Strategic Housing Land in Central Scotland
With the publication of two Strategic Development Plans (SDPS): SESplan (South East Scotland) Examination Report in July 2018, and, the adoption of Clydeplan (Glasgow City Region) in July 2017, this review highlights what key implications both SDPs will have on the future of strategic land across central and south east Scotland. Particular attention is focussed on housing supply targets (HSTs).
One of the most important issues for strategic land as a result of these SDPs is the now reduced HSTs across both plan areas. Compared to the HSTs set out in the first round of SDPs, both plans are now much less ambitious due to, i) a lowered growth scenario calculation in the HNDA 2015 (base year 2012) in Clydeplan; and, ii) an extended plan period by 6 years to include under delivery from the first SDP (i.e. also calculated from 2012) in SESplan. Regarding SESplan the overall HSTs did in fact increase, which is positive, however translating these figures into the now extended time period has not helped housing numbers. The inclusion of under delivery from 2012 into HSTs means that for SESplan authority areas, with the exception of Edinburgh City Council, all now generally have over 5 years effective housing land supply.
Regarding Clydeplan, calculating the HST was subject to multiple factors, from environmental and social factors, to the availability of resources and recent development levels. Clydeplan used these factors to justify the ‘more modest’ (lowered) growth scenario, making negative adjustments to the social sector figures and transferring these figures to the private sector, creating a reduced all-tenure HST (with the assumption that affordable housing would be delivered by the private sector). Private sector figures were also adjusted in order to better reflect the under-delivery of past completions as the previous HST was not met from 2012 – 2017. Ultimately the HSTs in Clydeplan is now lower than the level of anticipated growth for each local authority area, resulting in this reduced HST figure. As for addressing under delivery in SESplan, at examination the Reporter offers some clarity on the issue stating that previous completions should be factored in when calculating supply (again, starting from 2012). Based on the new HNDA figures for SESplan, completions have largely been in line with the HNDA targets resulting in very little or no under delivery of completions. This has reduced overall housing supply figures in all Council areas apart from the City of Edinburgh.
Both SDPs also iterate a focus on improving housing delivery across all tenures, this raises another relevant issue of the amount of land required to deliver housing. In both SDPs this is largely to be met through existing allocations (at local level through the assessment of LDPs). In SESplan this will also be met through review of the Green Belt. The examination of SESplan acknowledges that in the future Green Belt land will need to be released in order to fulfil housing targets. This release of land would only be considered if accompanied by strong supporting evidence that demonstrates the need, and again, subject to review at local authority level. With Clydeplan, as a result of the lower HSTs, the housing land requirement has also been lowered. This means that there is only, at present, a small number of new allocations identified to meet HSTs. The effectiveness of large legacy sites is therefore called into question as most of these larger sites have been allocated throughout the period of under delivery (2012-2017).
HSTs being met through existing allocations is slightly concerning as, mentioned above, many of the LDPs have large legacy allocations which have struggled to come forward and have been in LDPs for many years. This, combined with reduced HSTs, offers very little opportunity for departure applications across both SDP areas. Another concern is the future of SDPs as the Planning (Scotland) Bill looks to take away their future role and purpose. Although the abolition of SDPs is a concern, the HSTs in the current SDPs are likely to continue to guide housing land supply figures even when and after these have been abolished.
The emphasis of the Scottish Planning Policy (SPP) requirement that there should be a five-year effective housing land supply at all times is one of the positives that comes from the revised HSTs in both SDPs. It has now been made clear that any shortfall or under delivery which arises must be made up over the next 5 years and not in the remaining lifetime of the plan. In order to address this, under delivery needs to be dealt with as soon as possible to ensure that future housing growth is not undermined. Strategic land promoters can help address this by working with landowners and Councils to help non-effective/stalled sites in the LDP areas become effective, i.e. through supporting infrastructure delivery, by monitoring the programming of established sites in the relevant HLAs to argue the non-effectiveness of sites, and promoting new and alternative sites to deal with any shortfalls which arise. Ultimately with the strong policy focus on delivery apparent in both SDPs, realising the opportunity associated with under delivery may be the answer in assisting the continued effective housing land supply across central and south-east Scotland.