Home building body Homes for Scotland (HFS) has said that a key Scottish Government document outlining the approach to planning and development to 2045 risks making the country’s housing deficit even worse

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.
  • 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 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.
  • 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 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.

“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.”