Last week, the Scottish Government launched its draft Planning Delivery Advice: Housing and Infrastructure, which is now out for consultation. This follows Ryden’s Planning for Infrastructure Research Report, which informs elements of this advice.
The draft advice is concerned with improving housing and infrastructure delivery primarily through the development plan process, but will also be a material consideration in the determination of planning applications and appeals. Once finalised it will replace Planning Advice Note (PAN) 2/2010.
The overall tone of the document is helpful. It seeks to provide clarity and close some policy loopholes which have been used by planning authorities in the past to avoid their statutory duties in relation to planning for housing. However, in one area at least, the advice itself fails to deliver.
Collaborative working is a key feature across most of the objectives set out in the advice for both housing and infrastructure delivery. This principle is nothing new and is how the process of delivering a development should already be working. The effectiveness of this approach ultimately boils down to the willingness and ability of individuals to be outward looking and work effectively. Whilst this is undoubtedly the right approach, experience suggests this is clearly easier said than done.
In considering the delivery of new houses there is a clear desire for political and community buy-in and engagement. Active community participation is deemed essential to housing delivery. Again, the principle is merited and clearly a local community should be engaged in plans for development proposed locally. However the planning system needs to balance the desire for public consultation with streamlined delivery. The planning profession needs to address the issue of how to make the public more aware of their opportunities to be involved in the development plan process. At the application stage, the emphasis should be on seeking to clarify what issues are material to the decision making process. As Paragraph 15 states, a site’s allocation within the plan should carry with it a firm and shared commitment to ensure it is delivered. Similarly, the public debate needs to move on.
It is good to see paragraph 18 of the draft advice making clear that in city regions, there should be little or no debate around the scale of development required within Local Development Plan. This appears to be a direct acknowledgement of SESplan’s initial failure to set out housing land requirements for each local authority. There remains evidence of a reticence from local authorities to acknowledge the significant housing land requirements set out in SESplan and in particular, the need to provide for the two separate plan periods. This should not happen again. The numbers game is too often a distraction from our clear priority: to deliver housing where it’s needed. This is acknowledged in the advice.
What could be given more emphasis is how a consistently negative economic view is applied to suppress Housing Supply Targets. Planning authorities do this even when Economic Strategies and City Deals flatly contradict them. The Scottish Government must emphasise the need for a credible and consistent evidence base if a planning authority is wiping thousands of homes from the Housing Supply Target on the basis of a downbeat assessment of economic growth or construction sector capacity.
As per the existing PAN, the draft advice addresses the issue of effectiveness and in doing so identifies a number of criteria against which the effectiveness of a proposed housing site will be assessed. Controversially, marketability is no longer considered to be directly relevant to a site’s effectiveness - a significant change from current advice and something that will be of concern to the housebuilding industry. Indeed, from a developer’s perspective if a house won’t sell then the site isn’t effective.
In reality, marketability, effectiveness and development viability are inextricably linked. A site’s marketability has to be reflected in land and plot values. If those values don’t add up, the site cannot be delivered without public intervention. This should be acknowledged in the advice.
Finally, we are wary of the introduction of “land with agreed development potential” into the calculation of the housing land supply. This will address the ambiguous status of sites in draft plans. However for other sites, planning authorities may use these to artificially inflate an otherwise deficient five-year housing land supply. The advice should therefore stipulate that a site’s development potential must be agreed with Homes for Scotland before is included in the housing land supply.
We are pleased to see many of our recommendations set out in Planning for Infrastructure being picked up by this draft advice. Early and better information on infrastructure capacity, and better and more consistent cross-agency working, will be key to overcoming infrastructure capacity issues that can hold up the delivery of development.
Greater clarity and transparency over the level and nature of developer contributions for infrastructure is needed as this has been a persistent gripe within the development industry. A move to satisfy those concerns and a more concerted effort to drive the delivery of infrastructure to enable the significant levels of new housing required across the country should be welcomed.