HOUSING SUPPLY TASK FORCE - OCTOBER 23, 2007
Homes for scotland
CASE STUDY OF LAND SUPPLY PROBLEMS - LOTHIANS AREA
1 Development Plan Framework
Homes for Scotland objected to the Edinburgh and Lothians Structure Plan 2003 on the basis that it did not fully reflect housing needs and demands, and consequently allocated insufficient land for future development. A further objection related to the types and qualities of land identified, with an inadequate supply in Edinburgh city coupled with an over-reliance on brownfield and windfall sites. Homes for Scotland responded to Ministers' call for a position statement on housing in the Lothians in July 2007 in similar terms. Key points in both submissions included:
- Basis of housing need assessment inadequate
- No account of affordable housing backlog
- No account of demand/market forces
- Assumptions on land supply over-optimistic
- 30 per cent of base land supply has not come forward as anticipated
- over-reliance on brownfield/windfall, which can only be developed for high-density flats
- 400 greenfield allocation in Edinburgh wholly inadequate for needs
- Only West Lothian allowed scope to allocate above need - for infrastructure reasons not demand
- Policy allows for failure
- Policy HOU10 allows less land supply than national guidance - 90% of the 5-year land requirement
- Evidence of market failures
- House price inflation
- No land in Edinburgh for family housing
- Families moving to Fife/Falkirk/Borders
- Travel to Work Area now 30 miles diameter - unsustainable transport implications
- Over-supply of flats on windfall/brownfield sites
2 Plan process
- Planning is an excessively long process
- ELSP begun 2000; approved 2003
- Conforming Local Plans will not all be adopted until 2009
- City-region plan not in place until 2011?
- Conforming development plans 2014/15?
- Current land supply pipeline will have to suffice for 7/8 years
- Are current market failures susceptible to remedy in that period?
3 Site development process
- Site allocation in Local Plan is no guarantee of construction
- Planning application determination for major sites 12 - 24 months
- Consent triggers a series of other processes/consents - sequential not parallel - a further 12 - 24 months
- Within that 24 - 48 months developer must continually adapt his proposals to market changes
- Lengthy exposure to risk
- Time = cost
4 Practical Issues for developers/landowners
- Land price inflation - driven by supply
- Rising burden of developer contributions e.g. West Lothian; Edinburgh revised tram contributions; Scottish Water Parts 1 - 3 infrastructure
- Principles of Circular12/1996 on planning agreements/developer contributions are accepted; replacing public investment with private is not accepted
- Affordable housing delivery is caught up in the same delays/constraints
- Drive to reduce land values for affordable housing by Communities Scotland will further delay affordable housing delivery
5 What can Government do?
- Set a national policy context for housing growth in all tenures
- Homes for Scotland's proposed target of 50000 houses p.a. - double present levels
- Drive changes to planning system
- Faster plan preparation
- More land allocated
- Faster application determination
- Press Local Government to adopt national policy aspirations
- Requires a culture change - promote development
- Use demise of Planning Gain Supplement to produce Scottish approach to major infrastructure provision - water/drainage and education are key
- Investment in affordable housing