Housing land audits: research project

HLAs should differentiate between housing types and the tenures of completions using a standard approach. Chapters 3 and 4 identified that approaches are not consistent and some HLAs do not differentiate at all.

Market housing for sale is straightforward to define. Affordable housing less so as it has two dimensions in HLAs^[32]: the type such as social rented or shared equity; and the delivery route which may be directly by an RSL or involve the private sector through a planning permission. Programming and linking to Action Programmes requires both dimensions.

Differentiating between houses and flats should form part of a standardised approach, while noting that the mix at a site may change in future from that currently consented.

Care is required around any more detailed differentiation of house types and tenures. The research identified interest in sectors such as private rented, self-build and custom-build housing. SPP requires local authorities through their HNDAs to identify accessible and adapted housing, wheelchair housing and supported accommodation, including care homes and sheltered housing. HNDAs will also evidence need for sites for Gypsy Travellers and Travelling Showpeople. This requirement does not flow through into HLAs. If monitoring of any of these types and tenures is pursued for policy reasons, then the analysis should nest them with the main headings (market or affordable), and note that these may measure a point in time rather than existing in perpetuity (for example a resold self-build home is simply a market unit).

The research ^[33] identified a surprising range of data sources, methods and checking / validation used to calculate housing completions in HLAs. Given that completions are physical facts and require completion certificates, and the data is aggregated by Scottish Government Housing Statistics, a standardised approach around definitions of house types and tenures should be a priority in order to minimise delays in producing HLAs and promote a consistent approach.

A first objective could be for HLAs to move onto the Scottish Government’s quarterly reporting basis for house completions and seek to reconcile or explain any differences. This could smooth the annual data collation task and speed-up the production of HLAs. Monthly and eventually real-time (see below) monitoring of completions could be further objectives.

For both tenure / type and completions, there may be a requirement to parallel-run existing and new approaches for an overlap period. That would also be the time
to consider alignment of HLA publication around either the calendar or financial year-end (although quarterly completions monitoring may remove that requirement).

As the HLA process moves forwards from confirming historic house completions into projecting and programming future delivery, so the research finds^[34] that the methodology becomes more localised, variable and subjective (although based upon experience). An extensive mix of information sources is collated and interpreted. The modelling approach is a mix of evidence-based and operator adjustment.

Dissemination of best practice beyond the existing Homes for Scotland industry guidance on projecting completion rates is required. This will require specific analysis and advice using historic performance and a range of adjustments.

Programming will though remain a forecasting exercise, based upon best information, but entirely open to misestimation, new information and changes in circumstances.

It is noted that the more sophisticated HLAs linking with Action Programmes are separating out the supply of effective land from the programming of house building (while recognising that these are interdependent).

The research has identified that all HLA data is already stored electronically. Subject to creating consistent definitions and format, it should be capable of being stored, linked, aggregated and interrogated in a standard manner. This process is required in order to create the baseline for integration set out below.

Report formats can learn from best practice and present data in a consistent manner. However, the requirements of different planning authority areas – from major cities to rural communities and stand-alone settlements to overlapping housing market areas – would suggest that a uniform reporting template is not appropriate. Standardisation should therefore be around HLA data, as above, to create baseline information on types, tenures, completions and projections, as well as anomalies such as the varied treatment of small sites. Report formats may then be more or less detailed and sophisticated, depending upon the requirements of the local authority or market area.

It would be useful if a clear, upfront non-technical summary or dashboard could be provided within all HLAs, identifying what has been achieved in meeting the housing requirements in the LDP, including the levels of completions expected in previous audits and what has actually been delivered.

Interactive mapping should continue to be encouraged to provide open access to housing land data with planning portals. Again, authorities not yet providing this functionality can learn from those who have established interactive mapping.

The research has identified that a small number of local planning authorities are well advanced in integrating HLAs with their LDP Action Programmes. Others are undertaking or examining this integration between what are currently separate, but mutually informative reports.

HLA information should form part of the GIS planning history held by authorities, tracking sites from proposals, to allocations, consents and development, and linked directly to the Action Programme and the timing of investments to release site constraints, all within the same suite. The Scottish Government or Heads of Planning Scotland, supported by the Digital Task Force, could work with those planning authorities currently at the cutting edge of this approach in order to assist in rolling out systems to other authorities.

