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Annex C - Housing Land Audits
INTRODUCTION
1. Planning authorities should carry out regular monitoring of housing completions and the progress of sites through the planning process in order to demonstrate the availability of land to provide an ongoing effective supply to meet the identified housing land requirements. This can be achieved through the preparation of an audit of housing land, carried out annually by the planning authority involving housing and infrastructure providers.
2. This Annex sets out advice on good practice in the preparation of housing land audits. It replaces PAN 38 Housing Land (Revised 2003). Its purpose is to promote greater consistency and transparency in content of audits and the way in which they are carried out. An annual audit will be particularly important in urban housing markets particularly where housing markets are buoyant and would benefit from a more responsive housing land delivery mechanism; in remoter rural areas where the requirement is of a more limited scale, the method and frequency of the audit process should be adapted to local circumstances.
3. The main text of SPP3 sets out the key stages in the process of identifying the housing requirements and the provision of an appropriate land supply to accommodate those requirements through the Scottish Housing Need and Market Assessment guidance, Local Housing Strategies and the development plan.
Research
4. Scottish Ministers are committed to ensuring a sufficient supply of land for housing, and recognise the value of systematic collection of statistics to indicate whether planning authorities are identifying and delivering sufficient land for housing. In order to better understand the usefulness of housing land audits in providing this information and the quality of the data collected, The Scottish Government commissioned research into monitoring housing land supply through housing land audits. A research report entitled The Effectiveness of Housing Land Audits in Monitoring Housing Land Supply in Scotland is available on The Scottish Government website .
5. The research has assisted in identifying scope for a more standardised approach to the audit process across local authorities in Scotland, and ways in which the value of the audit process can be maximised. Where appropriate the research findings have been incorporated into the draft revised SPP3.
HOUSING LAND AUDITS
6. Annual audits of the housing land are the established means for monitoring housing land, they have two key functions: to demonstrate the availability of sufficient effective land to meet the strategic housing land requirement for a minimum of 5 years ahead; and to provide a snapshot of the amount of land available for the construction of houses at any particular time. This information is vital to the preparation of the development plan strategy for housing and the audit process enables adjustments to the supply to be made in response to issues identified.
7. Housing land audits should also be recognised as providing a valuable source of information for a variety of purposes both for the local authority and a wide range of other organisations. The Government intend to use the collected information to monitor the amount of land being made available for house building and to measure progress towards the aspirational goal of increasing house building in Scotland to at least 35,000 houses per annum by the middle of the next decade as set out in Firm Foundations, published in November 2007. It is also intended to use data from annual audits to review the level of affordable housing being built countrywide. Communities Scotland and Homes for Scotland (HfS) have indicated their support for housing land audits and their willingness to contribute to them. It is likely that the data will also be of value to other organisations such as Transport Scotland and Scottish Water, and other bodies who plan their resource requirements and investment decisions with regard to areas of housing development, ie medical services and the post office. Local authorities are encouraged to consult widely with the industry and infrastructure providers in the collation of the annual audit to enhance the accuracy of the data and thus the usefulness of it. Relevant organisations who are likely to find value in the audits should be willing to contribute to their preparation and this should help to promote a shared understanding of the land supply among all interested parties.
8. It may be beneficial to have contributions from local housebuilders and landowners regarding their sites included in the audit particularly in relation to whether or not the site is effective and the likely annual completions on that site. This may be of particular value where HfS members are not the primary builders in an area. Local authorities and others should consider how such involvement can be sought, either through direct contact or through adverts in the local press inviting input from relevant parties.
9. Audits provide a snapshot picture in time of the land supply. Involvement in the preparation of an audit should not be viewed by contributors as an alternative means of commenting on the housing land allocations in the development plan.
