Scotland 4 National Planning Vision draft likely to exacerbate housing crisis – Liz Hamilton, Homes for Scotland

The National Planning Framework for Scotland 4, as it is now designed, is likely to reduce the number of homes under construction, according to Homes for Scotland (Photo: Matt Cardy/Getty Images)

By guiding spatial development, defining national planning policies, defining national development directions and highlighting regional spatial priorities, the NFP4 will differ from its predecessor in that it will have a higher status and become part of a statutory local development plan, which means that its policies will have a direct role in daily planning decisions.

It is set in the context of a planning reform program that was initiated by the Scottish Government to increase “the provision of high quality housing through a faster, more affordable and more efficient process”.

Unfortunately, this is something that seems to have been lost as the NPF4 project has evolved. Against the backdrop of an already acknowledged supply shortfall, the total number of completed housing units in 2020 fell to 14,843, the lowest level since 1947.

Covid has clearly had a significant impact, but let’s remember that this level is lower than even at the height of the financial crisis, from which we still have not fully recovered.

Although the draft NPF4 talks about the climate emergency and the natural crisis, it does not take into account the housing crisis that we are still involved in.

This is of great concern not only to those of us building new homes with all the conditions of ownership required in Scotland, but more importantly to those who cannot find a home that suits their needs and that they can afford. Housing should not be seen as just another spatial use of land. This is a fundamental right that every resident of Scotland should have access to.

In an age where phrases like “social justice” and “social equity” have become political language, the fact is that the gap between housing “haves” and “have-nots” is widening.

Indeed, too many people in need of housing (for example, single adults living with parents or in a shared apartment, and families living in a home with insufficient space for bedrooms or no personal outdoor space) are not counted at all due to the incredibly limited notions of what constitutes a need and the use of solely household projections that assume past trends will continue.

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This is reflected in the amount of housing offered, with some authorities providing figures that are lower than those built in the last ten years. A reduction is planned and this must be decided at the national level before NPF4 is adopted.

First of all, there should be no doubt among the general public and other stakeholders that the actual need and demand for new homes in many areas is likely to be much higher than these figures suggest.

Assuming the numbers can be fixed, it is reassuring that the “deliverability” of housing lots comes to the fore in NPF4, although the current wording needs to be strengthened so that this political intent can be consistently and effectively implemented across the country.

As the duration of the Local Development Plan is extended from five to ten years, an effective mechanism is needed to bring in additional lands if they are found not to meet their housing needs. This aspect of the NPF4 should be consistent with ongoing consultations on proposed changes to the Local Development Plan rules.

We would also like to see links to other recent key policy documents that have highlighted housing as critical to Scotland’s future success, such as Housing 2040 or Scotland for the Future: Opportunities and Challenges for Scotland’s Changing Population.

Today we will hear from the Minister of Planning to see what funding will be allocated to policies such as Infrastructure First, which could provide a good opportunity for earlier confidence in reachability and the ability to more easily connect to existing infrastructure.

However, this requires significant financial intervention, adequate resources with appropriate skills in local government, and early support from broader infrastructure providers, otherwise it may become a barrier to housing provision.

Similarly, vacant and derelict land policies aim to prioritize the use of derelict sites for housing. While these sites do play a big role in housing delivery, it’s important to remember that they tend to come with greater physical and financial constraints and are not always inherently “greener” to build.

A hybrid approach to allocating land together with greenfield land will and should continue to provide housing at the required level.

The resource provision of planning departments of local authorities, along with the certainty and consistency of decision-making, remains a serious problem for the implementation of housing construction.

It is not yet clear how “planning judgment” should be applied to the range of policies within NPF4, which are at times inconsistent and conflicting. At a time when planning fees are due to increase again from April 1, it is fair to expect the planning process to improve, not the other way around.

The current version of the NPF4 is likely to reduce the number of rented houses, which will exacerbate the housing crisis.

As the public consultations are open until 31 March and parliamentary consideration is taking place at the same time, the Scottish Government has proposed the summer break as a target date for the submission of the final MSP document. It seems that this time is not enough to revise and consider the final draft and further submissions from stakeholders.

We are not the only ones to express concern about these tight deadlines. For the sake of anyone in need of a new home, NPF4 must be clear, achievable, viable, consistent and ambitious.

There is too much at stake for the future of Scottish housing to rush through this document, so we will be listening carefully to what Mr Arthur has to say.

Liz Hamilton is Head of Local and Regional Planning at Homes for Scotland.

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