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Committee Reports and Agendas
May 2007 to Present
 | NORTH AYRSHIRE COUNCIL The Executive of North Ayrshire Council |
| Agenda Item 3 11 March 2008 |
| Subject: | Scottish Planning Policy SPP3 - Planning for Housing Consultative Draft |
| Purpose: | To seek agreement to a response to the Scottish Government in respect of the consultation on Scottish Planning Policy 3 - Planning for Housing. |
| Recommendation: | That the Executive agrees (a) to the terms of this report; and (b) that the report be sent to the Scottish Government and COSLA as representing the Council's views on the Consultative Draft of SPP3 - Planning for Housing. |
1. Introduction
- 1.1 A Consultation Paper on Scottish Planning Policy 3 - Planning for Housing (SPP3) has been received from the Scottish Government. Written responses are invited by 31 March 2008.
1.2 SPP3 was published originally in February 2003 and provides direction to planning authorities on the provision of sufficient land for housing in the right places through the planning system, and on related qualitative issues such as housing design and layout, density, open space provision, energy efficiency and the creation of mixed communities. The Scottish Government's view is that SPP3 is not operating as effectively as had been hoped and the aim of the revised SPP3 is to place greater emphasis on the "generous release" of land for housing in local authority development plans. The document states that stakeholders involved in the provision of housing have indicated that the absence of an adequate land supply is a major impediment to the provision of new housing in Scotland. The document recognises, however, that delivery of housing does not just rely on allocation of appropriate land but on other factors. This policy initiative reflects the national goal of 35,000 new houses per year by 2015, set out in the Scottish Government housing policy document Firm Foundations: The Future of Housing in Scotland, compared to a current total of approximately 25,000.
2. Current Position
2.1 The Draft SPP sets out core principles to establish and meet need and demand and seeks integration between local housing strategies and development plans, as well as links with the Community Planning process. It is intended that the revision will provide comprehensive guidance that relates to the assessment of housing need, the identification of suitable land and the delivery of the right houses in the right places as an integrated process in a way that the current SPP3 does not. It is not, however, clear on how these principles and processes can be introduced without impacting on the timescales for preparation of new Strategic and Local Development Plans. More guidance is promised. Additionally, the revised SPP3 will include guidance on other elements of planning and housing as annexes, including guidance on Houses in Multiple Occupation (HMOs) and housing land audits (currently provided by PAN38).
3. Proposal
3.1 The main changes are proposed co-operation on a regional basis in housing market partnerships to set and deliver targets, the identification of housing need and demand on a more consistent basis across all tenures to reduce disputes over methodologies, increasing the amount of land allocated for housing across Scotland and mechanisms to ensure that houses are built on land allocated. National policy in respect of affordable housing and the location and quality of new housing is largely unchanged.
- Housing Market Partnerships
3.2 Local Authorities should adopt a Housing Market Partnership approach to undertaking all housing and planning related work including a Strategic Housing Need and Market Assessment (SHNMA). This should involve local authority Planning and Housing Services and other stakeholders such as private house builders and housing associations as well as adjoining authorities where appropriate. These partnerships will have the responsibility for considering the full range of market and social housing requirements across functional housing market areas.
3.3 Authorities are encouraged to co-operate "regionally" in setting realistic housing targets and in enabling the delivery of these targets.
- Comment:The requirement for discussion and consultation through Housing Market Partnerships, however desirable, will potentially slow and complicate the process. There is no provision for communities to have any role in the proposed partnership and the targets being set prior to the development plan process.
3.4 It is not clear what will constitute a regional partnership nor how functional housing market areas are to be defined for this purpose. North Ayrshire Council is awaiting the outcome of its request to become a full member of the Glasgow and Clyde Valley Strategic Planning Authority. It is presently party to the Ayrshire Joint Structure Plan which recognises North Ayrshire as a reasonably self-contained housing market area.
- Strategic Housing Need and Market Assessment (SHNMA)
3.5 The Scottish Government wish to see less time spent identifying how many houses should be built and more spent creating quality housing in the right places. The approach to achieving this is the creation of a process for considering housing requirements that sits outside the development planning process and standardisation of the methodology used to calculate housing numbers for all housing tenures. SHNMA will quantify the amount of housing that is required to meet both market demand and social need following full discussion through the Housing Market Partnership. This will then be used in the preparation of the local housing strategy and provide input into the local development plan which will set out how the housing requirement will be met. An overview is set out in Annex A of the Draft SPP and the Government intend to publish guidance in Spring 2008.
Comment:A standardised methodology for assessing housing requirements is welcomed with the proviso that the figuidance allows for a degree of local priority setting. Closer integration between the Planning and Housing functions of local authorities will be required. This already happens in North Ayrshire.
3.6 The adoption of the new methodology should overcome criticism from the house building industry that private sector allocations were effectively reduced by the requirement to accommodate social rented as well as private market housing on them. Together with the requirement to make "generous" land allocations, this is expected to reduce the amount of time spent considering housing numbers in the development planning process. However, additional allocations of land for housing are likely to result in increased opposition to such proposals from some affected local residents, amenity and environmental groups thereby slowing the development plan process as does the requirement for discussion and consultation through the Housing Market Partnerships.