10. The usefulness of the housing land supply information in audits will be enhanced through audits across Scottish Local Authorities containing common information about the land supply in their areas, this could perhaps be assisted by the establishment of a working group to provide opportunity for discussion and sharing of ideas. Whilst desirable, it is not considered necessary for audits to be carried out at the same point in time each year however, an annual picture of land supply across Scotland will be valuable. It is recognised that audits do provide a snapshot picture of land supply and it is desirable that the audit is available within a reasonable period of time, preferably within 6 months of the collation of the data.
11. It is recognised that the way in which authorities work to produce audits may need to alter to reflect their participation in housing market partnerships and strategic development planning authorities and that additional resources may be necessary to support the preparation of enhanced audits. Agreement of relevant organisations to participate and provide timeous responses to consultation, and adjustments to the Government's requirements for statistical returns would contribute to minimising the additional burden on local authorities and this should be considered against the improved value of the collected information.
Methodology and Content
12. A housing land audit should contain relevant information about the established and effective housing land supply allowing for monitoring and comparison with the housing land requirement. The starting point each year will be the inclusion of:
- all land with planning permission for residential development, including the remaining capacity of sites under construction;
- land allocated for residential development (including the residential component of any mixed-use development) in adopted local plans; and
- other land with agreed residential potential, such as land identified in draft local plans or an urban capacity study.
13. Audits should contain information including the site address, area, capacity, the planning status of the site, annual completions. They may also include information relating to the greenfield or brownfield status of the land, whether it is a windfall site, and the type of housing being provided.
14. It is good practice to ensure that individual sites can be readily tracked from one audit to the next until such time as development is completed. If the audit is to provide an accurate picture of housing land supply, it will be necessary to ensure that the annual completions are accurately recorded and shown in the audit, including the residential component of mixed-use developments and the unplanned contribution to the housing supply made by windfall sites and conversions. Completions on regeneration sites should be shown net of any demolitions which have taken place. All sites finally completed in any year should be listed in a separate schedule and a comprehensive table of historical annual completions should also be provided.
Effective land supply
15. Not all of the sites in the audit will be effective, and it is important that the audit distinguishes effective ie unconstrained sites, from those which are affected by constraints which cannot be overcome in the short term. The decisions and assumptions around effectiveness and programming make a significant contribution towards the accuracy and usefulness of the data in the audit and therefore merit careful consideration.
16. The effectiveness of individual sites should be determined by planning authorities in the light of consistent interpretation of the following criteria and through discussions with housing providers. To assess a site or a portion of a site as being effective, it must be demonstrated that within the period under consideration, the site can be developed for housing (ie residential units can be completed and available for occupation) as it will be free of each of the following types of constraint:
- ownership: the site is in the ownership or control of a party which can be expected to develop it or to release it for development. Where a site is in the ownership of a local authority or other public body, it should be included only where it is part of a programme of land sales;
- physical: the site, or relevant part of it, is free from constraints related to slope, aspect, flood risk, ground stability or vehicular access which would preclude its development. Where there is a solid commitment to removing the constraints in time to allow development in the period under consideration, or the market is strong enough to fund the remedial work required, the site should be included in the effective land supply;
- contamination: previous use has not resulted in contamination of the site or, if it has, commitments have been made which would allow it to be developed to provide marketable housing;
- deficit funding: any public funding required to make residential development economically viable is committed by the public bodies concerned;
- marketability: the site, or a relevant part of it, can be developed in the period under consideration;
- infrastructure: the site is either free of infrastructure constraints, or any required infrastructure can realistically be provided by the developer or another party to allow development; and
- land use: housing is the sole preferred use of the land in planning terms or if housing is one of a range of possible uses other factors such as ownership and marketability point to housing becoming a realistic option.
17. Programming of sites is an important element of the audit. Programming is an indication of the expected annual completions on each site taking account of the lead-in times, the capacity of the builder to develop the site, and the capacity of the local housing market. The housing land audit should show the expected completions on sites over the following 7 years. The contribution of any site to the effective land supply is that portion of the expected output from the site which can be completed within the period under consideration. It will be important that the programming is also related to the expected timing of housing land allocations in the local plan.
