Draft National Planning Framework 4

It is noted that the Sustainable Places policies are ‘universal policies’. HFS members understand, respect and support the commitment that the Scottish Government has made to make Scotland a net zero society by 2045. We recognise that we all have our part to play in this and we confirm our commitment to achieving what is practicable at the earliest opportunity. We also recognise that we all have our role to play in tackling biodiversity loss/nature crisis and, in the absence of a national policy, home builders have already begun to take action to address the issue. The ‘Nature Crisis’ would benefit from a definition within NPF4 given it is a core theme within the document. HFS is disappointed that there isn’t an equivalent policy drive towards addressing the housing crisis within the universal policies section. NPF4 is the spatial manifestation of Scottish Government policy and there is a missed opportunity to reflect recent publications such as Housing to 2040 and A Scotland for the Future: opportunities and challenges of Scotland’s changing population.
‘Housing makes a crucial contribution across all four pillars (economic, human, social and natural) which underpin our vision of an economy that delivers sustainable and inclusive growth for the people of Scotland’ Housing to 2040, March 2021
‘Depending where families live, they may not have adequate housing to raise a family, or at least the family size they wish to have either due to supply or cost. If individuals do not have certainty about their housing then this can also impact on their decision.’ A Scotland for the Future: Opportunities and Challenges of Scotland’s Changing Population, March 2021
New home building is well placed to meet the demands of the climate emergency and nature crisis whilst also addressing the worsening challenge of providing Scotland’s people with a home that they can afford and meets their needs. NPF4 needs to reflect the three pillars of sustainability: environmental, social and economic. NPF4 address environmental sustainability as a priority and appears to take a passive approach to the social and economic requirements of Scotland.
Detailed responses are included later for the Sustainable Places (Universal Policies) policies namely: 1 Plan Led Approach to Sustainable Development; 2 Climate Emergency; 3 Nature Crisis; 4 Human Rights and Equality; 5 Community Wealth Building and 6 Design, Quality and Place.

HFS supports the aspirations contained within the Liveable Places section and the home building sector is extremely well placed to deliver the future places, homes and neighbourhoods that our communities need. This section refers to the ‘social legacy’ left behind by the COVID-19 pandemic. HFS agrees that there has never been a more important time to provide people with a home that meets their needs in a community where they want to live.
Housing delivery needs to be identified as a National Development to allow Local Authorities (LAs) to operate in a plan led system that prioritises housing as a societal right to the people living in Scotland and not merely another spatial land use. This can be directly linked to outcome (a) (Annex A) identified in Section 3A (c) of the Town and Country Planning (Scotland) Act 1997 which is ‘meeting the housing needs of people living in Scotland including, in particular, the housing needs for older people and disabled people’. As it stands NPF4 is unlikely to meet the requirements of outcome (a).
With the above in mind, it is critical that the policy background within NPF4 translates to a supportive planning environment that allows the number of new homes our country needs to be delivered. HFS is supportive of the principle of 20 minute neighbourhoods and does not disagree with the fundamentals of what the policy is seeking to achieve. However, its success will be reliant on its interpretation at Local Authority level and a recognition that it must offer a degree of flexibility depending on local context and the specifics of each development proposal. A comment that can be applied to all of the policies within NPF4 is that there must remain an ability and recognition of planning judgement.
In principle, HFS is supportive of the Infrastructure First approach. However, it needs to be reinforced via adequate resourcing and skilling in LAs to properly assess and plan for infrastructure. It will also require significant financial intervention at a local, regional and national level and, crucially, have early buy-in from the key statutory agencies and utility companies. There is a real concern that the policy could become a blocker/delay to development rather than acting in a proactive manner to assist in bringing sites forward that are/or will be ready to be deliverable.
Policy 9 Housing and its implementation via the LDP process will be crucial to the delivery of the number of homes that are required across Local Authorities. A detailed response is provided in response to question 31 and this must be aligned with both Annex B Housing Numbers and the other consultation on proposed changes to the Local Development Plan Regulations. Given the significance of each of the aforementioned topics to the future of housing delivery, HFS is keen to follow up this consultation with more detailed discussion with the Scottish Government (SG).
Detailed responses are included later for the Liveable Places policies namely: 7 Local Living/20-minute neighbourhoods; 8 Infrastructure First; 9 Quality Homes; 10 Sustainable travel and transport; 11 Heat and Cooling; Blue and Green Infrastructure, play and sport; 12 Sustainable Flood Risk and Water Management; and 13 Lifelong Health, Wellbeing and Safety.

This section is focused on transformations required to tackle the climate and nature crises but fails to recognise the contribution that housing can make to its overall aims. Housing not only provides homes to people that need them but also provides an abundance of economic benefits including job creation, supply chain support and improvements to existing local infrastructure. (See “The Social & Economic Benefits of Home Building in Scotland” report for further information.)(Report is also attached as Appendix C to our response.)
As currently drafted, NPF4 risks adding complexity and delay to an already struggling planning system. The aims and priorities of NPF4 must be related to wider economic and social issues beyond the climate emergency and nature crisis. Home building is a key sector in Scotland, providing an abundance of social and economic opportunities and improvements. It is highly reliant on a well-functioning planning system that will provide the right number of housing opportunities across LAs, and clarity and certainty in decision-making. As currently drafted, NPF4 does not appear to provide the foundations for an improved system as was outlined within the planning reform agenda. HFS would question the ability for NPF4 to attract investors to Scotland in a backdrop of a less certain planning system.
Detailed responses are included later for the Productive Places, as far as they relate to housing delivery, policies namely: Policy 23 Zero Waste.

HFS supports the aspirations contained within the Distinctive Places section and the home building sector is extremely well placed to deliver the future places that will be distinctive, safe and pleasant, easy to move around, welcoming, nature positive and resource efficient
It will be essential that the design tools as outlined in policy 6 are updated in order that they remain relevant and credible. An up-to-date suite of design documents at national level is also required in order that LAs and applicants have clarity of design expectations early on in the planning process.
The policies within Part 3 need to be clearer on what is meant by “resource efficient”. The re-use of vacant and derelict land is an important source for future development opportunities, however, it needs to be recognised that this cannot always be relied on as a priority. It should also not be assumed that building on vacant and derelict land is inherently ‘greener’. A detailed response to policy 30 is provided outlining why this is the case.
In terms of biodiversity, there needs to be a clearer metric on how to measure net gain. Policy 3 assumes that biodiversity enhancement is best achieved through restoration. In some cases, introduction may be more effective than restoration.
HFS is supportive of a policy framework that ensures that the social and economic challenges specific to rural places are being met. However, we do not believe that this section will help to counter population challenges or housing needs in rural areas. To ensure the long-term sustainability of rural places, NPF4 needs to recognise that they operate differently to urban and suburban areas and therefore require a more flexible and specific approach to planning policy. As it stands NPF4 will fail to meet outcome (c) within Annex A.
Detailed responses are included later for Distinctive Places, as far as they relate to housing delivery, namely policies: 27 City, town, commercial and local centres; 28 Historic Assets and Places; 29 Urban Edges and the green belt; 30 Vacant and derelict land and empty buildings; 31 Rural Places; and 32 Natural Places.

See answers to questions 1 - 4.

1. Compact Growth:
HFS does not believe that it is always appropriate to allocate vacant and derelict vacant and derelict land for housing as a priority over greenfield land. The delivery of all-tenure housing to meet future needs across Scotland will be reliant on an appropriate blend of brownfield/vacant and derelict/greenfield land coming forward through LDPs. This spatial strategy will require LAs to always prioritise vacant and derelict land with no clear evidence as to why. Whilst vacant and derelict land sites do contribute to the delivery of new homes, there are also examples of where housing simply may not be appropriate. This includes examples of where the delivery of new homes is severely restricted by contamination, lack of access, remoteness or where the economic hurdles cannot be met (such as where the redevelopment requires a perceived over-development of the site). Whatever the role of vacant and derelict land is to be, this should not be at the expense of the release of potentially more suitable greenfield sites. “Suitable” could mean that greenfield sites are in better serviced and connected locations, have less existing biodiversity than vacant and derelict land or are better equipped to support the 20- minute neighbourhood principle. In addition, a blend of land allocation that includes greenfield allows homes to be delivered in a more consistent timeline given the cost and practical considerations. Brownfield land can provide a range of redevelopment opportunities beyond housing including retail, employment and leisure - helping to reduce the need for travel by creating 20-minute neighbourhoods for existing residential areas.

2. Local Living:

HFS can support the principle of local living and does not disagree with the fundamentals of what the policy is seeking to achieve. However, there is insufficient clarity in policy 7 and substantial scope for varying interpretations leading to the potential for inconsistency in decision-making. The 20 minute neighbourhood principle must be capable of being applied flexibly taking into account local context and with discretionary decision making powers depending on wider social, economic and environmental benefits. Land use planning alone will not deliver the shift to sustainable transport and the policy will be ineffective unless it is supported by a significant change in individual consumer behaviours and backed by substantial investment in public transport. All development will have a car impact as the decision to own a car is not just directly related to the location and layout of homes and communities but involves much more nuanced and personalised choices such as confidence in the reliability or safety of other modes of travel in the location that people choose to live.

3. Balanced Development

HFS is supportive of people having more choice about where they live, learn and work. That is why it is essential that housing is delivered in places where people want to live and at the required level in order to meet the needs and demand from people living in Scotland. This aligns with the HFS response to section 1 of question 6 that a blend of brownfield and greenfield land allocation is required. Demand for homes may be driven by a desire to be close to extended family members, an aspiration for a higher quality of life than they currently have or a desire to seek to rebalance their life in more or less densely populated locations. HFS recognises the need to create opportunities for communities in areas of decline. A range and choice of housing options will help support this, as will a clear and costed delivery mechanism that has ownership across all relevant public bodies and the private sector. There needs to be a clear strategy on how the affordability gap in areas of high demand can be met. If future housing supply is constrained in these areas, then the gap is only going to increase. The rural places policy is critical in enabling these communities to retain and grow their communities. Rural places have different needs and challenges to urban areas and therefore require a radically different approach to spatial land use planning.

4. Conserving and recycling assets

HFS agrees that the retention and enhancement of assets in Scotland will assist in leaving a positive legacy for communities. However, a flexible approach will be required and it will not always be the case that existing buildings can or should be preserved. The retention of assets and locking in of embodied carbon should always be balanced against the overall success of a place or building where redevelopment could often be the best solution for social and economic reasons.

5. Urban and rural synergy

HFS is supportive of the aims of this principle. The home building industry is well placed to improve and enhance green infrastructure and biodiversity.

6. Just transition

As a sector, home building is very well placed to respond to and address the climate challenge. Building regulations ensure that new homes are extremely efficient with the incorporation of improvements to the building fabric and low carbon technologies including PV panels and heat pumps. New home building can also support, and help to create new, local services meaning less reliance on car travel to meet daily needs.
New homes are only a fraction of overall housing stock and therefore a strategy is required for existing homes to yield better results/performance. This may need relaxation of conservation area/listed building policies to support installation of more efficient doors/windows, but would make a significant impact rather focusing on the new build, which already delivers via current and soon to be improved building standards.

It is not clear from this section what is intended to be achieved from the 5 identified action areas. Are they to guide Local Development Plan (LDP) production or Regional Spatial Strategies? The mapping used within NPF4 is vague and, in some instances, cuts across LA boundaries. The areas are far too broad to accurately pinpoint regional issues. For example, the Central Urban Transformation covers a vast area within the central belt of Scotland with local and regional challenges much broader than urban transformation. If NPF4 is to be successful in identifying and overcoming regional challenges then it needs to have a more focused and localised approach. There is an opportunity for NPF4 to be more prescriptive on the intention and role of Regional Spatial Strategies within this section. This section of NPF4 fails to reference the Minimum All Tenure Housing Land Requirements (MATLR). HFS is of the view that the broad MATHLR numbers for each region should be detailed in the action areas. Also, housing delivery needs to be identified as a National Development to allow LAs to operate in a plan led development that prioritises housing as a societal right to the people living in Scotland and not merely another spatial land use.

No comment from HFS.

No comment from HFS.

This area of Scotland will require a carefully balanced approach to development planning with a wide range of mechanisms to support urban growth alongside the long-term sustainability of rural communities. Housing delivery will play a key role in providing the required number and range of housing that people need and can afford in the area. This includes providing housing for young people to remain living in areas where they grew up and the challenge of creating suitable housing opportunities for the ageing population. It is encouraging to see that the document recognises the recent acceleration of the increase in house prices and therefore the requirement for an intervention in the delivery of homes that people can afford.
HFS has responded to Q.49 that addresses policy 31 Rural Places. Rural places and settlements present unique circumstances across Scotland and therefore a flexible and innovative approach is required to ensure that policy aims are met. Car use will, inevitably, be higher in rural areas where they lack the range and choice of public transport connections or local services. The introduction of new homes can assist with the overall sustainability of a rural place by helping to sustain and grow local services and create greater economic justification for the funding of public transport.
The MATHLR figures are published in Annex B of this document. HFS has responded in detail to this section under Q.57.

No further comments.

HFS believes that there is a lack of detail in outlining how the region will transition from oil and gas to renewable energy. There needs to be a clear strategy on how a just transition will be achieved, giving time to allow new industries to establish and provide a seamless transition. HFS requests more clarity for businesses who are operating within the region on what is expected of them in driving the transition to net zero. In light of the current energy crisis, NPF4 should provide flexible mechanisms to allow self-sufficiency in terms of all energy types, including oil and gas, and recognise that the north east is well placed to provide a wide range of energy.
We also believe that this section of NPF4 is much too focused on already committed projects (such as the harbour expansion) and lacks ambition for the next 10 years. In terms of the Waterfront strategy, members are supportive of this in principle but note that it will require significant Scottish Government intervention and an overhaul of the Compulsory Purchase Order (CPO) system. The lack of a delivery strategy does not provide any clarity or confidence on how this will be achieved.
The MATHLR figures as presented in draft NPF4 for both Aberdeen City and Aberdeenshire are below the housing numbers completed during the period between 2009 – 2019. As an absolute minimum, the figures must be equal to the previous 10 years completions prior to NPF4 being adopted - otherwise NPF4 would appear to be planning for decline.
The MATHLR figures are published in Annex B of this document. HFS has responded in detail to this section under Q.57.

