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2. HOUSING LAND AUDIT BASELINE INFORMATION

Introduction

2.1 This chapter details the information collected from our analysis of baseline HLA information provided by consultees (see paragraphs 1.11 - 1.16). Although a few conclusions are drawn in this section of the report, Chapter 3 considers the main issues arising from this analysis.

Engagement Between Councils

2.2 A principal function of the HLA is to monitor performance of the housing land supply against the Structure Plan housing requirement. Some individual Council areas (e.g. Perth & Kinross, Scottish Borders, Dumfries & Galloway) are directly aligned to Structure Plan areas, and so there is no need for collation of information between Councils to establish this performance. The majority of Structure Plans, however, include more than one Council areas. In these circumstances, there are different approaches to the collation of information between Structure Plan areas. For example, North East Scotland Together (Aberdeen and Aberdeenshire Councils) have a fully conjoined approach to preparation and collation, with a single team responsible for the output. Stirling and Clackmannanshire Councils, on the other hand, prepare and compile their audits independently. For Glasgow & Clyde Valley, although the eight Councils involved prepare and publish their HLAs independently, the information is subsequently compiled into an overview of the land supply in the Structure Plan area and housing market areas by the joint Structure Plan team. The various approaches are described in more detail in Appendix 3.

Date of HLA Baseline

2.3 Each HLA is prepared as a 'snapshot' of the land supply position at a particular date. Appendix 4 indicates the current base dates for Scotland's audits. These dates vary between Councils and it is therefore not possible to collate information for a common base-date at a national level.

Timeframe for HLA Review

2.4 There are significant differences between Council areas in the time taken to review the HLA and finalise an updated version, as identified in Appendix 4. A few HLAs are completed in 3 - 4 months, and a further few within 6 months. The majority, however, take longer than 6 months, with a significant number taking 9 - 12 months.

Consultation on HLAs

2.5 Appendix 5 lists the agencies consulted by Councils as part of the HLA preparation process. It is apparent that there is some variation between Councils in the extent of this consultation. Homes for Scotland is consulted by all Councils, although the extent of its role varies. In some cases it acts as the conduit for information to be passed from its members to the HLA team. However, most Councils also seek programming information from individual house-builders, albeit there would appear to be significant variation in the comprehensiveness of this exercise. From our discussions with HLA teams and Homes for Scotland (See Appendix 1 for their comments), there is a common view that in many areas the information provided by house-builders is inadequate, and that HLA teams themselves must assess effectiveness and programming.

2.6 Most Councils consult with Communities Scotland ( CS) in order to establish funding programmes for affordable housing. The following summarises CS comments on current practice:

• Involvement in the HLA varies across the country, and there would be merit in adopting a more consistent approach. CS would prefer to be involved at the draft stage, to allow the feeding in of information, which is not always the case.
• Information on the type and size of residential unit would be particularly useful, but this is not often provided.
• Information could be usefully included on issues that are likely to restrict the capacity of sites and any development constraints. Highlighting sites which are being actively marketed would be useful. The CS experience is that not all Council owned sites identified in HLAs are being actively marketed.
• It is recognised that HLAs should be produced within a shorter timeframe. Any prescribed timeframe arising from the research should be achievable and supported by Councils and developers.
• For affordable housing, CS would like to clearly measure delivery against development plan and LHS assumptions.

2.7 Scottish Water ( SW) is consulted by most Councils, and has provided the following comments on the HLA process:

• SW uses the HLA to help understand the build out rates of development and thereby align investment plans. It also identifies windfall sites not specified in the Local Plan.
• SW is committed to detailed involvement in the HLA process. At present, input varies across Councils from pre-publication consultation, working reviews, formal consultation, one to one meetings and tri-partite meetings with other agencies.
• Generally, HLAs are easy to use, although there can be confusion over the cause of constraints.
• HLAs are not produced quickly enough.
• Too much information in the HLA may make it too complex to interpret.

2.8 The Royal Institute of Chartered Surveyors ( RICS) is not consulted by any Councils. Its comments are summarised as follows:

• HLAs have the potential to be a very useful tool in ensuring sufficient land is made available. There is concern that the process of producing audits is too slow and reports can be out of date by the time they are published.
• The RICS would welcome an independent (from Council planning policy teams) system of production, but recognise possible cost implications.
• HLAs and the development plan should be better linked. There is concern that with plan reviews taking 2 - 3 years, there is little scope for action when an audit reveals a land supply problem.
• The approach in West Lothian is welcomed, which programmes a surplus of sites to ensure adequacy in the supply.
• HLAs seem to over-estimate the future housing supply, leading to shortfalls. The problem could become more critical as there is a move towards fewer larger sites where infrastructure provision may be a challenge. Infrastructure providers should be fully engaged in the audit process.

2.9 Most of the Councils and house-builders consulted consider that the involvement of SW is inadequate, partly because it does not usually seek to comment on the detail of the HLA but instead views its role as a strategic one.

2.10 Most Councils consult with internal departments e.g. education, estates and transportation, although a number have indicated that the quality of the response is variable.

HLA Compilation Methodology

2.11 A summary of the approach taken by each HLA area is provided in Appendix 6. There are two main components to HLA preparation which are common to all Councils' approaches:

• Assessing house completions on existing HLA sites and establishing the remainder at the base date.
• Adding new sites to the HLA, usually resulting from new planning permissions granted and new sites emerging through the development plan process.

2.12 However, there are differences in the detail of the various Councils' preparation methodologies, and these are referred to throughout this report. At this point, it is worth noting that there are a variety of approaches to counting house completions. In some areas it is purely a desk-top exercise, using Building Control completion records. However, most Councils consulted for this research project indicate this information can be inaccurate, and at least some site visits are required. It is this study's understand that Building Control completion records are of variable reliability depending on the Council area, and it should therefore probably be the responsibility of individual Councils to decide whether or not a purely desk-top assessment is sufficient within this context.

Approach to 'Small Sites'

2.13 Appendix 7 indicates the approach taken to small sites in HLAs. At present Councils do not define small sites consistently, some defining them as less than four houses, and others as less than five houses. Most HLAs present only summary information for small sites. In a number of HLAs, agreement with Homes for Scotland has been reached that only a proportion of small sites (e.g. 50%) will be effective. This agreement is usually based on the fact that planning permissions for small sites are quite frequently not implemented.

Programming Period

2.14 PAN38 requires the HLA to indicate the yearly future programming for a period of at least 7 years. As indicated in Appendix 8, a significant minority of HLAs only provide a 5 year programme.

Affordable Housing

2.15 The approach of HLAs to affordable housing is identified in Appendix 9. A significant number of HLAs do not distinguish affordable housing from other types of housing. Of those that do, there is inconsistency in the definitions. The issue of Affordable housing is addressed in more detail in paragraphs 3.48 - 3.49.

Housing Type

2.16 Only three HLAs (Lothian, Stirling and North East Scotland Together) distinguish between houses and flats. No HLA includes information on house size ( Appendix 9).

Conclusions

2.17 From the above analysis it is clear that there are a number of different approaches employed by Scottish Councils in the preparation of HLAs. As will be described in Chapter 3, this raises a number of issues which bear upon the stakeholder engagement process, predictive accuracy and the ability to effectively monitor housing land supply at the local and national level.

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