Housing Land Audit: guidance

Introduction and context

1. This guidance sets out the approach to the preparation and publication of Housing Land Audits (HLAs) for all planning authorities in Scotland. HLAs provide information on past completions and future programming of new homes in an area.

2. The purpose of the guidance is to support a consistent approach to the method and presentation of HLAs. This is important to be able to provide a comparable baseline of information across Scotland’s authorities and to aggregate the information to provide a national picture of the housing pipeline and its progress through the planning system. The guidance recognises that authorities face different circumstances locally and therefore also provides for flexibility.

3. This guidance replaces the Housing Land Audit section of Planning Advice Note 2/2010, reflecting the new legislative and policy context within the Town and Country Planning (Scotland) Act 1997 (the Act), as amended, and National Planning Framework 4.

4. The next HLAs to be prepared and published by planning authorities should be new style HLAs, applying this guidance and methodology.

Research

5. The Scottish Government published research on HLAs in January 2019 – Research Project: Housing Land Audits. The project assessed HLAs for consistency and compliance with guidance, the potential for standardisation and the role of HLAs in development plan delivery. The research found the HLAs analysed from across Scotland were ‘not consistently defined, researched, analysed, consulted on, tested, reported or integrated with development planning or delivery’. It indicated that the inconsistency creates uncertainty in the planning and development system and the possibility of different planning outcomes. It noted that ‘consistent, reliable housing land and development information is required by the planning system’ and that this may assist in reducing delays.

6. The Scottish Government also commissioned research on deliverability of housing sites which was published in February 2020 – The Deliverability of Site Allocations in Local Development Plans. The project considered the type of information that demonstrates a site’s deliverability.

National Planning Framework 4

7. National Planning Framework 4 (NPF4) is the national spatial strategy for Scotland, adopted in February 2023. It sets out spatial principles, regional priorities, national developments and national planning policy. NPF4 is part of the development plan, along with the Local Development Plan (LDP) for an area, that guides decision making on plans and applications for planning permission.

8. NPF4 introduced a new plan-led approach to planning for new homes. Policy on Quality Homes (policy 16) encourages, promotes and facilitates the delivery of more high quality, affordable and sustainable homes, in the right locations, providing choice across tenures that meet the diverse housing needs of people and communities across Scotland.

9. Policy 16 states that ‘the annual Housing Land Audit will monitor the delivery of housing land to inform the pipeline and the actions to be taken in the delivery programme’.

10. The pipeline is the sequencing of housing land which is allocated in the local development plan to meet the Local Housing Land Requirement (LHLR). The purpose of the pipeline is to provide a transparent view of the phasing of housing allocations so that interventions that enable delivery, including infrastructure, can be planned. It is not to stage permissions.

11. The pipeline is established in the Delivery Programme. Sequencing is expected across the short (1-3 years), medium (4-6 years) and long-term (7-10 years). Where sites earlier in the pipeline are not delivering as programmed, there is flexibility to bring forward sites that had initially been identified for later stages. Policy also indicates de-allocations should be considered where sites are no longer deliverable.

12. The LHLR is the amount of land required for new housing and is set out in the local development plan. It is expected to exceed the 10 year Minimum All Tenure Housing Land Requirement (MATHLR) in NPF4. LDPs should allocate deliverable land to meet the 10 year LHLR, and identify areas which may be suitable for new homes beyond 10 years.

13. HLAs can also inform decisions on whether sites additional to those allocated can be released for new homes. Policy 16 f) states that proposals for new homes on land not allocated for housing in the LDP will only be supported in limited circumstances: these include where delivery of sites is happening earlier than identified in the deliverable housing land pipeline. This will be determined by reference to two consecutive years of the HLA evidencing substantial delivery earlier than pipeline timescales and that general trend being sustained.

Local Development Planning Guidance

14. Local Development Planning Guidance (2023) brings together legislative requirements and advice in relation to NPF4 for the preparation of LDPs. HLAs are important data sources at different stages of the plan making process, for the Evidence Report, the Delivery Programme and for monitoring.

15. The Evidence Report informs what the LDP is to plan for. HLA data is a relevant source of information as it will provide the context of housing land supply, both on past delivery and future intentions. Comparison with previous HLAs will provide an indication of change over time.

16. As part of the preparation of the LDP, the planning authority should confirm that each allocated site is deliverable. To support the allocation of deliverable land, it is anticipated that the planning authority will establish a site appraisal methodology at Evidence Report stage of plan preparation and the LDP Guidance states that “all sites for new homes should be assessed using the site appraisal methodology which was considered at the Evidence Report and Gate Check. No sites should automatically roll forward from one plan to the next.”

17. The Delivery Programme sets out how an authority proposes to implement its LDP. It is part of the project management toolkit helping to focus on achieving the plan’s intended outcomes. Rather than noting progress on actions, it should set out a clear pathway to facilitate the delivery of homes, particularly where action is needed to overcome identified constraints.

18. The Delivery Programme must include the expected sequencing of, and timescales for, delivery of housing on sites allocated by the LDP. The LDP Guidance provides further detail on timeframes to support sequencing of deliverable housing land pipelines.

• Short-term sites: where the first homes are to be completed in years 1 to 3 of the plan, including sites with full planning permission.
• Medium-term sites: where the first homes are to be completed in years 4 to 6 of the plan, including sites with planning permission in principle and allocations supported by masterplans, development briefs or equivalent. And,
• Long-term sites: where the first homes are to be completed in years 7 to 10 of the plan, in locations that align with the spatial strategy of the plan and have a pathway to delivery identified in the Delivery Programme.

19. The Delivery Programme must be updated at least every two years and will be informed by the annual HLA. The LDP Guidance states that “the Delivery Programme and HLA together play important and complementary roles in supporting and driving the delivery of the LDP”.