- Increased Housing Land Allocation
3.7 The introduction to the Draft SPP states that difficulties in bringing forward sufficient land for housing has been identified as one of the most significant obstacles to the delivery of new housing. The Government's aspiration to increase the rate of new housing supply by at least 10,000 houses each year by 2015 underlines that it is "strongly supportive of house building" and that the planning system has an important role to play in achieving that goal.
3.8 No regional targets are set for house building nor is there a definition of what constitutes a "generous" supply of land for housing. It is at the discretion of planning authorities to determine the housing requirement for their area, within the context of Housing Market Partnerships and SHNMA. This would be implemented through Development Plans, which require to include a sustainable settlement strategy.
- Comment:The key considerations identified for a sustainable settlement strategy do not prioritise regeneration and there is a lack of acknowledgement of the impact of climate change. With insufficient emphasis being given to the role of regeneration of existing communities and only qualified support for a presumption in favour of brownfield development, the easier option of greenfield release could readily predominate in the desire to attain the national house building target. This could be prejudicial to the regeneration objectives of authorities such as North Ayrshire.
- Mechanisms to ensure houses are built
3.9 The Draft SPP encourages an outcome-focussed approach which seeks to secure the delivery of new housing. Reference is made to mechanisms to ensure that houses are built. The Draft SPP does recognise that the delivery of housing does not rely solely on the allocation of appropriate land in the development plan.
- Comment:The Draft SPP does not fully recognise factors such as the strength of the national and local economy, availability of credit, taxation levels and, in relation to land supply, the willingness of a landowner to sell his land if he perceives the "planning gain" demands and taxation levels to be too high. Thus the means by which these additional houses are to be built depends on many factors of which the effective working of the planning system is only one. In allocating a "generous" supply of land for housing there has to be a framework to manage and programme the sequence of land release taking into account infrastructure investment. A "generous" release may only result in landbanking and there are no current mechanisms through which planning authorities can ensure that houses are built.
- Specific Questions Posed in the Draft SPP
3.10 The consultation paper poses a series of twelve questions for consultees to consider. Only three of these raise key policy issues of concern; the remainder are of little relevance to North Ayrshire or are of a technical nature.
- Question 3: Do you agree it is desirable to achieve a more robust and consistent approach to the assessment of housing need and demand? Does the approach set out in chapter two provide an appropriate mechanism for this?
- Comment:While it is agreed that it is desirable to achieve a more robust and consistent approach there are serious reservations regarding the time, expertise and resources needed to set up Housing Market Partnerships and carry out Strategic Housing Need and Market Assessment prior to commencing new development plans.
- Question 4: How should the transition between the existing housing delivery system and that proposed be handled? How best can the cycles of new development plans due from the end of 2008 and the LHS due in summer 2009 be synchronised?
- Comment: A SHNMA will have to be undertaken with the findings agreed with the Housing Market Partnership and thereafter inform the Local Housing Strategy. This will in turn be reflected in allocations in the new Local Development Plan. There are concerns regarding the programming of this and there may be a period where the SHNMA and the Local Development Plan are not synchronised resulting in delay to the plan preparation process. In North Ayrshire, a Strategic Housing Need and Market Assessment will be commissioned by Housing Services in May 2008 (following publication of the SHNMA guidance) and this will facilitate the process.
- Question 7: Does "the period under consideration" require a definition?
Comment:It is considered that "the period under consideration" for the Strategic Development Plan is 20 years and for the Local Development Plan is 10 years. There is in each case an inconsistency with the 7 year audit period and the 5 year local housing strategy. There is a danger that slower rates of development may arise leading to the allocation of yet more sites and in turn undermine the prospects of the completion of developments under construction. Clearer definition is required with a framework to manage and programme the sequence of land release.
4. Implications
4.1 The Impact Assessment which forms part of the consultation paper recognises that the revised guidance will place greater burdens on planning authorities in terms of the preparation of plans, with a greater number of sustainable, effective housing sites requiring to be identified. The imposition of a standardised methodology, comprising a wider range of evidence, for the assessment of housing requirements and the involvement in Housing Market Partnerships to input to the Local Housing Strategy will necessitate additional staff and time resources in both the Housing and Planning Services. The greater monitoring of land supply and housing land audits required by the revised SPP3 will also be an additional burden.
4.2 The document recognises that there will be additional costs to planning authorities but these are not quantified. Taken together with the considerable additional costs arising from the Regulations on Development Planning, previously brought before the Executive, there is concern that no Scottish Government allocation is being made to meet these additional costs.
5. Consultation
5.1 Consultation has been undertaken with Housing Services.
6. Conclusion
6.1 The revised SPP3 puts forward positive proposals in its attempt to deliver increased housing numbers in Scotland. However, in the desire to achieve the national housing target there is concern that the regeneration of existing communities, including the reuse of brownfield sites, is given insufficient emphasis. As regards delivery of housing, there are many impediments not simply a shortage of allocated housing land. Community resistance to increased house building and the greater involvement of the community in the Local Development Plan process can be expected to prolong the process to adoption of the Plan, particularly if more greenfield release is involved. Planning and Housing authorities will experience greater pressure on resources in attempting to make the new systems work.
| IAN T MACKAY Assistant Chief Executive (Legal and Protective) |
Reference : KMcK/LI
For further information please contact Kenneth McKelvie, Planning Officer , on (01294) 225182
Background Papers :
Committee Reports and Agendas
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