NPF4 call for ideas: analysis of responses

Housing - General

Proposed key objective of NPF4: To ensure that development plans allocate the right land in the right place at the right time and to facilitate and monitor the delivery of this land

Some of the issues raised in relation to enabling the delivery of new homes were similar to those made about the Housing Technical Discussion Paper (see the relevant section of this report).

Overall aims and objectives of housing policy

There was a call for homes for all to be a central objective for NPF4, and the importance of those homes being affordable was also highlighted. In terms of the focus of policy going forward, suggestions included that it should take account of:

• Quality and design.
• The importance of placemaking, and of creating high quality and well-functioning places and mixed communities, and how new housing can accommodate the range of needs as part of better integrated communities.
• The relationship between housing and economic development, including around enhancing economic performance and place competitiveness. It was suggested that the Scottish Government's housing growth plans present an opportunity to improve the use of housing as an enabler of economic growth.
• Environmental sustainability, including that the number of new homes that can be delivered should not be to the detriment of or prioritised over principles of sustainability.
• Gender and other forms of equality. It was suggested that current services and discussions about planning for housing to 2040 do not take account of women's experiences and needs.

It was also suggested that NPF4 presents an opportunity to assist in shaping an evolving housing system in line with the ambitious vision and principles of 'Housing to 2040', that LPPs, LDPs and RSSs should all have a role to play, and that NPF4 should allow scope for regional and local priorities to be considered.

Targets

Please note that it was not always clear whether comments on targets were referring to housing land supply targets or targets for the number of new homes.

In terms of whether there should continue to be a focus on delivering homes and the quantum of land available, some respondents considered that the Scottish Government should (continue to) set housing targets. There were some references to the national targets for affordable new homes, including how local or regional plans are seeking to support the Scottish Government in meeting those targets. More generally, there was a suggestion that new homes should be classified as essential infrastructure and that there should be a pan-Scotland, all-tenure housing delivery target of 25,000+ homes a year, with minimum delivery targets for each LDP to support the pan-Scotland target. It was also suggested that the 25,000+ new homes target should become a National Development. A number of the other National Development proposals submitted as part of the Call for Ideas also focused on the provision of new homes, including as part of the development of new towns or villages or through mixed use development of brownfield or former industrial sites.

In terms of delivering new homes more generally, it was reported that affordable housing and build-to-rent can generally be delivered more consistently and faster than the parts of the housing market dependent on the mortgage market. However, one local authority respondent reported that if either market or affordable housing targets were to be set at higher levels than existing 2027 targets, they would not be able to deliver unless policy on housing land supply is changed and clarified.

Others considered that current housing policy is too target driven. There was an associated concern that, since the 2019 Act introduces a requirement for the NPF to include housing land supply targets, there is a danger that nationally set targets and efforts to deliver them will not lead to the development of housing on the right land in the right places unless the way in which places work is fully considered in the process of setting targets. Other concerns raised about a target-driven approach included that targets are somewhat meaningless given that the delivery of housing is largely under private sector control and dependent on market conditions.

It was also suggested that nationally determined housing targets (and the 5-year effective housing supply discussed further below) do not work for some areas. For example, it was reported that the approach is not suited to the Outer Hebrides for a number of reasons including; the distinct land ownership/crofting tenure set up; limited volume house building; significant single and self-build on windfall sites; a single main RSL; two dysfunctional HMAs which do not operate like conventional HMAs; and hidden and very localised housing demand. It was suggested that these factors, along with significant build costs, all advocate for a discretionary policy and grant funding/fiscal approach for housing delivery in some areas.

Others considered that, whilst housing numbers and targets are important, or may be unavoidable, it is also important to recognise the barriers to delivery of the required number of homes and also to take account of:

• Regional and local demands and trends.
• Infrastructure issues and requirements.
• The management of greenbelts and the relationship with brownfield land regeneration, including cross-boundary efforts.
• Other policy approaches, such as repopulation.