The section on local liveability looks to address high levels of car ownership and respond to the area’s dispersed settlement pattern. The range of sites mentioned are not likely to offer a solution on their own. There also needs to be a focus on sites that are situated closer to Aberdeen and within the city. It is surprising that there is no mention of housing growth opportunities adjacent to public transport corridors.
Higher density development on brownfield land is one option for delivering housing growth, however, this needs to be balanced against a blended approach with greenfield release and reflect actual housing need e.g. housing for the ageing population, family housing.
There needs to be a commitment to the dualling of A96. Although it is shown in the diagram on page 26, there is no specific mention of it in the text.

Firstly, the Central Urban Transformation area is far too wide in its geographical spread to effectively deliver on its aims. This area includes some of the most diverse range of geographies than the other four Action Areas, combining the major conurbations of Glasgow and Edinburgh (and everything in between) with the rural idylls of parts of Ayrshire, Stirling, Perthshire and Angus. The majority of Scotland’s population live and work in this area and therefore, in order to deliver long-standing and ambitious transformation, it needs to be divided into smaller regional areas. A large proportion of the ‘central urban’ area is not, in fact, urban with a number of rural towns and villages and suburban areas. Are these parts of the central belt not being recognised as requiring intervention within NPF4? The Edinburgh and Glasgow regions dominate the content of this section with much less detail provided for areas such as Ayrshire and Fife. This reinforces the requirement for the Central Belt action area to be subdivided into smaller geographical regions.
Para 3 states that there are differences between the city regions of Glasgow and Edinburgh. The Glasgow region is identified as having high concentrations of poor health, economic disadvantage and population decline contrasting with strong demand and expected population growth in parts of the Edinburgh city region. It is then suggested that, despite good connections and infrastructure capacity, it can be more challenging to encourage the market to deliver new homes towards the west of the central belt. This statement is not true - our members companies are experiencing strong demand in the west. In 2021, Motherwell saw the highest house price growth at 17.3%, followed by Hamilton in second place at 13.7%. This points towards a trend of demand outstripping supply. It is not the market that needs to be encouraged to build new homes, rather a significant shift is required in the way that new land is allocated. This means allocating enough land that is deliverable. The west does, in places, have a legacy of post-industrial land. However, it must be recognised that they do take longer to deliver and require significant upfront investment. Therefore a blend of greenfield and brownfield land must be allocated to ensure the constant supply of new homes.
The MATHLR figures are published in Annex B of this document. HFS has responded in detail to this section under Q.57. In summary HFS and its member companies operating in the west of the central belt area are extremely concerned by the low numbers being forecast for the next ten years in the Clydeplan area. There is a clear disconnect between the numbers as currently forecast versus real demand for new homes.

Due to the lack of a delivery programme within this draft there is no apparent link between the aims of the strategic actions and their subsequent implementation. Urban transformation is going to be heavily reliant on a programme of investment and the fact that there is not a routemap for delivery of this within the draft is concerning.
The 20 minute neighbourhood concept is broadly supported by HFS and a detailed response is provided for Q.29. However, there needs to be a flexible approach to 20 minute neighbourhoods taking into account local context and wider social and economic requirements. They are unlikely to be universally workable and will be dependent upon the existing urban form and surrounding area. New home building is well placed to create mixed use facilities and improve existing suburban areas by assisting with the provision of new services. Greenfield sites are often better able to deliver sustainable neighbourhoods as the necessary social infrastructure can be provided in a more planned manner and these sites are not constrained by the existing urban fabric.
HFS is supportive of the reuse of vacant and derelict land as an important function of housing delivery. We do not believe, though, that it is always appropriate to allocate vacant and derelict land for housing as a priority over greenfield land. Vacant and derelict land sites tend to have many more physical constraints than greenfield and require significant financial investment. The delivery of housing to meet future needs across Scotland will be reliant on an appropriate blend of greenfield, brownfield and vacant and derelict land coming forward through LDPs. There does not appear to be a strategy for public sector-led development. The redevelopment of brownfield sites will require a proactive approach from the public sector with adequate skilling to allow for CPO, land assembly and identification of key constraints. This document does not give any information on how that will be achieved and what funding will be made available.
It is stated (Action 17) that Edinburgh has committed to building a significant share of future housing development on brownfield sites. It needs to be noted that the majority of sites that are newly allocated in the proposed Edinburgh City Plan are currently occupied by business or employment uses and therefore not deliverable. As it stands, the proposed City Plan is also not likely to deliver the number and range of homes that are required. There must be a credible policy context to ensure that the housing needs that are generated by the success of Edinburgh can still be met within its City Region with an allocation framework that is able to respond to needs generated by mobile demand.
HFS notes that this section does not reference the following initiatives within the area: Glasgow and Clyde Valley City Deal, M77 Strategic Corridor, Pan Lanarkshire Orbital Transport Corridor, Greenhills Road/A726 Dual Carriageway and Community Growth Areas.
Action 20 refers to development on the urban fringe. HFS agrees that development on the urban fringe has potential to sustain communities by providing enhanced biodiversity and services to help existing edge of town residential areas to meet the wish list of 20 minute neighbourhoods. Additionally, HFS agrees that the pandemic has demonstrated that many people are looking for more space at home and in their communities. This reinforces the requirement for a balanced approach to the allocation of new housing developments and a recognition of the vital services they can provide in order to meet the needs of existing communities.

This area of Scotland has a similar blend of rural and urban to that of the Northern Revitalisation area. It will require a carefully balanced approach to development planning with a wide range of mechanisms to support urban growth alongside the long term sustainability of rural communities. Housing delivery will play a key role in providing the required number and range of housing that people need and can afford in the area. This includes providing housing for young people to remain living in areas where they grew up and the challenge of creating suitable housing opportunities for the ageing population.
HFS has responded to Q.49 that addresses policy 31 Rural Places. Rural places and settlements present unique circumstances across Scotland and therefore a flexible and innovative approach is required to ensure that policy aims are met. Car use will, inevitably, be higher in rural areas where they lack the range and choice of public transport connections or local services. The introduction of new homes can assist with the overall sustainability of a rural place by helping to sustain and grow local services and create greater economic justification for the funding of public transport.
The MATHLR figures are published in Annex B of this document. HFS has responded in detail to this section under Q.57.

No further comments.

See answer to question 21.

No comment from HFS.

No comment from HFS.

The delivery of new housing should be recognised as a national development.
This request is set in the context of the planning reform agenda which was initiated by the Scottish Government with the objective of increasing the “delivery of high-quality housing developments, by delivering a quicker more accessible and efficient process” at its heart.
Unfortunately, this is something that seems to have been lost as draft NPF4 has evolved. Against a backdrop of already recognised undersupply, total 2020 housing completions fell to 14,843 – the lowest level since 1947. Covid has clearly had a significant impact but it should be remembered that this level is lower even than that experienced during the depths of the financial crisis from which the sector has still not fully recovered.
Whilst draft NPF4 refers to the climate emergency and nature crisis, it fails to recognise the housing crisis. This is highly troubling, not only for those of us involved in the delivery of the new homes of all tenures that Scotland requires but also, and more importantly, those who are unable to find a home that meets their needs and that they can afford.
Housing must not be viewed as merely another spatial land use; it is a basic human right.
It is defined as such under Articles 17 and 25 of the Universal Declaration of Human Rights. It is even referenced as such in Part 4A of Housing to 2040. However, there is no reference to this within NPF4, nor any of the supporting documents. With the supply of new homes being increasingly restricted as a result of local and national policies (and the associated rising concerns of affordability, homelessness and access to adequate housing), it is fundamentally vital that Articles 17 and 25 of the Universal Declaration of Human Rights be afforded weight in the preparation of NPF4. There remains a significant amount of work to do to ensure that everyone in Scotland has access to a safe, secure and affordable home.
In an age where phrases like “social justice” and “social equality” have become policy wording norms, the fact of the matter is that the gap between the housing “haves” and “have nots” is growing. Indeed, too many people in housing need (e.g. single adults living with parents or in a shared flat and families in a home with inadequate bedroom space or no private outdoor space or older people in homes which are too big for them) are not being counted at all due to an incredibly limited view on what constitutes need which draws too exclusively from household projections assuming that past trends will continue.
This is reflected in the housing numbers being proposed, with some authorities providing figures that are below the numbers built in the last ten years. This is planning for decline and must be addressed at a national level before NPF4 is adopted. Above all, the general public and other stakeholders must be left in no doubt that the actual need and demand for new homes is, in many areas, likely to be significantly higher than these figures suggest.
Key policy documents that have highlighted housing as being critical to Scotland’s future success e.g., Housing to 2040 or A Scotland for the Future: opportunities and challenges of Scotland’s changing population, do not appear to be strongly reflected or recognised within draft NPF4. It is understood that NPF4 is intended to be a long-standing document and therefore cannot mention current policy objectives specifically, but it is surely an error for the document not to support and implement their aims and objectives. NPF4 must balance environmental sustainability with social and economic requirements for the future prosperity of Scotland.
Housing not only provides homes to people that need them but also provides an abundance of economic benefits including job creation, supply chain support and improvements to existing local infrastructure. (See “The Social & Economic Benefits of Home Building in Scotland” report for further information.)(Report is also attached as Appendix C to our response.)

HFS recognises the importance of both in the decision-making process however they both largely focus on the physical sustainability of Scotland. The three pillars of sustainability: environmental, social and economic must be considered together to ensure the future prosperity of the people living in Scotland. NPF4 should act as the spatial manifestation of policy and needs to better reflect on recent publications including Housing to 2040 and the Economic Transformation Strategy. Housing is a social and economic requirement that cannot simply be treated as another spatial land use. The response to housing need in NPF4 appears passive and does not appropriately balance the three pillars of sustainability or adequately address the housing crisis.

HFS agrees with a plan led approach in principle, but plans must be effective and prepared quickly to provide businesses and communities with confidence in future decision-making. They must also be altered quickly if circumstances change. This will require a high input of public subsidy, large scale local authority/ government delivery of infrastructure and development sites. In this regard, Policy 1 does not set the right tone for the remainder of the plan. As the first of the national policies, Policy 1 needs to provide a commitment to the delivery of achievable outcomes that are within its sphere of influence. The use of terms which are open to interpretation such as “seek to achieve”, ‘long term public interest”, and the inclusion of 17 complex U.N outcomes and goals, sets the system and LDPs up for failure. In turn, we believe that this will affect confidence in the planning system to deliver measurable outcomes that are clear to business and communities.

We suggest Policy 1 needs to be much stronger and should more clearly set the tone for how NPF4 and LDPs should set out the spatial manifestation of Scotland’s economic strategy and other such national strategies. Policy 1 should include a presumption in favour of sustainable development, including National Developments related to housing delivery, referencing the three pillars of sustainability: environmental, social and economic and echoing the aims of the recently published Economic Transformation Strategy. Further, it should explain what this means for both plan-making and decision-taking. As it is written, it solely refers to the environmental aspects of sustainability and ignores the rest.

Lastly on this policy, we have issue with the bold text being a restatement of the purpose of planning from Section 3ZA of the Town and Country Planning (Scotland) Act 1997 (introduced by the Planning (Scotland) Act 2019). This is problematic as the wording in Policy 1 narrows the definition of the purpose of planning and what is in the long-term public interest to Scotland’s national outcomes and UN Sustainable Development goals only. The statutory definition is broader than that and takes precedence.

HFS members understand, respect and support the commitment that the Scottish Government has made to make Scotland a net zero society by 2045. We recognise that we all have our part to play in this and we confirm our commitment to achieving what is practicable at the earliest opportunity. We can therefore support this policy in principle but have serious reservations about the policy in its current form. There needs to be more clarity on what is meant and what is required of the sector.

Policy 2 (a)
We agree with the overall intent of the policy. However, it is highly subjective as currently drafted and is lacking in any measurable targets. Much more guidance is required on what is to be measured and what is required from the sector.

Policy 2 (b)

We have significant concerns about this policy as it is drafted currently. We agree with the overall principle of measuring and minimising both operational and life cycle emissions. However, this can only be done effectively with the provision of a clear and standardised tool for measurement and this sits more appropriately within the scope of Building Standards. At the moment, no such tool exists so each developer and each of Scotland’s 32 local planning authorities will have to develop their own measurement system leading to substantial delays and confusion within the planning system.

Current proposed changes to the Scottish Government Building Standards focus on the operational emissions of properties in recognition of the fact that current lifecycle emissions cannot currently be measured in a comparable and meaningful way. This policy would add a considerable additional burden to planning authorities who require additional guidance, resourcing, and skills to be able to deliver this effectively. It is therefore inappropriate to include this policy as it stands currently.

It is also unclear to us what national decarbonisation pathways are and to what extent the ability of others (e.g. the energy providers or the wider supply chain) to deliver on other aspects of decarbonisation will impact on the home builders ability to build homes that deliver on this ambition.

Policy 2 (c)

The requirement for developers to demonstrate the cumulative impact of their proposals alongside other developments not in their control is not reasonable, not least because of the already mentioned lack of guidance or reliable methodology to consistently baseline, measure or demonstrate impact of such emissions.

It is not clear how the “significance” of emissions will be measured. Will it be relative to the scale and type of development (and a matter of qualitative judgment) or a fixed threshold?