At this stage however from an HLA perspective, there may be a risk in this increasing specialisation and integration within some authorities, when the wider methodological underpinnings of HLAs remain so inconsistent. The data and analysis issues noted above are therefore at least a parallel action to systems integration, if not a precursor.

From the research it could be queried how appropriate a complex integration process would be in smaller and rural areas, where there is limited certainty over what will be built and where year-to-year.

The research indicates that consultation is a valued part of the HLA process, particularly around the programming of future development. However, while some local nuance may be expected, the current consultation process varies greatly. Some of that engagement is information gathering to better inform the HLA, while some takes the form of a formal consultation to agree the outcome of the HLA.

The private sector house building industry is typically consulted via Homes for Scotland as an umbrella organisation for its members. Non-members may be also approached directly for discussions and may or may not respond. Affordable housing providers are consulted in market areas where they are very active (or are the local authority), but potentially not in other areas. Engagement with the Scottish Federation of Housing Associations to match the Homes for Scotland consultation seems to be essential, particularly given interlocking delivery with market housing via affordable housing quotas and also the Scottish Government’s current, major affordable housing programme.

The withdrawn 2016 Draft Planning Delivery Advice: Housing and Infrastructure expanded PAN 2/2010’s promotion of participation in HLA production, to HLAs actually being informed by engagement with developers, agencies and infrastructure providers. Some of the consultations currently undertaken with key agencies and other infrastructure providers may however be replaced by closer integration with Action Programmes, as those will include extensive consultation and joint working.

If the formal process to agree HLA outputs as well as inputs is to continue, then the forum with an independent chair used by one authority may be worthwhile. This type of forum followed by an approved HLA may also shorten the consultation period and thus the currently long HLA production periods.

The Scottish Government could confirm the renewed purpose of HLAs as moving beyond monitoring reports into integrated elements of development plan delivery. As part of this, a suite of work as indicated above is required around HLA data and analysis, programming, consultations, reporting, systems and integration. Some of this can be achieved through dissemination of best practice; other elements are more complex and require research and design of solutions (possibly including software).

At the Scottish level, the objective should be a clear and consistent ‘national’ HLA.

A formal forum operating during the period 2019-2021, possibly convened by the Scottish Government, and including Heads of Planning Scotland and the Improvement Service, in consultation with house builders and infrastructure agencies, would assist with the standardisation of HLAs in the run-up to planning reform.

If the Scottish Government decides to support a standardised and consistent approach to HLAs, then the areas for consideration noted above could be assessed then included in national planning guidance. A further review and evaluation would be required by 2019/ 2020 to establish progress with HLAs at that time, using this report as a March 2018 baseline.

The standardisation of HLAs set out above can help to drive planning reform post-2020. A fully integrated, digitised development planning system - from site proposals through to completed developments - may mean that an HLA is simply a real-time progress report, which can be commissioned and run as required, layered with market area, sites, completions and Delivery Programme data from digital interfaces.

At this future point, the housing land focus could potentially move from intensive data gathering and analysis, onto planning, monitoring and evaluating outcomes.

SPP’s requirement for a continuous 5-year effective housing land supply, in tandem with PAN 2/2010’s effectiveness criteria, mean that the findings of an HLA can lead to the release of additional housing sites, or refusal of planning permission for unallocated sites.

A calculation to establish this 5-year housing land supply is set out in different draft documents^[35] but is not yet published as a standard to be adopted. A standard approach could also confirm the treatment of shortfalls in completions from previous HLA periods and the treatment of any new HNDA information (see paragraph 4.14) when undertaking future programming.

HLAs evolved to monitor the erosion of housing land and to ensure effective future supply. If they are to move beyond being a planning audit of whether there is ‘enough’ land, to become part of a programmatic approach to delivery of a range of housing and complex infrastructure, then a formal statement could support this transition.

If LDPs are to remain extant for 10 years rather than 5, Housing Land Requirements may decay over time. In the absence of any adjustment mechanism the ‘new need and demand information’ problem noted above could compound over time.

As noted here, the move from Action Programme to Delivery Programmes would potentially enhance the role of HLAs in delivering development plans.

The removal of Strategic Development Plans may affect some of the more considered HLA and regionally standardised work currently produced in Scotland (noting however that new strategic/ regional planning approaches are proposed).