In terms of housing supply targets to be set out in NPF4, clarity and guidance was sought in relation to:

• Any requirements regarding the composition of these targets (i.e. market, affordable, special needs sectors etc.).
• What rights or opportunities there will be for local authorities to challenge the targets and the weight given to prevailing local circumstances.
• The period of target to be used and whether this is annualised or the complete period.
• The purpose of the housing land requirement and its relevance to the preparation of LDPs.
• The approach to taking into account (or not) housing completions and demolitions.

In terms of when targets are set, and given the time taken to produce HNDAs, there was a call for NPF4 to make clear the relationship of the national targets to the continuing role of HNDAs and LHSs.

Evidence and HNDAs

The importance of taking an evidence-based approach was also highlighted, with some respondents noting the importance of ensuring the needs and aspirations of people and their communities inform that evidence base. In terms of establishing the needs and priorities of the population, there was a call for comprehensive engagement and it was suggested that if the NPF4 Call for Ideas does not garner views from all elements of the population, further targeted work will need to be undertaken to ensure views about housing needs and aspirations are properly reflected. There was also a call for co-production with stakeholders.

In terms of other evidence sources, it was suggested that housing requirements need to be derived from population and economic forecasts at national, regional and local levels. Suggestions as to additional evidence that is required included having a clear understanding of the preferences and requirements of private sector buyers.

With reference to HNDAs as a key evidence source to inform housing targets, a number of comments addressed the applicability of the approach to rural, remote and island communities, including suggesting that the calculations completed through the HNDA are more suited to urban locations within the central belt rather than rural and remote locations. It was reported that research has found conventional HNDAs do not provide the granular detail required for smaller communities. The reference in the Planning Bill Island Communities Impact Assessment to local authority HNDAs not always picking up on specific local issues was highlighted, as was the recommendation that some areas, such as islands, should set targets locally based on their distinct development context and demand profile.

A local authority respondent reported that they would prefer to use an approach that focuses on sustainability and placemaking and which considers the local housing market and the future aspirations of all housing sectors in their area. This approach would be based on robust evidence with a focus on identifying the most appropriate land in the right locations, as well as reflecting local traditions, such as for self-building.

Other suggestions included that local surveys should be used more widely and could inform an LPP type of approach to ensure that planned development meets a community's need while also building support for development and placemaking.

Plan-led approaches and the planning system

It was suggested that the further division of the layers of the planning system (national, regional, local authority, local) will mean that the issue of housing targets and provision of land for housing will require to be transparent and easily understood for all involved.

A concern was raised that rather than being plan-led, in reality we have a development-led system. It was suggested that this is inscribed in everything from the 'call for sites' that are viable and deliverable to the fact that the system relies on developers to bring proposals forward whether or not they have been identified in the development plan.

Others raised concerns that in recent years, it has been hard to see how a masterplan has been guiding the design and development of towns in particular. There was an associated concern that ad-hoc housing has often been built through 'planning by appeal' and that this development sometimes looks suspiciously like part of an unannounced longer-term phased development. There was a suggestion that LPPs might be a good way to develop community empowerment and create better environments.

It was recommended that Scotland implement a real plan-led system where plans designate the most suitable sites for development and there is a presumption against development that departs from the plan. However, it was also suggested that being plan-led does not necessarily mean plan-led at a national level and that many issues are more appropriately left to local authorities though their LDP.

Other suggestions included that:

• An organisation for Scotland similar in structure to the Homes and Communities Agency would have greater potential for achieving more efficiency and financial impact for the delivery of varying housing needs. This would allow planning authorities to work together to reflect functional HMAs that cross local authority boundaries.
• Given their enhanced role, it must be made clear that forthcoming LDPs must, as they are required to do currently in their relationship to Strategic Development Plans, be consistent with NPF4 and its successors.

Housing Land Supply and effective land

A wider concern raised was that the current housing land supply approach does not work as it undermines the LDP and the alignment of growth with planned infrastructure, and removes confidence from politicians and communities that what they are engaging with through the LDP process is what will be delivered.

There was reference to the report of the Independent Review of the Planning System in 2016, which highlighted the impact of the confusion around measurement and definition of 'effective' housing land and recommended that a clearer definition be established. It was suggested that this issue remains a key piece of unfinished business from the independent review and NPF4 is an opportunity to set out a clearer policy context for how housing land and housing delivery are measured and dealt with.