Again, the requirement for national / major or EIA developments to provide whole-life assessment is not currently possible in the absence of a standardised measurement tool. In addition, the skills to adequately interpret such information is not currently embedded in local planning authorities.

It is also not clear why all EIA development should be accompanied by a whole-life assessment of greenhouse gas emissions from the development. It is conceivable that a local development could trigger the requirement for EIA, notwithstanding that it will have zero emissions.

As with the climate emergency, we recognise that we all have our role to play in tackling biodiversity loss and in the absence of a national policy, homebuilders have already begun to take action to address the issue. It is one of the many important issues that the planning system must assess and balance during the decision process. However, the weighting of this policy appears to be pre-determined. As it is written currently it seems overly lengthy and detailed when compared with other key policy areas such as Policy 1 and 2 above.
Despite the length, the policy does not define or quantify the nature crisis in a meaningful way. It does not provide parties with sufficient clarity on how impacts or mitigations can be measured. For example, it is not clear how the “significance” of biodiversity enhancement will be measured. Is a measurement tool being developed? If so, it should be a set at a national level to provide consistency across Scotland.
We recognise the policy does set out a way of establishing the baseline, the negative impact and then resolving, however, we need more certainty in the language to avoid future conflicts. The concern is that without any real directive there will be so much uncertainty with several unintended consequences. How a developer is to assess, agree, deliver and maintain the undefined nature positive attributes is unclear. In the absence of clear guidance at the national level, we are also concerned whether local planning authorities have the necessary skillset to determine whether proposals comply or not. This could lead to regional disparity and delays in the planning system.
We would like to see a clearer metric on how to measure biodiversity net gain and some mention of the mitigation hierarchy. The latter part will contain some recognition that conservation and enhancement cannot be achieved on all sites without off-site mitigation. It is also important to highlight that some requirements of the policy may require connections with sites or nature pathways over which applicants have no control, therefore resulting in ‘ransom’ situations which could render sites undeliverable.
The policy presumes that biodiversity enhancement is best achieved through restoration. However, that might not apply in all cases. In some cases, introduction may be more effective than restoration. Instead of restoration, the policy could simply refer to the “enhancement of biodiversity” however this needs to be defined.

HFS members fully support the protection of human rights and equality. However, there are concerns that NPF4 is not the appropriate place for a policy which is protected by national and international law. Public Authorities are already obligated to adhere to statutory legislation to ensure that their business functions are exercised in a way which protects human rights and equality.
Policy 4(a)
There are concerns that the potential prescriptive nature of some human rights, for example The Right to Peaceful Enjoyment of your Property, may lead to delays in applications to ensure that the human right has been specifically applied. This will have a direct impact on the delivery of housing.
Policy 4(b)
The title of this policy does not align with the explanation. There is a focus on collaboration and consultation rather than human rights and equality. Consideration should be given to renaming the policy to wording to the effect of ‘Community Engagement’, ‘Community Collaboration’ or ‘Human Rights, Equality and Collaboration’.
HFS members have seen an increase in online community engagement since the beginning of COVID. The typical demographic of engagement currently comes from those who are retired. Home builders are keen to reach the next generation of purchasers.
There are concerns that the enhanced responsibility on applicants to consult and engage with communities could lead to Local Authorities delaying or refusing applications. This will have a direct impact on the delivery of all tenures of housing in Scotland.
Overall, this policy lacks clarity and explanation. Further detail is required to understand how it is intended to work in practice and if it is relevant to planning processes and community engagement.

HFS is supportive of the intentions of this policy, however, there are concerns that there are no definitions of ‘Community Wealth Building’ anywhere in the document. This makes it incredibly difficult for the reader to understand the context of this policy. Additionally, it is unclear how the policy is intended to be achieved, how it will be applied in practice and the implications it will have on the development industry.

Policy 5 (a)

Development already brings its own benefits to communities and is currently required to be demonstrated by way of Policy 9 (Statement of Community Benefit). It is unclear why there is a further need to provide additional community wealth building.

There is no definition of community wealth building objectives. There is a lack of clarity regarding who will be bound by the proposed community wealth building initiatives. Is this policy aimed at local authorities when preparing spatial strategies and allocating land, or will this apply to the landowner or the home builder/developer who is in contract with the landowner? What is a large employer and how is this assessed? Further detail is needed to understand how national and major development proposals are expected to contribute towards community wealth building objectives. If the site is allocated in a development plan having regard to Policy 5(a), is it assumed that development thereon will address community wealth building?

There are further concerns that this policy will be used as a vehicle to impose financial penalties on home builders/developers, who are perceived to not be benefiting local communities.

Policy 5 (b)

As outlined, HFS members have concerns that there is no definition of community wealth building’. It is unclear why this has not been explicitly defined in the draft. The lack of definition and detail of this policy will lead to uncertainty of who is impacted, leaving a lack of time for home builders to prepare for the intended changes. See comments on the inter-relationship with Policy 5(b) and where the onus lies.

HFS supports the promotion of design, quality and place as a central policy area for the planning system and NPF4. However, it is not clear that policy 6 will achieve its aims due to the out-of-date documents that it relies on and use of subjective language. This policy area should be creating an opportunity for more certainty for planning decision-makers and applicants, however, as currently drafted, policy 6 will more likely lead to confusion, contradiction and inconsistency of approach across each of the LAs.

Policy 6 (a)

The policy states: “Development proposals should be designed to a high quality so that the scale and nature of the development contributes positively to the character and sense of place of the area in which they are to be located.” HFS strongly supports this statement, however, the language used is subjective. In order for there to be consistency across each LA it is essential there is a clear and objective approach to design.

Policy 6 (b)

This section is looking to address the suite of tools already available to LAs when determining development proposals. The concern with this section is that the documents referred to in bold print are considerably out of date e.g. Designing Streets 2010, Creating Places 2013. There already exists an inconsistency of approach to the named documents and it is not clear how this policy will address this. In order for Policy 6 to be credible the documents must be updated. The policy also proposes that a LA can refer to “any design guidance adopted by planning authorities and statutory consultees”. Whilst this could allow an ability for local and regional aspects of design and placemaking to be reflected, there is a danger that the large number of documents quoted will not lead to quicker and clearer decision-making during the application process.

Policy 6 (c)

This section deals with the updated Six Qualities of Successful Places. The headlines of the six qualities are broadly supported by HFS, however, this places yet another layer of design guidance on top of the many documents already referred to in section 6(b). Some of the language in this section is subjective e.g., “sense of joy”.

Policy 6 (d)

There is agreement with the sentiment of this section, however, as noted in sections (a) to (c) above, it is not clear how development proposals will be consistently determined to avoid subjectivity during the decision-making process. It is also questionable whether section (d) is required if parts a, b and c are being applied effectively.

Policy 6 (e)

There needs to be a clear policy focus on what is considered detrimental to the character or appearance of the surrounding area when taking into account effects on daylight, sunlight, noise, air quality and privacy. Equally, this policy also needs to allow for ‘planning balance’ and weighting to be applied during the determination of development proposals. This is mentioned in the backdrop of a clear policy focus towards the reuse of brownfield, vacant and derelict land where it can be harder to meet the required standards for the five aspects detailed above e.g., a high density inner urban gap site might struggle to avoid detrimental effects on daylight or privacy to the surrounding area. In this situation it is not clear what NPF4 policy would take precedence i.e., Policy 30 Vacant and derelict land or Policy 6 (e)?

We can support the principle of local living and agree with the fundamentals of what the policy is seeking to achieve. However, there is insufficient clarity in the policy with substantial scope for varying interpretations leading to the potential for inconsistency in decision-making. The term ‘reasonably be expected’ is open to very substantial differences in interpretation. We require much clearer guidance on the 20 minute neighbourhood principle – what it means, how it is measured etc.
Overall, there is a concern that application of this policy could result in fewer sites being brought forward for development with an associated reduction in the number of homes of all tenures being developed.
There also needs to be recognition that the provision of new facilities as part of a residential led-development proposal can actively support the 20-minute neighbourhood concept and meet the local living agenda for already established communities developed without any or many amenities - i.e., benefits a wider area than just the new development.
Policy 7 (a)
It would be helpful to understand what weighting LDPs should be giving to the principle of 20-minute neighbourhoods / 800m compared to, for example, a brownfield first approach that might include a site which is more than 800m away from other facilities.
There is a lack of clarity on how this policy is to be applied in rural settings where local facilities are often spread over a number of settlements. Again, what is the weighting that should be applied to this particular policy compared to other relevant policies?
Policy 7 (b)
The policy states that ‘consideration should be given to’ a long list of facilities that constitute local living. For consistency in decision-making, it would be helpful to have guidance as to which of these are essential, how many should ‘reasonably’ be expected to be included and what can reasonably be delivered at a local level. Without such guidance, substantial differences in interpretation will appear.

We are supportive of the principle of infrastructure-first and wish to highlight that housing is an essential part of local and national infrastructure. We welcome the intention that more clarity will be provide up-front as to what is expected from developers. The main concern we have relates to how national level infrastructure requirements will be translated to local level. It is also necessary to provide clarification as to whether there will be an affordable housing position on this or increase in associated grant support (such as the Housing Infrastructure Fund) to offset additional infrastructure costs.
We would advocate that, given the funding and programming complexities all developers experience in project delivery, that the SG should give consideration to the formation of an Infrastructure Delivery body to direct, programme and co-ordinate future delivery and provide the confidence in plan making at LDP level when allocating sites and programming output.
Policy 8(a)
Alignment with the listed relevant infrastructure plan and policies is welcomed, however, we have no visibility of the content of these plans and how they translate in detail down to local areas. If these plans have clear local locational development implications, then clarity at a local level is essential immediately. Delays in translating these national strategies, infrastructure capacity studies etc a local level will delay the necessary timely preparation of LDPs. We require clarity on who is responsible for preparing these local infrastructure plans and the timescale in which they will be prepared.
Where the infrastructure required at a LA level is part of a wider national infrastructure network (e.g., electric grid) then clarification is required as to who, when and how these national investments will take place to facilitate the subsequent local development. Without this, local development will be delayed, and local communities will suffer.
We welcome that LDPs will indicate the type, level and location of contributions that new development will be required to make. However, we again seek much more clarity on how clearly, quickly and comprehensively this information will be available at local geographies to allow these financial implications to be factored into business investment decisions, providing more certainty over costs.

Positive:
· This policy recognises the need for a continuous pipeline of sites. However, there is a need to clarify the definition of Housing Land Pipeline.
· This policy could potentially reduce the variety of approaches across authorities, if generally applied.
· The specific policy aspects are perhaps workable if a more robust and flexible policy context is created.
· This policy focuses much more on deliverability than existing policy does.
· The introductory paragraph seeks to set out that the planning system should support the delivery of more and better homes. HFS supports this.
Negative:
· This policy does not specifically reference the housing crisis. The optics of NPF4 are that primacy is given to the climate and nature crises, above the housing crisis. It is vital that the impacts of each of these crises are fully acknowledged. The Institute for Fiscal Studies reported in 2018 that home ownership had fallen with steep declines among younger generations (‘The decline of homeownership among young adults’, 2018) Consequently, the proportion of adults living with their parents has increased and affordable housing waiting lists have increased. These are clearly not outcomes which are desirable or consistent with government policy.
· There are too few references to existing strategies (e.g. Housing to 2040), suggesting a siloed approach to the formation of this draft Framework.
· This policy does not come with a metric / indicator for when more homes may need to be delivered. Also, there is no mechanism to trigger a review of the Housing Land Requirement (HLR)s if under-delivery is a persistent issue.
· The policy wording contains several ambiguous / unclear terms e.g. what is a “small site” and what is a “rural place”? There is also confusion regarding the term “exceeding”.
· There needs to be a change of engagement protocols regarding Housing Land Audits (HLAs) moving forward, including the introduction of third-party monitoring. A robust guidance note on HLAs, particularly in terms of the planning status of sites to be included and programming based on consents status, is required. Paragraph 346 on Part C of the draft regs on LDPs sets out what is a short-, medium- and long-term pipeline site. However, these definitions need to be expanded. Also, it requires to be confirmed that HFS, the development industry and landowners will be consulted on in the preparation of HLAs.
Our overall view is that the policy as written will not succeed in achieving the objectives set out in question 31 and we have, therefore, recommended some amendments. A persistent underlying problem in the development plan system since the last planning reform has been the failure of many LDPs to allocate enough deliverable housing land to meet need and demand. This has been a source of tension and challenge between home builders, councils and the Scottish Government, and we therefore welcome a fresh approach to the matter.
It is critical that NPF4 contains provisions which both encourage the delivery of housing and enable the release of more land if not enough is being delivered by an LDP. We therefore welcome the emphasis of draft NPF4 on delivery, but the current wording in some places is not sufficiently clear or strong to ensure this happens in practice. We note the move away from the concept of a shortfall in the 5-year housing land supply triggering a ‘presumption in favour’ of development. Whilst in our view the current approach has logic and merit, we acknowledge that it had become a focus of disagreement and complexity in its practical application. There is an opportunity for NPF4 to establish a different approach, which is perhaps more transparent and comprehensible, around which consensus can be achieved.
Our suggested amendments to Policy 9 reflect the above commentary and deal with various other points as outlined below.

