Liz Hamilton

In its submission to the consultation on National Planning Framework 4 (NPF4), HFS highlighted that the document, as drafted, “will likely reduce the number of homes delivered, thereby exacerbating the housing crisis”.

It also highlights the lack of recognition given to Scotland’s housing crisis, despite the delivery of new homes being the original purpose of planning reform. HFS is asking for housing delivery to be included in NPF4 as a national development. HFS has also detailing the lack of detail in relation to the delivery strategy and associated financial interventions that will be required to deliver the ambitions of NPF4.

The body has also revealed the framework’s failure to address the ongoing resourcing challenges within Local Authorities whilst adding to planning officers’ workloads with a raft of, at times, contradictory policies with no clear decision-making hierarchy, not to mention the introduction of a number of new technical reports.

HFS has highlighted the proposed new wording to support the identification of a deliverable pipeline of housing sites and to offer workable solutions when the pipeline is found to be under-delivering. The body has also detailed the lack of an evidence base for new policy direction such as requiring vacant and derelict land to be allocated as a priority before greenfield release.

Of particular concern, however, is the figure proposed as the Minimum All Tenure Housing Land Requirement. HFS argues that the tool used for calculating this relies too heavily on past population trends and fails to identify the full range of housing need, with many excluded from the count (eg single adults living with parents or sharing a flat, families living in a home with inadequate bedroom space). This follows a recent report showing that the cumulative housing shortfall since the global financial crisis is now approaching 100,000.

HFS head of planning Liz Hamilton, said: “Whilst we do welcome the focus upon the ‘deliverability’ of sites and broadly agree with the intent and purpose of several of the policies, we are extremely concerned that, as it currently stands, NPF4 will lead to significantly fewer homes being built.

“Indeed, it appears that Scotland’s housing crisis has been forgotten but this is equally as important as the climate emergency and nature crisis. A better balance must be struck to respond to all.

“With regard to the Housing Land Requirement, the purpose of a target was to shift focus away from numbers and on to the delivery, design and function of our future places. In order to do that, however, the numbers must at least reflect completions over the last ten years as an absolute minimum. Unfortunately, draft NPF4 falls short on this and looks like it is planning for decline.”

She continued: “The Scottish Government intends to have NPF4 passed before the parliament’s summer recess but, given the importance of this document and the extent of revision that we believe is required, we are calling for a pause until updated proposals are published in full and properly consulted on and scrutinised by MSPs.

“We all have our own examples, whether it’s ourselves or people we know, of the struggle it is to find a home that meets your needs and that you can afford. That is why we need to deliver more homes, both private for sale and social affordable housing, not less. It is crucial that the public understand what is at stake if our young people, growing families, ageing population and future generations are to have the safety and security of calling somewhere home.”

The Chartered Institute of Housing (CIH) Scotland has welcomed the commitment to identifying sufficient land for new housing but recommending further steps are taken to strengthen the links between the strategic framework and the priorities of planning authorities.

In its response, CIH Scotland supports the approach set out in NPF4 with regards to climate change, future place, homes and neighbourhoods but notes the need for NPF4 to link to existing strategies and policies that help deliver on this vision.

CIH Scotland also recommends that the spatial strategy would benefit from a clear roadmap up to 2045 setting out expected milestones, budgetary considerations, and outcomes.

Calum Chomczuk, national director at CIH Scotland, said: “The pandemic has taught us all the importance of having a safe, affordable place to call home, but with market trends in Scotland pointing to significant housing pressures, we need to improve access to affordable housing in the short to medium-term.

“The suggested plans for how we identify Scotland’s All Tenure Housing Land Requirement as part of NPF4 are welcome. We need to be able to plan for house building over the long term, outwith political election cycles, and a ten year housing land supply will help us institutionalise the reforms we need to deliver a ten year, all tenure housing plan.”
He added: “But we also need to see land identification then matched with the appropriate infrastructure changes. And then we need to help planning authorities realise the connection between these national strategic plans and their own local priorities.

“None of this is easy and it will require significant infrastructure investment from the Scottish Government alongside a recognition that more money will be required to increase planning authority capacity and to build the homes Scotland needs.”

According to Scottish Land & Estates (SLE), the framework falls short in meeting its own ambition.

The organisation has responded to the Scottish Government’s NPF4 consultation, welcoming the ambition of the proposed updated framework, but highlighting where it falls short in supporting rural interests. The organisation believes that while NPF4’s aims to address the climate and nature crises and to support rural communities are overwhelmingly positive, too many of the concrete proposals are at odds with those ambitions.

Sarah Madden, policy adviser on rural communities at SLE, commented: “We fully support the overarching ambition of NPF4, but unfortunately there is a large gap between that ambition and the detail in the framework.

“We of course understand that the planning system needs to take the climate crisis into account, but addressing that must not be to the detriment of rural development.”

SLE has also pointed out parts of the proposed framework which appear to be self-contradictory. Ms Madden continued: “We are supportive of the ambition to sustain and increase rural populations. Yet the framework contains proposals that would do the opposite.

“For example, the proposal to prevent developments where it would increase private car use simply isn’t workable in rural areas where public transport is patchy or non-existent. This could have the unintended effect of locking rural areas out of development at a time when they are in many cases already fragile.

“We are also disappointed to see the omission of high-quality cluster housing developments – an important model of rural housing development that ensures builds are in keeping with local design and character while safeguarding biodiversity.

“Our consultation response sets out in detail our concerns and our recommendations for improvement.”