Other comments on effective land supply often reflected those raised in relation to the Housing Technical Discussion Paper. They included that the effectiveness of sites is not the best way to measure the land supply available, with reasons given including that:

• Sites should all be effective and if there is clear evidence that a site physically cannot come forward ever it should be removed from the relevant plan.
• Effective/constrained status can be easily manipulated to push further housing land to be allocated unnecessarily, furthering the issue of land banking.
• Long-term strategic sites can be slower to deliver and this is often used as a reason for the release of additional smaller sites to make up for the 'shortfall' in delivery. However, this can lead to further slowing of progress on large scale sites.

In terms of the role of HLAs, variations included that they should be seen as a corporate tool to direct investment in infrastructure and help budget planning.

In relation to both carrying out and the ongoing monitoring of HLAs, comments included that:

• An approach based around land value sharing (rather than land value capture) might be a good way forward and is more likely to stimulate positive co-operation from landowners and others.
• It should be made clear to the development industry that timescales and build rates supplied to inform the HLA need to be realistic, achievable, and should not be artificially inflated/suppressed.
• More rigorous site assessment processes are required to ensure that all sites included in an LDP are achievable.
• Changes to densities/designs that have previously been desired by house builders may be required. LPAs currently have little evidence on housing preferences in terms of design/layout etc. and are frequently told by developers that their house styles reflect the market demand. The Scottish Government or LPAs may wish to carry out their own research to verify this and spark a discussion with developers as to the design and layout of sites.

Some of the challenges identified in relation to ensuring that the right land is allocated and then developed included that there needs to be clarity around:

• What, if anything, will be a trigger in terms of identifying if housing land policies in the plan are to be considered out of date.
• Why the current 5-year land supply period has been chosen.
• What planning authorities should do in the event that the land supply is considered to be inadequate/out of date.

Challenges or issues which respondents identified as needing to be considered going forward included that:

• One of the principal policies of SPP within paragraph 28 is the presumption in favour of development which contributes towards sustainable development. However, the policy has made no notable difference to how housing applications are considered. There should be an updated presumption policy that is less reliant on debatable concepts such as effective housing land shortfall and which, instead, presumes in favour of any development which will contribute to the delivery of homes, which will not cause adverse impacts.
• Shortfalls in the land supply should not have to be remedied through the planning appeal system. Any planning authority that is unsuccessful in delivering the quantum of new homes apportioned in NPF4 targets through its LDP, should be required to move quickly to make additional land available, both through the granting of planning permission and the new statutory procedures for plan review.
• Lack of effective land supply for housing is maintaining the high value of sites, and the overall high cost of creating housing. While allocation of sites within LDPs is not always an issue, there are also challenges with the profitability of site development. This is determined by several factors, including landowner aspiration of value as well as significant land preparation and servicing costs.
• While planning has an important role there are frequently factors outside the role of planning which limit development of housing. For example, a slow rate of sales due to a 'flat' market can mean that it is not possible for a developer to secure funding to cover the costs of getting development underway.
• It should not be a given that a shortage in the build programme necessitates the release of land. It should also be made clear whether LDPs will have the opportunity to include a local policy on further land release criteria in the event that such a shortfall does require such a release.
• The presumption in favour of sustainable development when a local authority is judged not to be maintaining a 5 year effective housing land supply does not seem in keeping with the proposed NPF4 objective that development plans should allocate the 'right land in the right place at the right time'. This can only be achieved through a co-ordinated process where the main issues relating to housing need, sustainable locations for development and impacts upon infrastructure and existing communities are assessed together in a strategic manner.

It was also suggested that completion rates should not drive the release of additional land. With specific reference to the impact of COVID-19, it was seen as important that NPF4 and Homes for Scotland recognise that the non-delivery of housing land that has been identified within LDPs will not always mean that there is a shortfall in the land supply.