Policy 9(a)
This Policy states: “Local development plans should identify a housing target for the area it covers, in the form of a Housing Land Requirement. Representing how much land is required, it should at least meet the 10 year Minimum All Tenure Housing Land Requirement”.
“At least” is important here. It is vital that LAs are encouraged to plan for beyond the 10 years and for more than what the NPF4 requirement establishes. Clearer guidance is required with regards to the ‘beyond 10-year period’. A 15 – 20-year requirement should be established, and a reserve of deliverable sites be maintained. These sites can come forward earlier if the Housing Land Pipeline under-delivers and will also ensure continuity of supply beyond 10 years.
We are also concerned that this policy may restrict LAs to only plan to meet the HLR within their boundaries, rather than within Housing Market Areas/Housing Sub-Market Areas of which they are a part. As a counterpoint, it is important to not lose what has previously been gained, and a return to LAs effectively deferring meeting a requirement to the regional level must be resisted. An amendment to the text to capture this point is recommended.
Suggested Policy 9a text amendment: “Local development plans should identify a housing target for the area it covers (and should also consider any Housing Sub-Market Areas of which it is a part), in the form of a Housing Land Requirement. Representing how much land is required, it should at least meet the 10-year Minimum All- Tenure Housing Land Requirement (MATHLR) set out in Annex B. Local Development Plans should plan positively to identify more than the minimum requirement, particularly where there are housing affordability problems or there are other benefits that might arise from securing additional homes. Local Development Plans should also identify longer-term (beyond 10 years) deliverable housing sites to ensure the maintenance of the housing land supply beyond the end of the plan period and during the plan period if housing delivery shortfalls emerge.”
We have added a sentence, reflecting our concerns that many Councils will simply identify the MATHLR as the actual HLR. We have also referenced the need for LDPs to be required to include longer-term deliverable sites, beyond the 10 year plan period. We would suggest that this should reflect the HLR and provide an additional supply of housing for 5 years.
Policy 9(b)
The draft guidance on LDPs elaborates on the Housing Land Pipeline, defining what are “short,” “medium” and “long” term sites. The currently proposed system risks encouraging LAs to push back the programming of sites to later in the effective period (effectively operating a Post Year 7 “dump” of sites), as is frequently seen in the preparation of HLAs now.
HFS suggests the following changes to the below table, including the introduction of a fourth group of sites:

ONE Immediate term sites To be commenced in 1-3 years Including sites with full planning permission. This type of site should have all of its consents, DPP, RCC, STA and Building Warrant and be in the hands of a developer. Ideally, these sites should also be under construction. Should be allocated in the adopted LDP.

TWO Short term sites To be commended in 4-6 years Including sites with planning permission and allocations supported by masterplans, site briefs or equivalent. This type of site should have more than just PPiP. It should be in the hands of a party reasonably expected to develop it for housing in the period in question. There needs to be a clear delivery strategy for these sites. Should be allocated in the adopted LDP.

THREE Medium term sites To be commenced in 7-10 years In locations that align with the Spatial Strategy of the plan and have a pathway to delivery identified in the Development Programme but need to be available. Should be allocated in the adopted LDP.

FOUR Long term sites (Safeguarded land) To be commenced after Year 10 These sites align with the Site Assessment Methodology, are either free from constraints, or can be made free from constraints, and are available to come forward earlier if needed.

Overall, NPF4 represents a more positive approach to delivery. However, concerns remain regarding a possible Year 5 and Post Year 7 sites “dump”, as frequently seen on HLAs now. The above recommended alterations would alleviate these concerns.
It is positive that the policy states “Site de-allocation should be considered where they are no longer deliverable”. HFS supports this approach. However, it is unclear where the burden of proof will lie. Will it be for developers/landowners to effectively “prove” their sites are deliverable or will it fall upon LAs to conduct more rigorous assessments of all of the sites within their boundaries? If the latter, HFS would support the creation of guidance to assist LAs to assess sites on a consistent basis to ensure that assessments can be conducted in a timeous manner. It is important that the de-allocation assessment process does not become protracted. LAs must therefore be properly resourced.

The current policy is extremely limited with regards to the sites which can be brought forward to resolve an under-delivery of sites. This is currently limited to “longer-term deliverable sites.” If medium- and long-term sites from the pipeline do NOT address the delivery timeline then non-identified sites will have to come forward. The suggested addition of a fourth group of sites would lessen the concern regarding these limits. However, a more robust policy is required. Our suggested text amendments below to policies 9(b) and (i) seek to address this, as there appears to be no mechanism currently for sites not allocated within the Plan to be inserted into the Pipeline retrospectively where this is essential to maintain a credible Housing Land Pipeline.

The current policy wording minimises issues regarding bringing forward larger sites. For example, larger strategic sites that are in the longer-term pipeline may be unable to be brought forward as they may depend on other parts of the site coming forward first or their earlier release may generate a greater impact on infrastructure capacity than the originally envisaged longer phased release anticipated.
Suggested Policy 9b text amendment: “Local development plans should include a deliverable housing land pipeline should be established for the Housing Land Requirement. Representing when land will be brought forward, it should set out immediate, short, medium and long-term sites which can be supported by the infrastructure requirements of the spatial strategy. Where sites in the deliverable housing land pipeline do not progress to delivery as programmed, deliverable longer term or unallocated deliverable sites should be brought forward in line with Policy 9i below. Site de-allocation should be considered where they are no longer deliverable. The Delivery Programme and Housing Land Audit should be used to manage the development pipeline to maintain progress towards the minimum housing land requirement and not to manage the Pipeline to the minimum level.
Where sites in the deliverable housing land pipeline do not progress to delivery as programmed and alternative delivery mechanisms are not possible and there are no long-term deliverable sites that can be brought forward, local authorities can support new homes on land not identified for home building in the local development plan, in line with 9(i) below.”
We have amended the Policy wording such that the LDP should include its Housing Land Pipeline relative to the HLR. If these are depicted as trajectories then they will be simple to understand and it will be clear how the LDP is expected to perform. We think this graphical presentation could be utilised across the plan-making process and used simply to assess performance over the plan period.

We have added an additional category of land i.e. “immediate”, which we have cross referenced in our comments on the draft LDP Regulations. This relates back to our view above that the definition of “longer-term” sites are those identified as a reserve of sites beyond the plan period, which can be brought forward more quickly if required.

Policy 9(c)
Nothing here that would raise any concerns, outwith obvious issues relating to 20-minute neighbourhoods and an infrastructure-first approach which are covered by the HFS response to the relevant policies.

Policy 9(d)
Design requirements to be covered in HFS response to relevant policy.

Policy 9(e)
The requirement for a Statement of Community Benefit may be a positive step. It would provide home builders with an opportunity to promote the social and economic benefits of home building.
However, greater clarity is required as to exactly what would be expected to be included in the Statement.
It is also worth stating that providing such a Statement should be a responsibility for all new development, rather than being limited to housing.
There is reference to ‘improving the residential amenity of the surrounding area’. This requires further explanation, particularly with regards to how the development industry can be expected to deliver off-site amenity improvements?
Furthermore, the opportunity for LAs to extend this requirement to smaller proposals in rural areas risks allowing for an overly onerous approach to be adopted by some LAs.

Policy 9(f)
Reference to improving choice and to ‘a range of size of homes such as those for larger families’ is welcomed.
Current assessment methods in determining need and identifying households are inadequate. This is expanded upon in our response to question 57 below.

Policy 9(g)
Not relevant.

Policy 9(h)
This policy represents a major shift in emphasis. Current Scottish Planning Policy (SPP) says contribution should generally be no more than 25%. This has now been amended to “at least”. The encouragement to ask for more where there is evidenced need is dangerous, as LAs are likely to favour that option over viability concerns.
We do not think it is reasonable to require “at least” 25% affordable homes in the terms stated. We also think the current text could be interpreted to mean that affordable housing is required at a certain level even when there is no justification for it.
The suggestion that the contribution should generally be for serviced land is not widely utilised at present (and is at odds with glossary definition which retains the breadth currently in SPP).
It is positive to see the suggestion regarding exception / lower standards for small-scale developments or where there is evidence of impact on viability. HFS supports this. Affordable housing requirements should be informed by locally assessed need.
A new mechanism is required when seeking to facilitate a reduced affordable housing contribution. The current District Valuer approach is time consuming and inefficient.
Overall, we question whether the high requirements for affordable housing will be achievable in the context of a ‘brownfield first’ strategy, given the likely high abnormal costs of such development. Great care is needed with this policy as it is often the case that politicians have high expectations of what the private sector can deliver in respect to affordable housing and this can result in unrealistic LDP policies which have the effect of stifling all-tenure delivery. Although the current 25% benchmark has no particular basis for its derivation, to some extent it works in practice and is now understood and mostly accepted by home builders and landowners. The proposed policy context will encourage different percentages and possibly unviable amounts of affordable housing to be required across different council areas and within council areas. It is likely to result in a highly differentiated mosaic of requirements which will create uncertainty and confusion and lead to a significant stifling of the delivery of private and affordable housing
Policy 9(i)
This is essentially a policy mechanism to deal with land supply issues during the Plan’s lifetime to ensure that housing needs can continue to be met without automatically reverting to a full-scale LDP review. It sets out circumstances in which an authority would be able to give permission for land that is not allocated and in the Housing Land Pipeline for the LDP.
The fundamental issue with this policy is that it is far too limited. There is no circumstance that would enable a ‘normal’ housing site to be given permission unless all of the sites in the Housing Land Pipeline were underway.
The provision that LAs will be encouraged to draw from longer-term sites if delivery timescales are exceeded is expected, albeit the link to available infrastructure capacity is crucial. However, there exists a requirement to introduce alternative sites if delivery timescales are consistently exceeded and there are no sites in the long-term supply capable of ‘plugging the gap’. There must be a mechanism to permit housing on unallocated sites in the event that there are not enough deliverable short and long-term sites to meet the HLR.
The limitations of this Policy are exacerbated by para c) of Policy 30 – which means that even where more sites are released (because all the planned sites are underway) – these sites will all have to be on brownfield land.
More positively, there are some elements of support in this policy here for smaller-scale home building and it is important that this is retained. However, again, the exceptions could be expanded.
The overall wording of this policy is also problematic. There are ambiguous terms (e.g. “exceeding”) and the general tone is excessively negative. It is recommended the wording be altered to reflect a more positive approach (e.g. “sites will be supported, providing:”).
To allow for the pipeline to be maintained, and for a continuous supply of homes to be delivered, the LDP should include a Housing Delivery Pipeline and represent the accumulating delivery graphically, in a manner akin to Figure 1 below.
The Housing Delivery Pipeline should show accumulating expected completions from allocated sites over the plan period at yearly intervals. By year 10, the expected housing delivery over the plan period must meet or exceed the total minimum HLR as set by the LDP. Total housing completions since the beginning of the plan period will be reviewed annually in the HLA.
Where total completions since the beginning of the plan period in the latest HLA are higher or lower than both the accumulating HLR and the Housing Delivery Pipeline longer-term allocated deliverable sites should be brought forward.
Additionally, as set out below, in certain circumstances, sites not identified for home building in the LDP may be considered/supported, provided that they are consistent with the Site Assessment Methodology confirmed in the Evidence Report.
Suggested Policy 9i text amendment: “New homes on land not identified for housebuilding in the local development plan should be supported, and additions to the Housing Delivery Pipeline should be limited to circumstances where the planning authority determines that:
· overall progress in the build-out of sites included in the housing land pipeline is significantly exceeding delivery timelines set out in the housing land pipeline; or
· there is a significant under delivery of housing required to achieve the housing land pipeline and housing land requirement; or
· the proposal is consistent with policy on rural places; or
· the proposal is for a new home or homes on a small site within an existing residential area; or
· the proposal is for the delivery of affordable homes of less than 50 units as part of a local authority supported affordable housing plan.
If accumulating housing delivery is 10% less or 10% more than shown in the Housing Delivery Pipeline, longer term deliverable sites should be brought forward. If accumulating housing delivery is 20% less or 20% more than shown in the Housing Delivery Pipeline for two consecutive years, then longer term deliverable sites and/or unallocated sites should be brought forward, which are consistent with the plan spatial strategy and other relevant policies. The development management process should ensure that such sites can be commenced within 2 years of receiving planning permission.”
This policy process is outlined graphically in Figure 1 below. It is also important to emphasize that infrastructure capacity constraints can be met by developers as well as providers.
A presumption in favour of sustainable, non-allocated sites is introduced in circumstances wherein the Accumulating Delivery either exceeds or falls short of the Housing Delivery Pipeline by 20% or more, for 2 consecutive years.

FIGURE 1 INCLUDED IN PDF VERSION OF RESPONSE
Figure 1: Housing Delivery Pipeline – Graphical Representation, Including Release Mechanisms
We accept that the buffer percentages and the period of over or under-delivery that would trigger the release of longer-term or unallocated sites should be subject to detailed consideration, but they seem to us to strike a reasonable balance. It is, in our view, essential that clear and objective criteria are identified, otherwise there will be constant disagreement as to when and how the provisions are to apply. We would anticipate that such a graphical representation would be prepared by councils on a yearly basis as part of the HLA.
Policy 9(j)
Not relevant.

This policy will contribute to increasing sustainable transport choices and many home builders are already delivering on many of the expectations of this policy. However, land use planning alone will not deliver the shift to sustainable transport and the policy will be ineffective unless it is supported by a significant change in individual consumer behaviours and decisions and backed by substantial investment in public transport. All development will have a car impact as the decision to own a car is not just directly related to the location and layout of homes and communities, involving much more nuanced and personalised choices such as confidence in the reliability or safety of other modes of travel.

Much more clarity and commitment is required from public transport providers with regards to the scale, nature and timing of their investment to allow this policy to be realistic and achievable.

Policy 10 (c)
Clarification is required as to what a “significant increase” is so that developers are clear as to what level of development may trigger a requirement for an additional transport assessment. Is this a policy to be set at a local level and, if so, how is consistency to be applied across Scotland?
Policy 10 (d)
We are unclear as to what the definition is of a “smaller scale development”. If this is not clearly defined it will lead to subjective decisions and a lack of clarity for developers and communities.
Policy 10 (f)
We consider that the issue of the provision of new junctions on trunk roads is a function of Transport Scotland and it is not appropriate to include this policy in NPF4. Furthermore, it is unclear as to how “significant prosperity or regeneration benefits” are defined and measured.