18. Programming is widely recognised as a less than scientific exercise, however it is important that assumptions do not overestimate the likely completions as the audited effective supply forms the basis for the calculation of the additional housing land requirement to be provided through the development plan. Overestimation of the potential of the effective supply would reduce the amount of additional land allocated and therefore reduce the flexibility available in the supply to address market fluctuations and other constraints to the delivery of housing. Realistic programming will demonstrate the continued availability of sites to maintain a five year supply and help to monitor whether sufficient sites are available to continue to meet the housing land requirement. It will also show whether the supply includes a sufficient range of sites to meet the varying requirements of different parts of the housing market.
19. Planning authorities should use the information from the audit process to ensure that at all times sufficient effective land is available to meet the housing land requirement for at least the following 5 years. Planning authorities, housing and infrastructure providers should work together to ensure that sites identified as effective are successfully developed within the expected timescale. Where constraints arise or funding commitments necessary to delivery of the site are delayed the status of the site should be reviewed as part of the next housing land audit.
Q7: Does "the period under consideration" require a definition?
Non-effective or constrained sites
20. Where sites which form part of the established housing land supply are identified as non-effective the audit should identify the nature of the constraint and the necessary action and time required for resolution of the constraint to allow house building. Again, planning authorities, housing and infrastructure providers should work together to ensure constraints inhibiting the development of sites are timeously removed. In a small minority of cases it may prove impossible to remove development constraints. Where this occurs, the site should be removed from the audit of housing land supply.
Land with agreed potential
21. Land with agreed potential includes any land which is not formally identified in an adopted local plan or which does not have planning permission. It can include sites identified in draft local plans, or in urban capacity studies. Careful consideration should be given as to whether to include such sites in the audit, although inclusion will not pre-empt subsequent consideration of the status of the site by the planning authority when finalising a development plan or determining a planning application. If a site is ultimately rejected by these processes, it should not be included in the next audit.
Small sites
22. It is for planning authorities to consider how to take account of the expected contribution of small sites ( i.e. sites capable of accommodating up to 4 houses) towards meeting the housing land supply through their development plans. Completions on small sites make a significant contribution to the land supply in some local authority areas and may be regarded as providing flexibility in addition to the supply on sites of 5 or more expected to meet the housing land requirement. For the purposes of auditing the contribution of these sites, there may be practical difficulties in identifying the each small site separately, and authorities may conclude that an aggregated figure should be included in the audit.
Windfall sites
23. Windfall sites arise unexpectedly and are by definition not part of the planned housing supply. These are opportunities for new housing involving the reuse or redevelopment of previously developed sites. They should only be included within the housing land audit once planning permission has been granted for residential development, and thus can only be regarded as effective at that stage. In order to allow planning authorities to monitor the contribution of windfall sites to the housing land supply in their area these sites should be differentiated in the audit. SPP3 refers to how planning authorities may consider the contribution of windfall sites to the overall housing land supply.
Affordable housing
24. The categories of affordable housing are set out in SPP3 and PAN 74; housing land audits should reflect these definitions to distinguish between affordable housing sites and completions, and private market housing. The Scottish Government is monitoring the number of affordable housing units securing planning consent in each local authority and have initially collected this data through a survey. It is proposed that if this information could be provided through the annual housing land audit, along with information on affordable housing completions, there may longer be a requirement for a separate return.
House types
25. A potential further development of the audit would be the collection of information on house types, in particular separating houses, flats and sheltered accommodation. This may be of assistance in demonstrating how well the supply matches the identified housing needs which emerge from SHNMA and the LHS. It is likely that it will be easier to collect this data in relation to completions as it is recognised that as sites are being planned and developed proposals can often change.
Availability of housing land audit information
26. Most housing land audits are available in electronic format and can be accessed online this provides opportunity for ease of reference and consultation, and reduces the costs associated with making the information available. This is particularly beneficial given the broad interest and value in the information they provide. All authorities are encouraged to progress towards making audits available online.
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