The need for NPF to have a trigger for the further release of land where sufficient land supply is not being maintained was accepted by some respondents, although it was suggested that the current 5 year trigger in SPP is problematic and the opportunity should be taken to review this in NPF4. A range of associated challenges were highlighted including that:

• The current trigger appears arbitrary and, in effect, gives developers the opportunity to downplay their build rate and local authorities a reason to inflate it, neither of which is helpful or achieves the goal of delivering the right development in the right place and providing homes where and when they are needed.
• Local authorities and communities are effectively penalised for failure to meet housing targets due to the market moving at different rates.

One suggestion was the definition of effectiveness needs to be reviewed in relation to the marketability criteria and that the effectiveness of the housing supply delivered in meeting the housing needs of the area should be the ultimate test of effectiveness of the housing land supply part of the LDP. A local authority respondent reported that they have been working with Homes for Scotland and Heads of Planning Scotland to develop a new, clearer approach which addresses most of the problems and impacts identified by the Independent Review by the simple step of measuring the supply of effective housing land and the rate of housing delivery as separate things. They went on to report that Heads of Planning Scotland members have drafted a paper setting out proposals for a new, common approach using the principles of separate measurement. The associated recommendations were that NPF4 should:

• State that the supply and availability of housing land (established and effective) should be measured separately from housing delivery/completion rates.
• State what should happen in situations where the supply of effective housing land will be used up before a specified number of years (e.g. 5 or 10).
• State what should happen in situations where the programme of housing completions over the forthcoming period is insufficient to meet the relevant targets.

Other suggestions regarding how any future approach could be structured included that:

• The trigger should move away from the automatic assumption that more housing land needs to be allocated, and instead there should be more emphasis placed upon developers developing their sites and what is reasonably required from LPAs to enable this.
• The gatecheck process for LDPs should set out what the HNDA says is the need and demand, but then provide evidence for a policy view on the number of new homes the planning authority realistically thinks it can achieve over the LDP period.
• There should be no continuation of unbuilt planning applications, or there should be a presumption against the renewal of planning permissions for housing developments or, in the case of larger sites, a requirement for a phasing agreement whereby planning permission would be revoked if the permitted housing is not delivered. Alternatively, a mechanism could be introduced whereby a developer or landowner would face a financial penalty in cases of non- or under-delivery unless there are proven economic or technical reasons why development has not gone ahead.
• NPF should have provision for local authorities to declare that areas have no capacity to release land or improve infrastructure - there are places that are full.

Other comments addressed land value and included that:

• The uplift in land values accruing from the grant of planning permission (or betterment) should be captured for the public good. It was suggested that by removing the potential for speculative profit and loss on land, the planning system could effectively de-risk development whilst leaving developers free to compete based on the quality of what they build, rather than underlying (and unproductive) land values.
• There should be continued support for policies and research on land value capture to help deliver well-planned sustainable communities in places people want to live and at prices they can afford to pay.

Monitoring of homes delivered or land availability

One perspective was that planning authorities cannot or should not monitor the number of homes delivered, as authorities do not control delivery on the majority of sites.

An alternative view was that, while current measures of housing completions appear to be unreliable and are insufficiently detailed to allow progress to be monitored with any degree of certainty, reliable statistics on housing starts and completions need to be collected. These should be by type, tenure and split by functional housing market (if adopted) as well as by authority. It was reported that this type of information is probably best generated from HLAs but must be reconciled to the issue of completion certificates to allow greater confidence to be placed on quarterly official figures.

It was also suggested that mapped and audit information could be used to secure a stronger emphasis on monitoring and that this could be done by standardising HLA data and methodology using a distributed database system using geolocation techniques.

Other suggestions included that LDPs should include a policy setting out the action which will be taken if availability falls short of stated targets and that it would be useful to have this general policy response set out in NPF with scope for planning authorities to vary this if necessary, to reflect any particular local circumstances.

Size of homes and density

A number of respondents commented on the number and size profile of new homes being constructed. It was reported that, although LDPs have given indicative capacities for housing sites, based on the characteristics of the site and the surrounding area, it has generally been left to the developer of the site to identify the exact number of houses proposed and also the size of those houses.