Policy 10 (h)
It is more appropriate that the 400m reference is guidance and not policy.

HFS supports the strategy of heat networks and there will be occasions when viability and timing could allow for their integration within new housing developments. However, it needs to be part of a flexible approach with an understanding of commercial, practical and viable constraints with regards to connection to heat networks. In addition, it is essential that this policy is entirely aligned with Building Standards Regulations. This policy needs to be clearer on what is intended to be achieved by its inclusion in a planning document when heat is already governed by Building Regulations.
Policy 11(a)
HFS supports the consideration of existing and planned heat networks when considering the allocation of land however this should not be a limiting factor.
Policy 11(c)
This clause requires clarification on the meaning of ‘cost-effective’ and who would be liable for the connection costs in the future i.e. the home builder or the home owner? This clause must be entirely aligned with Building Standards Regulations.
Policy 11 (d)
This clause should be deleted as heating systems are controlled by Building Regulations.
Policy 11 (g)
This clause should be deleted as energy systems are controlled by Building Regulations.
Policy 11 (i)
This clause should be deleted as air conditioning is controlled by Building Standards.

New home building continues to successfully deliver quality places incorporating blue and green infrastructure and opportunities for play and sport. There needs to be clarity on its implementation in order to avoid inconsistent interpretations across each LA. Additionally, the clauses dealing with blue infrastructure must entirely align with regulations governed by LA Roads departments, Scottish Water and SEPA.
Policy 12 (a)
HFS supports the protection of blue and green infrastructure, however, LDPs should also identify opportunities for new development that can enhance existing assets.
Policy 12 (b)
Blue infrastructure and play opportunities for children will not necessarily be achievable on the basis of health and safety.
Policy 12 (c)
This clause should refer to the overall quality of existing green and blue infrastructure. LDPs should take into account whether a new land allocation has an opportunity to improve the quality of blue and green infrastructure.
Policy 12 (h)
There will need to be a flexibility when considering the redevelopment of brownfield land. These sites tend to be more restricted for space and, with deliverability in mind, they may not be able to meet all of the aspirations of this clause.
Policy 12 (j)
Designing Streets was published in 2010 and therefore needs to be reviewed and updated. It is essential that within LAs the views of the roads department are aligned in order that new streets and public realm are constructed to an adoptable standard. Conflicting views between planning and roads departments has proven a challenge to new home building delivery in the past and NPF4 should be looking for proactive solutions. HFS would also note that Designing Streets does not promote the use of cul-de-sacs in order to maximise connectivity throughout a development, however, these were traditionally utilised by children as safer spaces for informal play. It also appears to prioritise vehicular connectivity over active travel permeability.


Policy 12 (l)
This clause reinforces the importance of blue and green infrastructure being designed and delivered in alignment with Scottish Water and LA roads regulations to ensure it can be adopted and maintained. HFS requests that the wording in the final sentence is altered to ‘…local authority before first occupation’ as it is not always achievable prior to construction starting.

HFS agrees that flood risk analysis will remain an important factor within the planning system when allocating land and determining planning application. The guidance within NPF4 must align with SEPA and Scottish Water regulations in order to provide certainty in decision-making.

HFS is supportive of a policy that promotes physical and mental health and wellbeing. The provision of a warm and good quality home within an area that is safe and pleasant to move around is central to physical and mental health.
Policy 14 (a)
This clause would benefit from a definition of what is meant by ‘infrastructure’.
Policy 14 (b)
This clause needs to define ‘significant adverse health effects’. HFS recognises the introduction of a requirement for all National, Major or EIA developments to provide a Health Impact Assessment (HIA). HFS requests that guidance is produced to outline what a HIA should include and how they are to be used by LAs during the determination of a planning application. This would preclude different interpretations of what is required by an HIA across each LA. Additionally, HFS is concerned about the lack of skilled resource within LAs to appropriately assess a HIA, which could lead to delay and uncertainty at planning application stage.
Policy 14 (c)
The term ‘significant adverse’ needs to be defined in order to provide certainty and consistency across the country.
Policy 14 (d)
The term ‘unacceptable’ needs to be defined in order to provide certainty and consistency across the country. Additionally, it needs to be recognised that a flexible approach may be required if the goals of reuse of vacant and derelict land are to be met. These types of sites are often closer to noise emitters e.g. railway line, road, factory etc. Therefore, LAs should feel confident in applying planning balance and weight to noise considerations.

No comment from HFS.

No comment from HFS.

No comment from HFS.

No comment from HFS.

Policy 20 (b)
There needs to more guidance on the use of materials with the lowest forms of embodied emissions. What level of detail will be requested at planning application stage? It is not clear what level of embodied carbon is deemed acceptable or not and therefore this policy risks causing delay and uncertainty to the planning system. Are LAs equipped/skilled to deal with these matters? This policy also needs to take into account the implications of the preferred brownfield strategy i.e. impact of demolitions needs to be considered.
Policy 20 (c)
There needs to be substantial guidance on how national and major developments should take into account circular economy principles. Without adequate guidance this policy risks causing uncertainty and delay to the planning system.

No comment from HFS.

No comment from HFS.

No comment from HFS.

Sites within these areas must still be required to meet the standard tests of deliverability, particularly in reference to noise/parking constraints, surrounding uses and access. The sites must be deliverable, particularly in terms of ownership.
If the site is not in the hands of a developer, the LA must have issued a CPO for it to be included as either an Immediate or Short-term site. Sites must be available. LAs must do more than just be ‘proactive’ in identifying opportunities and must ensure sites that are programmed to come forward are viable, available and deliverable.
Compulsory purchase powers outlined under Planning Circular 6/2011 are referenced in Part 4 of NPF4. More information is required to determine how this can be delivered in practice, particularly at scale, especially given the resourcing issues currently facing many Local Authorities.
A balanced approach is required. HFS does not disagree with the notion of allocating sites for residential development within town centres. However, this should not be at the expense of placemaking principles, or amenity.
Policy 18 of the draft NPF4 refers to the Agent of Change principle, stating “Development proposals within the vicinity of existing arts venues should fully reflect the agent of change principle. They should only be supported where they can demonstrate that measures can be put in place to ensure that existing noise and disturbance impacts on the proposed development would be acceptable and that existing venues and facilities can continue without additional restrictions being placed on them as a result of the proposed new development.” This is important to consider in the allocation of sites in town centre areas.

HFS is supportive of the intentions of this policy, however, there needs to be clarity on its implementation in order to avoid inconsistent interpretations across each LA. The language used throughout this policy is subjective e.g. ‘significant’ and ‘affecting’ lacking any quantifiable benchmark which is likely to lead to confusion and delay for both LAs and applicants.
Policy 28 (a)
This policy intention is that LDPs and their spatial strategies should identify, protect and enhance locally, regionally, nationally and internationally valued historic assets and places. This is a positive policy focus and is broadly supported.
Policy 28 (b)
There is an overall lack of definition in this section with the word ‘significant’ having no measurable quantification. This leaves the policy open to interpretation and challenge which will in turn lead to uncertainty for both the applicant and LA at planning application stage.
Policy 28 (e)
It is important that LAs maintain up-to-date Conservation Area Character Appraisals to ensure they remain relevant.
Policy 28 (j)
The wording of this clause is not clear and is open to interpretation. There needs to be a clear understanding of what ‘affecting’ means. Also, there needs to be a definition of ‘special qualities’.
Policy 28 (o)
This policy section is confusing and contradicts part (a) of Policy 28. There is no certainty or visibility over what a LA considers to be a ‘non-designated historic environment asset’. This section needs to clarify its intended purpose and use in determining development proposals.

This policy represents an impossibly high bar to meet. Furthermore, this policy is a green belt policy, not an urban edge policy, and should be renamed to reflect this.
Green belt release may be required to contribute to wider NPF4 policies, objectives and strategies.
‘Peri-urban’ development is not inherently unsustainable. In fact, it is precisely these areas where 20-minute neighbourhoods could be, and should be, easily introduced. In instances where the promoted site is deliverable and there are not enough deliverable and more sustainable brownfield sites, it should not be beyond the LA’s remit to approve these sites.
The policy wording in its current form may encourage LAs to adopt a brownfield-only approach, whilst also either disincentivising them from conducting a green belt review, or only reviewing a green belt under the guise of extending green belt boundaries. New green belt land should only be designated in exceptional circumstances.
Reference to green belts being directed towards the most “accessible” areas is concerning, as it is precisely these most accessible areas that are the most sustainable, at least in terms of public transport access. It should not be the goal of policy to restrict the delivery of sustainable sites on ideological grounds.
Scottish Planning Policy (SPP) 2014 defines the function of a green belt as: directing development to the most appropriate locations and supporting regeneration; protecting and enhancing the character, landscape setting and identity of the settlement; and, protecting and providing access to open space. This current definition is well understood. The drafted policy wording risks reframing the green belt as an area which is inherently anti-development.
Suggested policy text amendment:
“The Green belt
We want to increase the density of our settlements, restore nature and promote local living by using the land around our towns and cities wisely. Urban expansion may be necessary to accommodate housing and economic development needs.
Green belts can be used as a settlement management tool around Scotland’s towns and cities to help to direct growth to the most appropriate, sustainable locations. Green belts can have a role in protecting and enhancing the character, landscape and natural setting and identity of settlements, providing outdoor access to green networks which link urban and rural areas and supporting nature networks. A green belt will not be necessary for most settlements, as other policies can provide an appropriate basis for directing development to the right locations, and protecting nature, landscapes and green networks.
Policy 29: The Green belt
a) Local development plans should consider using green belts where appropriate in some of the most pressured rural or peri-urban areas, where there is significant danger of unsustainable growth in car-based commuting. In such circumstances green belts can provide a more restrictive approach to development, to benefit quality of life and environment in our cities and towns, increase urban density and minimise the need to travel using unsustainable modes. In circumstances where an urban edge site is well located in respect of active travel options, can provide/contribute to a 20-minute neighbourhood, and can be supported by necessary community infrastructure, its inclusion within the urban area should be considered if there are insufficient sustainable and deliverable brownfield sites to meet the local development plan’s development requirements. Green belts should be identified and reviewed when preparing plans with detailed boundaries clearly identified.
b) Development proposals within a green belt designated within the local development plan should not be supported unless for:
• development associated with agriculture, woodland creation, forestry and existing woodland (including community woodlands); residential accommodation required and designed for a worker in a primary industry within the immediate vicinity of their place of employment where the presence of a worker is essential to the operation of the enterprise, or retired workers where there is no suitable alternative accommodation available;
• horticulture, including market gardening and directly connected retailing, as well as community growing;
• recreation, outdoor sport, leisure and tourism uses that are compatible with a countryside or natural setting; and developments that provide opportunities for access to the open countryside (including routes for active travel);
• flood risk management (such as development of blue and green infrastructure within a ‘drainage catchment’ to manage/mitigate flood risk and/or drainage issues);
• development meeting a national requirement or national, regional or local established need, if no other suitable site is available;
• essential infrastructure (such as digital communications infrastructure, telecoms infrastructure, electricity grid connections, transport proposals and travel networks identified in the local development plan, or new cemetery provision), where these cannot be accommodated anywhere other than the green belt;
• minerals operations and renewable energy developments (where located within an identified area of search);
• intensification of established uses, including extensions to an existing building where that is ancillary to the main use;
• the reuse, rehabilitation and conversion of historic environment assets; and
• one-for-one replacements of existing permanent houses currently in occupation.
c) Development proposals in respect to (b) above will be required to provide a statement identifying the search area and the site options assessed, proportionate to the scale of development proposed, where applicable the details of the existing or proposed activity to which the proposal relates, and the reasons as to why a green belt location is essential. The primary consideration will be whether the development could instead be located on an alternative site outwith the green belt. Proposals should also support the qualities of successful places and safeguard historic environment assets and green and blue infrastructure. In particular all such applications should ensure the development:
• does not undermine the purpose of the green belt at that location;
• is fully compatible with the surrounding established countryside and landscape character;
• is of a scale, massing, external appearance, and uses materials that contribute to harmony with the visual character of the green belt;
• has no unacceptable long-term impacts on the environmental quality of the green belt (although mitigation processes may be a factor in limiting long-term impacts and should be considered as part of any consideration).

HFS is supportive of the reuse of vacant and derelict land as an important part of housing delivery. The delivery of housing to meet future needs across Scotland will be reliant on a balanced and resilient land supply to meet each council’s housing land requirement. A blended approach to land allocation that includes greenfield, brownfield and vacant and derelict land is therefore required to ensure the on-time delivery of new housing across all tenures. Additionally, brownfield can support a mix of uses, beyond housing, that will be essential to ensure the social and economic sustainability of our towns and cities. Therefore, vacant and derelict cannot be the sole provider of housing land.
Policy 30(a)
It is agreed that LDPs should seek to reuse vacant and derelict land and redundant buildings, however, not always as a priority when allocating land for housing development. The home building sector relies on a blend of greenfield, brownfield and vacant and derelict land coming forward in order to successfully meet the all-tenure housing needs of our country. This policy will require LAs to always prioritise vacant and derelict land with no clear evidence as to why. These types of sites have proven successful for the delivery of new homes but they should not be at the expense of the release of potentially more suitable greenfield sites. Suitable could mean that greenfield sites are in better serviced and connected locations, can provide greater bio-diversity net gain than vacant and derelict land or are better equipped to support the 20-minute neighbourhood principle. In addition, a blend of land allocation that includes greenfield allows homes to be delivered in a more consistent timeline given the cost and practical considerations. There is no funding strategy offered within NPF4 to assist with the delivery of V&D sites as a priority.
Policy 30(c)
This section needs to be deleted. A test for alternative sites is required. Eliminating all greenfield sites would result in the most deliverable sites not always being brought forward. Brownfield sites are more likely to have physical and financial constraints meaning that often they cannot be delivered with certainty and/or in a timely manner. It is unclear why this policy position is within Policy 30. Notwithstanding the position that this clause should be deleted, given it relates to housing delivery it should have been embedded into Policy 9 for greater visibility during this consultation period. The language is also questionable with words such as ‘explicitly’ and ‘suitable’ adding no clarity or certainty to the delivery of land for new homes.
Policy 30 (d)
LDPs play an important role in allocating land that is deliverable. This includes the viability and practical considerations of an unstable or contaminated site. It is unclear from the wording on whom the onus will be to ensure that the land is, or can be made, safe and suitable for the proposed new use and to what extent evidence will need to be provided.
Policy 30 (e)
The requirement for this clause to be within Policy 30 is not clear and it should be deleted. There are other policy frameworks throughout NPF4 that deal with the reuse of existing buildings and their associated demolition e.g. Policy 28 Historic Assets and Places. This policy is overly restrictive and it is not clear why demolition should always be the ‘least preferred option’. This wording is subjective and ambiguous and therefore not helpful to decision-makers or applicants. This clause would appear to be at odds with policy 30 as many vacant and derelict sites will have existing buildings on them. Often, demolition is essential to the delivery of a high quality and deliverable development.

