A PERSPECTIVE ON THE PLANNING (SCOTLAND) BILL - DELIVERY AND OUTCOME FOCUSSED?
By Stefano Smith FRTPI, Director – Stefano Smith Planning Solutions
Context and Challenges
There is a continuing and urgent housing crisis in the UK – something we only need eyes to know with so many homeless people on the streets and with so many young people struggling to access housing beyond the parental home.
This is not a new problem. The cumulative shortfall in new home building, particularly in the affordable sector, has been the case for many years. Indeed if you look at housing delivery over the last forty years you will see a clear, downward trend, spanning the inevitable cycle of boom and bust.
The number of new homes in the UK with the benefit of planning permission now stands at over 400,000 but people can’t live in planning permissions – the homes need to be built. Planning shouldn’t be and isn’t about putting obstacles in the way of building – it’s about identifying the constraints and finding ways of working around them to enable building to take place. Part of this is about ensuring that the delivery of housing is planned and coordinated with access to schools, transport networks and the services and infrastructure which go to make a good quality of life. Doing so, also ensures that the homes we build are readily useable. For example, new homes without adequate and timely access to school places are unlikely to be attractive to buyers and tenants.
We also need to ensure that new homes have access to jobs – that we plan for new and refurbished business space in accessible and sustainable locations. We need to ensure that we are able to maintain adequate space for future businesses, just as we need to be able to coordinate housing delivery with services and infrastructure.
Delivery depends on the adequate resourcing of our local planning authorities. This is in part about ensuring they have the right staffing levels to be able to be to deliver the development plans that are the cornerstone of our planning system and to process the planning applications and discharge of conditions required for building to get underway in a timely manner. Sadly, at this crucial time, we have allowed our local authority planning teams to decline, both in terms of their strategic role and in terms of resourcing.
The combination of under-resourcing and the necessary focus on housing and economic growth, has limited the ability of many local planning authorities to deliver across a wider range of social objectives and in particular to consider the environment and climate change, and social and cultural needs.
The Premise of Planning Reform
The whole premise of the current planning reform in Scotland was housing and infrastructure delivery. It was to take forward,
‘…reforms that will strengthen the planning system's contribution to inclusive growth, housing and infrastructure delivery and empowering communities. Our [Scottish Government’s] proposals will maintain our [Scottish Government’s] commitment to a strong, high-performing system that enables housing and infrastructure delivery and supports quality of life of all our communities by promoting quality of place.’
We are now at the final stage of the Planning (Scotland) Bill process – Stage 3 (Parliamentary Consideration) – and the potential enactment of the Bill is expected mid-2019. See Figure 1.
Figure 1 Planning (Scotland) Bill Timeline
The efficiency and reputation of the planning system has an important role to play in making Scotland an attractive place to invest. I consider whether we are any closer in fulfilling this original premise. Will the proposed changes to Scotland’s planning system enable it to realise its full potential? I particularly focus on whether the proposed reformed planning system will actually facilitate housing and infrastructure delivery.
Closing the gap between planning consent and delivery of homes
Planning authorities should be supported to take more steps to actively help deliver development.
Housing delivery is a continuing priority. Scottish Government must ensure that planning actively helps to enable development and the commitment to deliver 50,000 affordable homes over the course of this Scottish parliament. To assist in achieving this I recommend that:
- Consideration be given to how better information on viability can be used to strengthen delivery;
- Whilst changes to Compulsory Purchase Orders, Compulsory Sale Orders and a development land tax could all influence the context for planning for housing, Scottish Government should prepare revised guidance for acquiring authorities on the use of their existing CPO powers, and a series of case studies of how CPO can be used, in the short term. Scottish Government should also be considering the work of the Scottish Land Commission on these matters;
- Scottish Government to continue to work with others, including through the More Homes Scotland approach, to ensure that planning does all it can to enable the building of more high quality homes of a broader range of types, and in a way which strengthens places and quality of life;
- Scottish Government should work with their More Homes colleagues to explore the potential to map the 50,000 affordable homes target, the spatial distribution of homes delivered and opportunities to link this to wider investment and delivery information. There should be a focus on 'Activating Sites' and exploring options to unlock land for homes; and
- Continued support is given to the development of pilot projects that demonstrate and promote the value of self and custom build housing as an alternative to the mainstream housing delivery model.
Development Planning - Key themes, ambitions and changes
The development planning aspirations, ambitions and priorities of Scottish Government prior to the start of Stage 2 (line by line scrutiny) of the Planning Bill, followed by the subsequent key changes, are outlined in Figures 2 and 3.
Figure 2 Development Planning Aspirations, Ambitions and Priorities
Figure 3 Key Development Planning Changes from Stage 2
I am concerned that resource implications of the Bill as laid before Parliament, along with the number of amendments tabled, have not been rigorously costed and will place new demands upon the planning service.
These concerns have been heightened by the number of further additional duties and responsibilities that have been introduced at Stage 2. RTPI Scotland’s analysis shows that recent amendments made to the Planning Bill will place up to 91 new duties and responsibilities on planners without resources required to undertake them: 66 new and unfunded duties will be put on planning departments with a further 25 responsibilities placed on Scottish Government. See Figure 4.
Figure 4 Duties, Funding & Resources
This additional work comes at a time of severe resourcing pressures for planning departments which have already seen a 23% loss of planning staff since 2010. Adding these new duties to the workload of already stretched planning departments could see the system grind to a halt. Many of these duties can be done through existing legislation.
Next steps for planning and housing
I recommend that the final Bill include elements of the following to facilitate and enable the building and delivery of much needed homes in Scotland:
- Scottish Government to facilitate and enable more directly the delivery of the many thousands of homes stalled on major (allocated) development sites across Scotland. Providing the infrastructure investment required (be it schools, drainage or transportation) to deliver housing on the ground.
- Identify land held within land banks which has little potential under the current developers financial model (sites that due to their location in low value market areas or because they had been historically overvalued could not be developed at a reasonable profit). Whilst there are probably few such sites left, the Scottish Government could fund the transfer of these sites to constructors and builders who are willing to deliver a more affordable product in poorer market areas.
- Consider the land use opportunities that new (or planned) infrastructure could bring. The Waverley Line, the ongoing improvements to the M8 and the new rail routes between Glasgow and Edinburgh, all create obvious new opportunities for development.
- Embrace modular housing to increase rates of housing delivery. Traditional build will continue but Off Site Manufacture (OSM), from factories across Scotland, could significantly increase the speed of production and resolve some of the supply issues affecting the industry.
- Use NPF4 to identify and then deliver new settlements in sustainable locations and with good market demand. Plan the housing and infrastructure at the same time.
- Enshrine all of this in NPF4, giving this forthcoming National Plan the theme of ‘Delivery’. There needs to be a radical move to support the Plan Led system with a delivery mechanism.
Planning is central to the economic, social, and environmental policy objectives of the Government, the devolved nations and our local authorities. I believe that now, more than ever, is the time to use our planning system and our highly qualified planners to fully deliver in the public interest on jobs and infrastructure, to mitigate climate change and much-needed, high quality homes.
Please don’t hesitate to get in touch for more information or advice. Contact details are:
Stefano Smith FRTPI, Director
Stefano Smith Planning Solutions
(e) firstname.lastname@example.org (m) 07464 744337
By Stefano Smith FRTPI, Director – Stefano Smith Planning Solutions
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