With regard to density, it was suggested that private sector housing generally delivers large 'executive' homes at lower densities during a buoyant market, not providing the mix that is necessary for quality, long-term sustainable communities, and increases pressure on issues such as affordability.

It was reported that the opposite market conditions increase site densities where issues such as reduced floorspaces of homes create lesser-quality home environments and reduce adaptability to changing needs.

A local authority respondent reported that their area has tended to see the development of 3 or 4 bedroom houses, while evidence from their HNDA and discussions within communities has indicated that a far broader range of housing is required, including smaller housing and flatted developments.

Challenges identified included that:

• The type of houses delivered by housing providers will also become more important as demographic changes continue.
• There are not the resources, mechanisms and data monitoring in place for planning authorities to set out the needs of specific mixes of homes (e.g. bedroom numbers, house types).

Suggestions relating to density and size or type mix included that:

• NPF4 should reflect the importance of land by applying a minimum density requirement.
• Applying standard densities based on the location of the settlement (semi-rural, rural, urban) may encourage more effective use of land, without leading to over- or under-development in some areas.
• The NPF should encourage higher density housing and a full range and mix of different house types, on larger sites too, in the interests of good place making for the longer term.
• NPF4 could encourage and support the identification of ratios or percentages of different types and sizes of housing to be identified on each site through development plans. This could be in the form of a percentage, with some flexibility (+/- %) to allow for suitable layout and design solutions. It was suggested that such an approach could support a move to more mixed, more inter-generational developments.

It was also suggested that local authorities, through consultation with local people, should be able to stipulate to developers what type of housing is required - for example, stating that a portion of any proposed development should include terraced, semi-detached or housing for older people. Specifically, it was suggested that the HNDA output should be made more granular by indicating the quantum of need for student accommodation, starter homes, homes adapted for disabled occupants, homes suitable for elderly occupants and other categories identified as being required.

It was also suggested that changes in demography, land availability and socio-cultural trends have increased demands for more varied siting and adaptive design. Examples of the types of properties required included:

• For single person occupancy.
• For small home living.
• With onsite annexes for dependants/boomerang children.
• Of zero carbon design.
• Recreational huts or alternative tourism accommodation.
• For seasonal workers.

It was seen as important to ensure there is clear policy direction and a responsive policy framework in place to assess applications for properties such as those listed above while maintaining standards to ensure they are well designed, safe and energy efficient.

Issues around affordable homes and tenure mix are considered in greater detail at the Housing - affordable theme.

Placemaking and sustainability

While sometimes noting support for the proposed key objective of ensuring that development plans allocate the right land in the right place at the right time, the importance of housing development to placemaking and the health and wellbeing of communities was also highlighted.

It was suggested that the focus needs to be on the creation of high-quality places to benefit local communities whilst recognising the need to support the economy and the housebuilding industry. It was suggested that mixed residential development which supports a broad demographic is required, which in turn promotes inclusivity and diverse types of housing.

Other factors identified as needing to be considered included:

• Landscape and infrastructure capacity.
• Environmental considerations.
• Cultural heritage and archaeological designations.
• The relationship between housing and health, with a suggestion that access to housing that is affordable and health promoting should be specifically recognised as a key feature of any place.

It was suggested that whether it be social or private, new housing should be built in places where communities can thrive and where residents have access to services and are well connected, with a view to creating healthy sustainable lifetime communities. Other comments included any new housing should be positioned with a view to:

• Placing sustainable travel - including walking, cycling and public transport - at its heart. This was seen as vital to delivering on the environmental, social and economic targets of Scottish Government. As a minimum NPF4 should, for example, set a benchmark that new housing development should not be supported if it is not accessible or cannot be made accessible by regular public transport services or is easily accessible by active travel modes
• Preventing and protecting from consequences of environmental changes, such as flooding.
• Being smarter, in order to release areas of the housing stock, including by facilitating downsizing. It was suggested that well planned housing for downsizers has a lesser footprint and is more sustainable than building on greenbelt and farmland around commuter belt towns.