HFS is supportive of a policy framework that ensures that the social and economic challenges specific to rural places are being met. However, we do not believe that this section will help to counter population challenges or housing needs in rural areas. To ensure the long-term sustainability of rural places, NPF4 needs to recognise that they operate differently to urban and suburban areas and therefore require a more flexible and specific approach to planning policy. Outcome (c) with Annex A seeks to increase the population of rural areas of Scotland. Policy 31 will not meet the requirements of this outcome as currently written.
Policy 31 (a)
The policy intent outlined in this section is and should be a key outcome for NPF4. However, the clauses that follow, in practice, will not support the overall policy intent. Instead, the overall policy lacks vision and ambition for the sustainability and prosperity of rural communities and economies.

Policy 31 (b)
It is not clear what is intended by this clause and what planning balance/weighting should be given to either the resettlement of a previously inhabited area or climate change targets.

Policy 31 (c)
Rural places and settlements present unique circumstances across Scotland and therefore a flexible and innovative approach will be required to ensure the policy aims are met. It is overly restrictive that the redevelopment of vacant and derelict or brownfield land should only be supported where a return to a natural state is not likely. This type of wording does not appear in Policy 30 and it is therefore not clear why it has been used in Policy 31. It is recognised that sustainable settlements and 20-minute neighbourhood concepts are central policy aims, however, given the wider economic and development pressures within rural places flexibility must be applied when considering development proposals.

Policy 31 (f)
This clause will not support the policy aims of supporting, sustaining and growing rural areas. It is not clear how a LA will decide what level of home building would, or would not, lead to the unsustainable growth in long-distance car-based commuting or suburbanisation of the countryside. Car use will inevitably be higher in rural areas where they lack public transport connections or local services. However, the introduction of new homes can assist with the overall sustainability of a rural place by helping to sustain and grow local services and create greater economic justification for the funding of public transport. It also needs to be recognised the much greater prominence of home working over the last few years, particularly post Covid.

Policy 31 (h)
It is not clear why this clause is within the rural places policy when prime agricultural land is as commonly adjacent to urban/suburban settlements as it is to rural places.
The first sentence is confusing as it refers to prime agricultural land but also to ‘land of lesser quality that is culturally or locally important for primary use’. The latter description of land is entirely open to interpretation and gives very little certainty to the delivery of new homes. The first bullet point refers to ‘essential infrastructure’. This needs to be further explained as to what that would include. The word ‘suitable’ is subjective and needs a description. There should be another bullet added to the list that permits support for allocation of prime agricultural land to reflect an identified development need.
The final bullet point refers to minimising the amount of ‘good quality land’ that is required for development proposals. To provide certainty and avoid interpretation there needs to be a description of good quality land. The use of prime agricultural land for development must take account of local context e.g., what proportion of prime agricultural land would be lost across a wider regional bank of that type of land. The loss of 10 acres, for example, could be potentially offset by the wider social and economic benefits of redevelopment.

Policy 32 (b)
It is not clear from this policy what an ‘unacceptable impact’ would be defined as. This wording would leave it open to interpretation across each LA. Would an appropriate assessment be required to quantify the extent/level of impact?

Policy 32 (d)
The wording of this clause is clear and largely quantifiable. Could this clause replace part (b) if the intentions are the same?

Policy 32 (f)
This clause is required by law. Is it therefore necessary to repeat within NPF4?

Policy 32 (g)
The wording of ‘significant adverse affects’ is open to interpretation and subjective. However, the wording that outlines where an effect could be clearly outweighed by social, environmental or economic benefits of local importance is welcomed as it allows planning balance and weighting to be applied on a case-by-case basis.

No comment from HFS.

No comment from HFS.

No comment from HFS.

HFS agrees that the ability to align resources in a collaborative manner will play a central role in delivering the spatial strategy. However, the wording in this section fails to provide any detail on how this will be achieved. The private sector’s role cannot not be underestimated and should therefore be mentioned in the context of wider stakeholder engagement/alignment including LAs (wider than just planning departments), key agencies, investors and central government. The delivery plan and supporting financial commitment will be a key test for the deliverability and effectiveness of NPF4.
As HFS’s response to policy 8 states, Infrastructure First should be seen as a positive as long as it can be implemented effectively. For this to happen there needs to be a robust structure for early stakeholder engagement and a clear financial strategy for front funding and cost recovery. There is an opportunity for LAs to take a more proactive role in infrastructure planning, however, this will require that they are properly skilled and resourced, with the ability to draw on funds. It is not clear from this section how those challenges will be met. HFS is concerned that if this policy cannot be implemented effectively then it could become a blocker to development which is clearly contrary to its aims. There needs to be more information on how this policy will link with Planning Obligations in a fair and balanced approach that will maintain the essential delivery of new housing.
The section on Regional Spatial Strategies (RSSs) does not provide any further clarity on their intended role and how they are to be implemented. The Action Areas in part 1 hint at a linkage to RSSs but it isn’t clear exactly how they will connect. The Central Belt Action area covers such a wide area of Scotland it is hard to envisage how that section could relate back to the production of RSSs. It isn’t clear from NPF4 what planning weight RSSs will carry or where they will be placed in the hierarchy planning system next to LDPs and NPF4. NPF4 also doesn’t propose a timeline for production of RSSs.
Policy 9 Housing must align with the LDP Regulations consultation with a focus on remedies when a Housing Land Pipeline isn’t being delivered. Tools such as HLAs and two-yearly delivery reviews will be essential as part of this evidence checking and must be undertaken transparently and properly consulted on.
Regarding Local Place Plans (LPPs), Homes for Scotland (HFS) notes the publication of Circular 1/2022: Local Place Plans, which provided guidance on the preparation, submission and registration of LPPs. Whilst this does provide a degree of clarity as to the function of an LPP, as well as their weight in the preparation of an LDP, Part C of the Draft Guidance on Local Development Planning does raise some questions. Paragraph 22 states: “Local Place Plans (LPPs) have an important role to play in voicing the aspirations of local people. Where they have been prepared, the community’s proposals are able to be incorporated into the LDP. This will help LDPs reflect their communities’ place-based aspirations.” This paragraph requires to be amended to confirm (as stated in the Circular) that LPPs sit outwith the development plan. Paragraph 92 states “Planning authorities must take into account any registered LPP when they are preparing or amending an LDP (section 16(2)(a)(iii)). The Evidence Report must set out how communities have been invited to prepare LPPs and the assistance provided to them (section 16B(3)(d)).” This is an unclear statement and more needs to be done to clarify exactly the weight a registered LPP can have upon LDP preparation.
Overall, it is not clear how LPPs will “support delivery”, rather than merely reflect local opposition to development. There appears to be no scope to incentivise local groups preparing these LPPs to include an element of development within the area their LPP covers. Reference is made to “community wealth building”, although there is no clear definition of what this means.
There is no detail on how a more positive and proactive approach to land assembly will be implemented. The increased use of compulsory purchase powers will rely on adequate skills and resourcing within LAs and must be reinforced by clear and accessible funding initiatives.
HFS is supportive of a better resourced planning service and recognises the clear linkages of this to Scotland’s economic recovery and future success. Planning fees will be increased again from 1st April 2022. It isn’t clear at all how an increase in planning fees will improve the resourcing, upskilling and decision-making within LAs. The policies within NPF4 have no clear hierarchy and as written are likely to make decision making slower and provide less clarity to the applicant or the decision maker. Planning fees must be ring fenced within LAs so that they have a direct link to the resourcing of development management services. As well as increased funding for additional planning resources, a national strategy for planner ‘employment, development and retention’ is required. This could involve apprenticeship/internship schemes, post graduate financial support or mentoring programmes.
Monitoring of NPF4 will be essential to its successful implementation. HFS requests that it is consulted fully on the development of a monitoring system, which it is expected will include frequency of review, pre-determined success criteria and remedial strategies.

Part 4 provides too little information on delivery options and puts nothing new on the table. The delivery plan and supporting financial commitment will be a key test for the deliverability and effectiveness of NPF4.
When LAs consult on their new style proposed LDPs, they will, rightly, be required by regulation to also publish a draft proposed delivery programme that has been approved by their full Council. This will show the actions that need to be undertaken to deliver the plan policies and proposals, name the person responsible and give a date for each action to be undertaken.
The Scottish Government has not provided a clear explanation as to why it has not led by example by accompanying draft NPF4 with a draft delivery programme. We do not agree with the view, expressed by the Planning Minister in introducing draft NPF4 to parliament, that it would have been presumptuous to provide a full draft delivery programme alongside draft NPF4.
There must be a ‘Just Transition’ with the adoption of NPF4. LAs and stakeholders of the planning system need to understand how timescales will work for its implementation i.e. if a major application for housing is submitted in April, NPF4 is adopted in August and the major application remains undetermined, does it then need to go back and include for example a Whole Life Assessment of Greenhouse Gas Emissions, or a statement on Community Wealth Building or be measured on 20 minute neighbourhoods etc? The transitional detail will be critical in ensuring the flow of new housing delivery is maintained
In summary, this section is drastically lacking in detail and much of the success of implementation of NPF4 is reliant on the delivery mechanisms and associated financial commitments that will be put in place. HFS believe it is vital that the consideration by parliament and adoption of NPF4 does not come before the delivery proposals are published in full and properly consulted on.

The six outcomes are:
a. meeting the housing needs of people living in Scotland including, in particular, the housing needs for older people and disabled people.
HFS does not believe that the development measures identified will meet the housing needs of people living in Scotland, particularly the housing needs for older people and disabled people. There are a number of reasons why this is the case:
1. The MATHLR numbers are too low with some LAs having less numbers than have been completed in the last ten years.
2. Not all LAs have undertaken a robust review of the housing numbers as initially published in 2021.
3. The two main components of the MATHLR are household projections and the HoTOC assessment of unmet housing need. As identified in our response to Q.57 both of these components have important flaws.
4. The HNDA tool does not adequately identify all households in need with a very restrictive dataset only taking into account two types of need. It does not identify the specific needs of older people whether that be their house no longer meets their needs or that it is too big for them. With an ageing population in Scotland that is forecast to increase, it is essential that the needs of older people are recognised as an integral part of our housing system.
5. There is no policy remedy in NPF4 to enable LAs to identify new housing allocations in the circumstance that the pipeline is under delivering and the longer-term sites cannot fill the gap.

b. improving the health and wellbeing of people living in Scotland.
The ability to access a warm and safe home that meets the needs of the occupier and is affordable to them is a central driver to improving the health and wellbeing of those living in Scotland. HFS believes that this outcome must be linked to outcome (a). HFS is supportive of the overall aims of the policies that relate to Health and Wellbeing (Policy 14), 20 minute neighbourhoods (Policy 7) and green infrastructure. Specific policy responses have been provided.

c. increasing the population of rural areas of Scotland.
HFS is supportive of a policy framework that ensures that the social and economic challenges specific to rural places are being met. However, we do not believe that NPF4, and specifically Policy 31, will help to counter population challenges or housing needs in rural areas. To ensure the long-term sustainability of rural places, NPF4 needs to recognise that they operate differently to urban and suburban areas and therefore require a more flexible and specific approach to planning policy. Policy 31 lacks vision and ambition for the sustainability and prosperity of rural communities and economies.

d. improving equality and eliminating discrimination.
It is disappointing that there is not currently a specific Human Rights Impact Assessment. Housing is a human right. It is defined as such under Articles 17 and 25 of the Universal Declaration of Human Rights. It is even referenced as such in Part 4A of Housing to 2040. However, there is no reference to this within NPF4, nor any of the supporting documents. With the supply of new homes being increasingly restricted as a result of local and national policies that don’t adequately reflect or respond to need (and the associated rising concerns of affordability, homelessness and access to adequate housing), it is fundamentally vital that Articles 17 and 25 of the Universal Declaration of Human Rights be afforded weight in the preparation of NPF4. There remains a significant amount of work to do to ensure that everyone in Scotland has access to a safe, secure and affordable home.
NPF4 needs to provide a definition for ‘Community Wealth Building’.

e. meeting any targets relating to the reduction of emissions of greenhouse gases, within the meaning of the Climate Change (Scotland) Act 2009, contained in or set by virtue of that Act.
It is not clear how the “significance” of emissions will be measured. Will it be relative to the scale and type of development (and a matter of qualitative judgment), or a fixed threshold? The requirement for national, major or EIA developments to provide whole-life assessment is not currently possible in the absence of a standardised measurement tool. In addition, the skills to adequately interpret such information are not currently embedded in LAs. The circular economy is mentioned, however, there is insufficient advice and guidance available to business and LAs to fully understand and plan for this going forward.

f. securing positive effects for biodiversity.
Policy 3 does not provide parties with sufficient clarity on how impacts or mitigations can be measured. For example, it is not clear how the “significance” of biodiversity enhancement will be measured. The policy presumes that biodiversity enhancement is best achieved through restoration. However, that might not apply in all cases. In some cases, introduction may be more effective than restoration. Instead of restoration, the policy could simply refer to the “enhancement of biodiversity”. HFS is supportive of the intentions of policy 12 Blue and Green Infrastructure and new home building continues to successfully deliver quality places incorporating this essential part of infrastructure. There needs to be further clarity on its implementation to avoid inconsistent interpretations across each LA. There will also need to be flexibility when considering the redevelopment of brownfield land. These sites tend to be more restricted for space and, with deliverability in mind, they may not be able to meet all of the aspirations of Policy 12.

