure that these documents do not contradict each other, but the degree to which they will be able to inform each other may be limited.
Paragraph 75
SW: The proposed housing market statements from Communities Scotland would also provide useful market information.
Paragraph 76
AC: Clarification should be made as to whether reference is being made to Housing Market Areas (HMA) or Housing market types. There is a significant difference between consideration of housing land requirements for different housing markets (i.e. affordable, luxury etc) and requirements within a HMA While "house type" represents a very useful indicator in the monitoring of housing issues we would be very uncomfortable with any attempt to plan for market segments at a strategic level. Clarification should also be made as to whether the reference is being made to the Local Housing Strategy or to local housing policies.
SBC: The requirement for local housing strategies to recognise the fact that housing market areas do not respect local authority boundaries is noted.
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