In terms of building or sustaining communities, including in relation to the local and wider economy, comments included that:

• Zoning needs to be more keenly related to the proposed uses, especially in relation to location of housing, to better align where people live to their type of work, and in relation to the regional placement of centres of industry and productive work. In making such decisions we should leave a positive legacy for future generations.
• NPF should encourage all developers to demonstrate how their investment will contribute positively to economic development and regeneration objectives, and social, environmental, ecological and climatic effects.
• Paragraph 29 of SPP refers to principles including net economic benefit, yet there is limited evidence of consistent efforts being made in planning decisions to consider the net economic benefit of residential development such as job creation and the easing of pressures on affordability. These factors need to be considered alongside wider planning considerations.
• There needs to be a much more flexible approach that takes account of pending/future economic opportunities and the needs of employers.
• The allocation of land to smaller towns and villages, where appropriate, could provide housing choice for local communities, and help sustain local services.
• In high demand areas, public sector funding may be brought forward to take advantage of lower land values, and to encourage an improved and expanded private rented sector to support labour market mobility, which will be key in a recession. In weaker housing markets, investment should be focused on upgrading existing stock and quality of place improvements, over new supply.

Finally, it was suggested that there is more scope for small-scale housing development including clusters and groups near settlements, replacement housing, and plots on which to build individually designed houses in rural Scotland. It was recommended that this be included in development plans, either as part of a general settlement policy or as a separate sub-set on rural housing policy.

Infrastructure and developer contributions

Some respondents commented on the importance of taking existing infrastructure or new infrastructure requirements into account when planning for new homes. It was noted that people want to live where facilities are available and that, in the case of any new settlement type development, it will succeed where infrastructure of all types is concentrated.

However, challenges were also noted, including the suggestion that, while local authorities start off by trying to plan growth alongside infrastructure development, all too often landowners obtain planning approval but the upfront infrastructure costs can lead to approved development not happening and to a shortage of new build numbers.

The importance of taking a strategic approach was highlighted, and there was an associated suggestion that Scotland could benefit from funding of a similar scale to that provided by the UK Government Housing Infrastructure Fund.

Other infrastructure-related comments focused on developer contributions and included that:

• Developer contributions have continued to increase over the past decade, and it must be acknowledged that developers are not able to fund all infrastructure requirements. Levels of contributions have risen to over £20k per plot and such levels will make schemes unviable, particularly in periods of recession. Central funding for key infrastructure should be addressed with contributions for site-specific matters being provided.
• NPF4 could greatly assist by setting out typical infrastructure costs or section 75 contributions required from development. It was suggested that the reduction in section 75 contributions per property over the past 10 years is leaving far too many new housing estates without the required infrastructure.
• Providing greater clarity and certainty on the level and timing of developer contributions would result in land changing hands for lower prices and leave more surplus available to help pay for infrastructure. Improving guidance on developer contributions to improve clarity and consistency of application across the country could help to address this.
• The Developer Obligations System should be less restrictive and more flexible.

Finally, it was suggested that NPF4 could help overcome some utilities servicing constraints in remote and rural areas by using appropriately designed off-grid housing as a credible option, with appropriate support to upskill and promote broader understanding and adoption of off-grid methodologies.

Quality of design and build

It was seen as important not to focus simply on numbers but also on the quality and design of new homes being built, that they are accessible and are built to lifetime homes standards. Concerns were raised that most new housing in Scotland is poorly designed, lacks character, and is too small and that housing design often adopts an approach that favours a particular style rather than requiring sensitive and harmonious design. Increasingly limited outdoor space was also highlighted.

It was suggested that, while all LDPs currently have polices on design, without a stronger statement through national policy some developers may seek to deliver poor quality layout and design. One suggestion was that a key focus for NPF4 should be to promote a Scottish Housing Standard, which would, for example, set standards relating to low energy requirements, lower waste objectives, and ensure all new houses are accessible.

In terms of how the quality and design agenda can be taken forward, comments or suggestions included that:

• Any policy interventions in NPF4 seeking improved technical standards would be best achieved through the Building Standards process.
• While a change to the housing delivery calculation will help ensure better balance on decision-making, this must be supported by strong appeal decisions which see poor design, even in mainstream areas not affected by conservation area designations, as unacceptable.