NOTE: OUR RESPONSE TO THIS QUESTION IS CONTAINED WITHIN, AND BETTER READ IN THE CONTEXT OF, OUR PDF VERSION OF THIS RESPONSE. TABLES AND GRAPHS ARE NOT DISPLAYED CORRECTLY HEREIN.

No

1.0 Summary Reasoning
These numbers do not support the objective of increasing the delivery of new homes.
We would expect LAs to have undertaken significant further work on these numbers by the end of this consultation period, building on the best practice of those authorities who previously fully engaged. HFS would certainly have expected the Scottish Government to have undertaken some degree of critical analysis of the returns received to ensure they are content with presenting the figures within their part of the Development Plan.
HFS has proposed alternative MATHLRs for some authorities, in our alternative Annex B. The methodology we have used is based on the Scottish Government’s own steer on considering, and not dipping substantially below, past completions levels. We have used the same flexibility allowance of 25% (in urban areas) or 30% (in rural areas) as applied by the Scottish Government.
The two main components of the MATHLR are household projections and the HoTOC assessment of unmet existing housing need. Both have important flaws which mean that they systematically underestimate housing need and demand. Using such a limited assessment of housing need and demand is inconsistent with the aims of achieving an inclusive economy and the aspiration to provide housing choices outlined in Housing to 2040 and draft NPF 4. It will undermine the ability of Scotland to deliver the outcomes set out in NPF4, particularly reducing inequalities, giving opportunities to all and creating sustainable and inclusive growth.
2.0 Context
Annex B assigns each local authority a ‘Minimum All Tenure Housing Land Requirement’ (MATHLR). These set the tone for how much housing land is likely to be allocated in each part of Scotland for the first 10 years of the new planning system.
For reasons HFS has outlined at length throughout earlier stages of planning reform (see summary of methodology issues in the attached paper (Appendix B of our response)), the MATHLRs are an underwhelming response to the new legislative requirement for NPF4 to contain targets for the use of land in different parts of Scotland for housing (Section 3A (3A) (a) of the Town and Country Planning (Scotland) Act 1997). Because the method through which they were derived does not seek to grapple with the question of how many homes Scotland needs (lack of evidence on housing need has also been cited in research by ALACHO and CACHE as a barrier to the development of good policy on housing as a human right: https://housingevidence.ac.uk/news/housing-is-a-human-right/), these numbers undermine the statutory outcome of meeting the housing needs of people living in Scotland (Section 3A (3) (d) of the Town and Country Planning (Scotland) Act 1997).
Increasing the delivery of new homes was the original purpose of planning reform (source: A Stronger Scotland: Programme for Government 2015-16). It remains a necessity, as demonstrated by ever-increasing house price and rental inflation, and by huge demand for new homes.
As part of the statutory development plan for all parts of Scotland, NPF4 has unique bite amongst Scottish Government policy documents. It forms the top tier of the development plan, replacing strategic development plans. It tells LAs what they should do in their own LDPs. It will inform every planning decision. It should therefore be a game-changing plan for housing ambition in Scotland and for implementing the commitments set out in Housing to 2040. Instead, it plays an inappropriately passive role in setting the tone for housing ambitions. It prevents local authorities from planning for fewer homes that are represented in the MATHLR numbers, but it does not require them to plan for more than they are building now.
It is clear from the Scottish Government’s own assessments (an assessment for each authority / region is available on the Transforming Planning website) that it is not content that every LA has done enough work to sense-check and inform their figures and ensure they reflect and support national, regional and local policy objectives. HFS agrees. It is essential that the Scottish Government does not roll forward any figures into the final version of NPF4 unless they have been fully sense-checked. We have provided alternative figures for some areas, based on the Scottish Government’s own preferred approach, for use if not all authorities use this consultation period to evolve their numbers themselves.

3.0 Summary of Methodology Issues
The numbers are derived in part from national datasets. Our strong reservations with those datasets and the way in which they have been applied are set out in full in the ‘OVERCOMING DATA LIMITS: EXISTING NEED AND NEWLY FORMING HOUSEHOLDS’ section of our separately provided paper (Appendix B).
In short, the national dataset on existing housing need is very limited. It takes an incredibly limited view on what constitutes ‘need’ (see below).
Existing Need Count: The existing household need count included in the Scottish Government initial default estimates of need and demand only cover two very acute forms of need:
· Homeless households in temporary accommodation
· Overcrowded households that include at least 1 concealed family (excluding single people)

FIGURE 3 INCLUDED IN PDF VERSION OF RESPONSE
Figure 3: Existing Housing Need not included in default HNDA input data

Type of Existing Household Need Description and Example
An overcrowded (but not concealed) household. A household living in a home that has too few bedrooms for the family members (for example a family with a boy and a girl but only 2 bedrooms).
Households that are concealed (but not overcrowded). A household that wants but does not have a home of their own (for example a young family living with grandparents).
Single person households in need (even if both overcrowded and concealed) (e.g. adults living in HMOs or with friends / parents / other relatives). For example, an adult son or daughter forced by circumstance to be still living with a parent. If they wanted to form a home with a partner they would be ‘counted’, as a single person they are not.
Those living in homes that are physically unfit. For example, a family living in a home with very poor condition roof / walls / ceiling.
Households in homes that are not affordable to them. For example, a family that is struggling financially and spending more than 50% of their income on housing costs.
Households in unsuitable homes. For example, a family with children living in a home with no private outdoor space. This can also include older people that are seeking to downsize but are unable to due to a lack of available options.

The evidence used for predicting future demand is also limited – it draws too exclusively from household projections which assume past trends will continue. The current projections are based on the years when delivery was at its very lowest, post-recession.
The household projections are trend based. They project forward what has happened in the past. Academic studies have concluded that planning housing based on them “simply reinforces existing trends” and “excessive reliance on household projections as a basis for housing targets is seriously flawed”. Uncritical reliance on household projections can, therefore, lead to unsatisfactory housing outcomes being projected forward as Professor Glen Bramley has observed “If household growth has been artificially suppressed by the undersupply of new housing, then basing future need calculations on those lower growth figures will by necessity under-estimate that need” (Professor Glen Bramley, November 2018, Housing supply requirements across Great Britain: for low-income households and homeless people; Crisis and National Housing Federation).
The latest household projections are largely informed by trends from the last 10 – 15 years. This has been an exceptionally challenging period for household formation: real wages have seen the most sustained squeeze for 200 years while rents and house prices have increased significantly ahead of inflation. Home ownership has fallen, with steep declines among younger generations (source: https://ifs.org.uk/uploads/publications/bns/BN224.pdf), the proportion of adults living with their parents has grown and affordable housing waiting lists have increased. These are clearly not outcomes which are desirable or consistent with government policy yet, by placing such heavy reliance on household projections, the MATHLR figures implicitly plan for their continuation.
The Scottish Government identified initial figures for each area using the process described in the method paper on initial estimates (available here: npf4-housing-land-figures-method-paper-pdf-123mb-v2.pdf). It circulated those figures to LAs in February 2021. LAs had until June 2021 to consider the initial figures and suggest any adjustments. As a result of the shortcomings in the base data sets, the initial Scottish Government numbers were instantly recognised by many authorities as being too low, but there was not a lot of time for them to do much about it. Only those who happened to be doing local research at the time, or who were already considering how to increase delivery in their area, were able to scrutinise and amend the figures with confidence.
The approach taken by the different authorities was very varied, both in the extent to which they sought to sense-check and challenge or corroborate the figures and the sources of evidence they used.
HFS would also ideally like to see usage of the recent census data within LA HNDA calculations moving forward.

4.0 Specific Comments and Suggestions on Draft NPF4 Annex B
HFS can support:
· The use of minimum requirements rather than absolutes. Paragraph 15 of the Housing Land Requirement explanatory report helpfully explains the Scottish Government concern that these numbers are described as a requirement to better convey the intention that they are to be met within LDPs. Reference to targets could be inferred as aspirational amounts that authorities try to achieve.
· The MATHLRs that have been informed by local primary research (notably Argyll & Bute and the Tay Cities Regions).
· Attempts so far by some other authorities to sense-check and inform their numbers (Authorities that have applied themselves most fully include East Ayrshire, Highland and Edinburgh).
HFS cannot support:
· The lack of clear direction to LAs on planning for more homes.
· An inconsistently derived evidence base rooted in limited data sets and not aligned to policy ambition.
· The draft MATHLR figures, which only meet 81% of the industry’s call for 25,000 all tenure new homes per annum.
· The failure to date to ensure all authorities robustly sense-check their numbers.
· Lack of transparency for members of the public on the basis for these numbers.
· Lack of clarity in NPF4 itself on how much work each authority has done.
· The absence of a clear steer on how many new homes Scotland needs.
· The fact the NPF4 numbers still add up to significantly fewer homes than Scotland is already building. 22,596 homes were built in 2019 (the last pre-pandemic year for which we have completion statistics). The NPF4 numbers equate to just 20,014.

Suggested Changes:
· Final NPF4 to highlight how much work each authority has done on their MATHLR.
· Adjust MATHLR to reflect 10-year completion levels as a minimum, wherever this is higher than in draft NPF4, if some LAs have not undertaken an adequate amount of sense-checking work by the end of this consultation period. All LAs should be working to the same parameters. Failing to do so forms an imbalanced approach to the formation of the MATHLRs.

The HFS’ ‘alternative Annex B’, included in this response, suggests alternative figures for authorities whose draft NPF4 10-year MATHLR number is lower than their previous completions record. We have added the appropriate level of flexibility to the 10-year completion figure provided by the Scottish Government in its February 2021 consultation.
Our strong preference is for all of the figures to be sense-checked and informed by local, regional and national evidence and policy drivers, set from a consistently delivered framework and methodology. Our alternative figures are intended to be used in instances where LAs have not completed sufficient work. Planning for decline cannot be a position that the Scottish Government supports. Therefore, it is vital that these alternative minimum figures be introduced at NPF4 stage to avoid a situation further down the line wherein a LA may plan for fewer homes than previously delivered, which would represent a situation directly at odds with the entire purpose of planning reform.

5.0 Wider Changes Required to the NPF4 MATHLR Approach

· Collaborative review of HNDA guidance.
· Close monitoring and biennial review of the impact of MATHLRs on local planning.
· Key Performance Indicators that encourage greater efforts to unlock delivery.
· Review MATHLRs more frequently than 10-yearly, to overcome risks of long-term forecasting and reduce disconnect between NPF4s and LDPs prepared towards the end of the 10-year NPF4 plan period.

6.0 Observations on Local and Regional Responses to 2021 Consultation on Numbers
There is significant inconsistency in the extent to which LAs have engaged in setting these numbers, and in the ways in which the engaged authorities have approached this work. This is in itself concerning. The MATHLR figures for some authorities have been increased since the February 2021 consultation. However, the level of response from LAs varies substantially and some will have had more time and resources available to respond. Some authorities, such as Perth and Kinross and the other Tay Cities, have responded with proposed MATHLR figures informed by primary evidence from telephone surveys whereas others have simply agreed to the default figures with little interrogation. There is significant variation in how robust the figures are for authorities across Scotland. If the figures are to be robust, a higher standard of evidence, including household surveys, should be required across all LAs.

City Regions
The Tay Cities Region authorities worked with Arneil Johnston consultants in reviewing their initial figure and promoted adjustments that grew their collective regional number by 156%. These adjustments are supported by up-to-date, robust, primary research. Other than for Fife, this work has resulted in MATHLRs that in combination exceed the number of homes completed across these authorities in the 10-year period 2009-2019 (though the figure for Fife (North) remains below its previous completion levels).

Local Authority / City Region 10- Year MATHLR Initial Default Estimate 10- Year MATHLR draft NPF4 Adjusted Percentage Change
Angus 850 2,550 200%
Fife (North) 1,050 1,500 43%
Dundee City 2,000 4,200 110%
Perth and Kinross 2,650 8,500 221%
Dundee City Region 6,550 16,750 156%

Aberdeen City and Aberdeenshire liaised with each other and used a common methodology to review and adjust their initial figures. Aberdeen City has increased its figure by 47% and Aberdeenshire by 16%. However, the adjusted figures for both authorities remain below the number of homes completed in these authorities in the 10-year period 2009-2019.

Local Authority / City Region 10- Year MATHLR Initial Default Estimate 10- Year MATHLR draft NPF4 Adjusted Percentage Change
Aberdeen City 4,750 7,000 47%
Aberdeenshire 6,500 7,550 16%
Aberdeen City Region 11,250 14,550 29%

The Edinburgh City Region authorities appear to have worked independently of one another, with only the City of Edinburgh and the Scottish Borders making significant changes to their initial figures (50% and 174% respectively). Other than Fife, all of the draft NPF4 MATHLRs for this region exceed the number of homes completed in these authorities in the 10-year period 2009-2019. Nonetheless, the failure of East Lothian, Midlothian and West Lothian to undertake sense-checking these figures is of great concern given the important role these authorities play in the regional housing market.

Local Authority / City Region 10- Year MATHLR Initial Default Estimate 10- Year MATHLR draft NPF4 Adjusted Percentage Change
City of Edinburgh 27,550 41,300 50%
East Lothian 6,050 6,400 6%
Fife (Central and South) 4,200 5,650 35%
Midlothian 8,050 8,050 0%
West Lothian 8,850 9,600 8%
Scottish Borders 1,750 4,800 174%
Edinburgh City Region 56,450 75,800 34%

The Glasgow City Region authorities have done some redistribution between themselves but there is no significant change to their collective figure. Their overall increase is just 4% and two of the constituent authorities have actually promoted significantly lower figures for themselves (East Dunbartonshire –22% and East Renfrewshire -31%). All Clydeplan authorities, bar Glasgow, are promoting figures that are below their 10-year average completion rate. This is the region that is giving HFS most concern, for the reasons described in detail below.

Local Authority / City Region 10- Year MATHLR Initial Default Estimate 10- Year MATHLR draft NPF4 Adjusted Percentage Change
East Dunbartonshire 3,200 2,500 -22%
East Renfrewshire 4,050 2,800 -31%
Glasgow 21,450 21,350 0%
Inverclyde 250 1,500 500%
North Lanarkshire 6,300 7,350 17%
Renfrewshire 4,900 4,900 0%
South Lanarkshire 7,800 7,850 1%
West Dunbartonshire 450 2,100 367%
Glasgow City Region 48,400 50,350 4%
Other Authorities
Outside the city regions, the level of and approach to engagement in shaping these housing numbers has been equally mixed.
It is clear from the East Ayrshire response to the 2021 consultation that the authority has used a wide range of evidence and policy arguments to ensure their figure is as fully informed as possible and aligned to policy imperatives (such as the Ayrshire Growth Deal). In consequence, their numbers have evolved to a much greater extent than those of the other Ayrshire authorities (though both North and South Ayrshire have done some work to review and evolve their numbers too).
Of the authorities in the Falkirk-Stirling-Clackmannanshire area, only Clackmannanshire has made real efforts to evolve their initial number. Falkirk has promoted no adjustment to its figure and Stirling actually promoted a reduction to their initial number (though this was not supported by the Scottish Government). Though all authorities have a draft number that is higher than their past 10-years’ completions, the lack of robust engagement by both Stirling and Falkirk is a concern.

The Highland Council has made significant attempts to engage with and influence the number-setting for their area, drawing on a wide range of evidence sources and policy arguments. They have not, though, arrived at a number that sustains or exceeds their previous completion levels. This really highlights the constraints of the methodology the Scottish Government has asked local authorities to work within. Highland is an authority that is determined to ensure its communities benefit from increased investment in housing delivery, yet the methodology being used has prevented them from gaining Scottish Government support for the full MATHLR they proposed (The Highland Council’s response to the 2021 consultation shows they wanted a MATHLR of 10,000. This would have been largely in line with their previous 10-year completion rate of 10,300). One specific barrier that held their figure back was an unwillingness of the Scottish Government to let an allowance be made for their high proportion of ‘ineffective stock’ (homes that are not actually available as to meet housing need and demand as they are being used as second homes, vacant properties and housing used for short-term letting (holiday accommodation).
There is clear scope for the MATHLR figure for the Highland Council to be further increased, to exceed previous completion levels. An increase to 1,500 homes for annum would be in line with the current 2015 LDP.
Argyll and Bute Council also put significant effort into ensuring their housing number is as supportive as possible of policy drivers. To support their LDP HNDA, and inform their NPF4 housing number, they invested in primary research into existing housing need in their local area.


Local Authority / City Region 10- Year MATHLR Initial Default Estimate 10- Year MATHLR draft NPF4 Adjusted Percentage Change
Argyll and Bute 200 2,150 975%
Clackmannanshire 450 1,500 233%
Dumfries and Galloway 400 4,550 1038%
East Ayrshire 350 4,050 1057%
Eilean Siar 100 192 92%
Falkirk 5,250 5,250 0%
Highland 4,350 9,500 118%
Moray 1,800 3,450 92%
North Ayrshire 450 2,950 556%
Orkney 450 1,600 256%
Shetland 300 850 183%
South Ayrshire 500 2,000 300%
Stirling 3,500 3,500 0%
Cairngorms National Park 850 850 0%
Loch Lomond and the Trossachs National Park 250 300 20%

Clydeplan Concerns
The outlook in the former Clydeplan is the most worrying of all the regional groupings, having not sought to meaningfully sense-check the initial numbers during the February-June 2021 consultation window. This is despite having had their HNDA underway at the time and being presented by HFS with recent, robust and relevant primary research on existing housing need amongst households in the region.
The Existing Housing Need in the Clydeplan area - Survey Results Report, commissioned by HFS, and prepared by The Diffley Partnership and Rettie & Co in May 2021, highlighted the actual levels of need and demand in this area:
Initial Default Estimate of Need and Demand 1,916
Survey – overcrowded and concealed – 12,710
Survey – other forms of need – 183,000
This report developed and tested a new approach of conducting primary research to inform the HNDA process, using the Clydeplan area as a test geography. This approach used primary research to examine existing housing need in the area. This test survey demonstrated there is an easy and robust approach available to LAs and the Scottish Government, or to anyone seeking to gather data on existing housing need, beyond the secondary data already incorporated in the HNDA tool. The test survey has also produced estimates of wider household need that can be used as input data to inform HNDAs and policy decisions on planning for housing. Based on a wide definition of existing household need, the survey found, overall, 21.6% of the sample had some form of housing need, equating to around 183,000 households in the Clydeplan area. To avoid double accounting, this figure screens out 29,000 households with two or more forms of need. This includes 12,710 overcrowded households that have at least one concealed household (the only form of existing need currently counted in Scottish Government existing need estimates, other than homeless households in temporary accommodation).
Other authorities that informed their response with data from similar primary research went on to revise their initial number upwards by between 43% and 975%. In contrast, the Clydeplan authorities have collectively only moved by 4%. Two of the authorities in the Glasgow City Region, East Dunbartonshire and East Renfrewshire, have encouraged a reduction of their initial number. This is remarkable in the face of the robustly evidenced housing need indicated in the HFS survey.
7.0 Conclusions
In some of the most prosperous areas of Scotland previous plans which have set low targets have contributed to exclusive rather than inclusive growth. For instance, Edinburgh has not planned to meet its housing need and demand in full for decades. The result of this has been an increasingly pronounced imbalance of supply and demand, particularly for family homes. As available housing has become artificially scarce, prices have increased, rewarding homeowners with increasing values while eroding the disposable income and potential saving of renters. There is evidence of a continuation of this approach in the draft NPF4. It is notable that the only two authorities for which the MATHLR figures have significantly reduced from the draft February 2021 consultation figures (East Renfrewshire and East Dunbartonshire) are the two least affordable LAs in the country, with median house prices over 8 times median full-time earnings. Affordability needs to be addressed rather than identifying areas of high house price inflation for additional planning restrictions and lower targets. This would appear also to be a breach of the Community Wealth Building aspirations of NPF4.
It is simply not possible to reconcile the Scottish Government’s draft NPF4 MATHLRs, and the approach it is taking to setting them, with the Housing to 2040 target of delivering 110,000 affordable homes over the 10-year period to 2031/32.
The figures that are currently on the table could see land allocated for as few as 20,014 homes across Scotland each year. Subtracting 11,000 affordable homes leaves only 9,014 homes a year for private tenures. The Scottish Government cannot expect so few market homes to be able to support 11,000 affordable homes.
In 2019, 5,909 affordable homes were built in Scotland. That was 26% of the homes built that year. That is higher than previous trends that show, over the last 5, 10 and even 20-year period, approximately 20% of the new homes built in Scotland have been affordable housing.
If the Scottish Government adopts MATHLRs that allow land to be adopted with capacity for as little as 20,014 homes of all tenures, it can only expect to yield, at most, 5,204 affordable homes from that land. And that is dependent on:
• all the allocated sites delivering homes to their full capacity within ten years; and
• funding, policy and wider circumstances allowing the 26% affordable housing yield of 2019 to continue.
If policy and wider circumstances were to remain equal, then achieving 11,000 affordable homes would require a corresponding all-tenure housing target of 42,308. (I.e. 11,000/0.26=42,308.)
Providing enough homes for people is critical to achieving the overarching aims of government policy. The methodology for the MATHLR risks creating housing scarcity rather than choice.

HFS Alternative Annex B
This table is based on Scottish Government methodology. It utilises 10-year completions figures and flexibility allowances introduced and disseminated by Scottish Government.
The Alternative MATHLR: This is the higher of the draft NPF4 MATHLR or past completions. Our measure of past completions is the 10-year figure provided by Scottish Government to LAs in its February 2021 consultation. Where the past completions figure is used, it has been increased using the flexibility level the Scottish Government identified as appropriate for the area. No adjustments have been made for island authorities or national parks, though some of these areas have MATHLRs that fall short of previous completion levels.
Local Authority / City Region / National Park Authority Draft NPF4 MATHLR 10 Year Average Completions Alternative MATHLR
Aberdeen City 7,000 773 9,663
Aberdeenshire 7,550 1,213 15,769
Aberdeen City Region 14,550 2,118 25,432
Angus 2,550 246 2,550
Fife (North) 1,500 240 3,000
Dundee City 4,200 238 4,200
Perth and Kinross 8,500 556 8,500
Dundee City Region 16,750 1,280 18,250
City of Edinburgh 41,300 1,665 41,300
East Lothian 6,400 512 6,400
Fife (Central and South) 5,650 961 12,013
Midlothian 8,050 627 8,050
West Lothian 9,600 657 9,600
Scottish Borders 4,800 351 4,800
Edinburgh City Region 75,800 4,773 82,163
East Dunbartonshire 2,500 368 4,600
East Renfrewshire 2,800 300 3,750
Glasgow City 21,350 1,534 21,350
Inverclyde 1,500 240 3,000
North Lanarkshire 7,350 757 9,463
Renfrewshire 4,900 585 7,313
South Lanarkshire 7,850 1,134 14,175
West Dunbartonshire 2,100 260 3,250
Glasgow City Region 50,350 5,178 66,901
Argyll and Bute 2,150 203 2,150
Clackmannanshire 1,500 115 1,500
Dumfries and Galloway 4,550 297 4,550
East Ayrshire 4,050 367 4,050
Eilean Siar 192 127 192
Falkirk 5,250 458 5,250
Highland 9,500 1,030 13,390
Moray 3,450 451 5,863
North Ayrshire 2,950 312 3,900
Orkney 1,600 145 1,600
Shetland 850 99 850
South Ayrshire 2,000 240 3,120
Stirling 3,500 288 3,500
Cairngorms National Park 850 - 850
Loch Lomond and the Trossachs National Park 300 - 300
All Scotland 200,142 17,349 243,811

Note: For Highland, as previously stated, there is potential scope for this figure to be even higher, at 15,000, which would represent a continuation of the requirement outlined in the adopted LDP.

Proposed additions:
Community Wealth Building – needs a clear definition.
Significant – overused word in NPF4 – needs to be defined in each case.
Deliverable land – we can provide a proposed definition of this from policy 9.
Small Sites – it’s not clear what constitutes a small site in policy 9.
Rural Places – what is the definition of a rural place?
Vacant and derelict land – what does this mean – can’t include ‘still in use’ brownfield sites e.g. live employment site.

No comment from HFS.

No comment from HFS.

No comment from HFS.

No comment from HFS.

No comment from HFS.

No comment from HFS.

No comment from HFS.

No comment from HFS.

No comment from HFS.

It is disappointing that there is not currently a specific Human Rights Impact Assessment. Housing is a human right. It is defined as such under Articles 17 and 25 of the Universal Declaration of Human Rights. It is even referenced as such in Part 4A of Housing to 2040. However, there is no reference to this within the NPF4, nor any of the supporting documents. With the supply of new homes being increasingly restricted as a result of local and national policies (and the associated rising concerns of affordability, homelessness and access to adequate housing), it is fundamentally vital that Articles 17 and 25 of the Universal Declaration of Human Rights be afforded weight in the preparation of NPF4. There remains a significant amount of work to do to ensure that everyone in Scotland has access to a safe, secure and affordable home.

No comment from HFS.

With specific reference to the Partial BRIA, HFS takes the view that NPF4 sets a higher bar than what existed previously regarding the allocation of sites for residential development. The draft NPF4 outlines that a site should now be “deliverable”. However, there is no guidance as to where the cost burden to prove this deliverability lies. We believe that LAs are inadequately resourced to deal with this increased workload.
HFS disagrees with paragraph 60 of the Partial BRIA. As set out in our response to the Draft NPF4 consultation, NPF4 as currently written will not be able to provide the certainty required for developers when developing their planning proposals. There remain numerous ambiguities in the Draft which will be counter intuitive in achieving any cost savings for businesses or resource efficient outcomes for LAs.
Another issue pertains to paragraph 62 of the Partial BRIA, which does acknowledge that there are several new requirements that are likely to have cost implications for businesses. However, there remains a lack of clarity in what the details of these requirements will be. For example, under Policy 9 there is a requirement for developers to provide a Statement of Community Benefit alongside certain proposals, however, it is unclear how this may be aligned with existing assessment requirements in practice.
We also have issue with “Appendix B: Infrastructure First”, as there is a fundamental lack of evidence regarding how the policies will be delivered. The timing is unhelpful here, and views from businesses should have been sought more robustly prior to the current consultation stage.
Lastly, in relation “Appendix B: Quality Homes”, there is no indication of how the noted concerns have formed the currently drafted policy. We believe SG should seek further views on businesses on this matter prior to adoption of NPF4.