Brown and greenfield/greenbelt

The connection was sometimes made between the efficient use of vacant or derelict sites and/or with avoiding the use of greenfield or greenbelt sites (both issues covered in greater depth at the relevant themes) and with the wider sustainability agenda.

For example, it was suggested that prioritising sustainable locations will mean prioritising brownfield sites over greenfield, edge of settlement sites. The benefits identified included protecting prime agricultural land and greenspace, not over-stretching infrastructure and services, and not creating car-dependent communities that add to carbon emissions while depopulating more sustainable town centres. It was reported that many LDPs already aim to guide development in this way and there was a call for the principle needs to be reinforced through NPF. One suggestion was that we should build more compactly within the existing footprint of our towns and to higher densities in their centres.

Comments relating to the development or redevelopment of vacant or derelict land, or disincentivising development in greenfield areas, included:

• While the re-use of urban brownfield locations is to be encouraged, not all brownfield locations are suitable for development for sustainability reasons - for example those situated within isolated countryside locations with no services.
• Zero VAT could apply to LDP allocated or brownfield sites, with full VAT payable on greenfield or greenbelt sites.

Existing housing stock

In addition to comments relating to new supply, some respondents addressed issues associated with the existing housing stock. These included that refurbishment, adaptation and improvement of existing stock and associated community regeneration have a role to play in a refocusing on quality of housing. The importance of continuing to tackle empty homes was also highlighted, with one local authority respondent reporting that long-term empty properties in private ownership equate to 3.5% of local housing stock.

Suggestions for taking the approach to existing stock forward included:

• Considerations should be given to additional mechanisms, including planning regulation and taxation, to address the issues of empty and second homes.
• Financial and practical support should be offered to restoring developers. The public sector should be enabled to take a lead in the re-use of historic buildings for housing where this is appropriate. There are models of public interest-led development where the financial risks of restoring historic buildings and places for housing delivery are shared, and these should be explored.
• Enabling the re-use and refurbishment of existing buildings for housing might require greater public sector intervention. For example, Historic Environment Scotland currently offer a Historic Environment Repair Grant and the Conservation Area Regeneration Scheme for the maintenance and re-use of existing buildings.
• Local authorities need the tools and resources to repair and bring empty buildings into use for housing where appropriate. This could include more scope to use Compulsory Purchase Order or Compulsory Lease powers where property is at risk.
• In the case of repairs to neglected tenement housing, there should be consideration of how this is to be enabled, alongside any planning provisions.
• Housing audits should consider means of paying for repairs to existing housing where the owners cannot do so.
• VAT should not be payable on repairs.

Other comments addressed particular types of existing stock and included that tenements are a valuable form of Scottish housing which should be preserved. To be effective, a review of the planning process should take into account the possible effects on neighbours' quality of life as well as the structure itself when considering planning applications for internal alterations whether the building is listed or not.

Issues associated with the energy efficiency of buildings or the use of sustainable building materials are covered under the Climate change and Sustainability themes respectively.

Other issues

Among a range of other issues raised were a number which had a rural dimension. These included that:

• Any application from an intended owner occupier/self-builder for a single house on a single plot of ground should be exempt from requiring planning permission.
• The issue of succession housing for rural businesses needs to be considered. It was suggested that planning policy should explicitly recognise that building a new home in the countryside is justified when it will enable a farmer to retire and transfer a farm to the next generation.
• There is an opportunity for the Crofting Commission to be empowered to support applications from development partnerships to take land out of crofting tenure for appropriate home builds which satisfy broader community housing needs.

Further points raised included that:

• Proposals for new housing near to airports should take full account of existing airport infrastructure and potential noise and should include noise mitigation features within their developments. Housing built in existing noise contour areas should meet higher standards of noise insulation.
• NPF4 needs to address the problem of shared equity housing becoming open market housing at the second sale, which results in continuing, unsustainable demand for new shared equity housing to be built.
• National legislation on the definition of a caravan needs review as an increasing number of alternative developments are being inappropriately assessed under this.