National Planning Framework 4 and what it means for our economy
Scotland needs more homes. With a shortfall now approaching 100,000 houses since 2007, this is beyond doubt and we require a robust and ambitious plan to put this right. The Scottish Parliament will shortly vote on such a plan, the fourth iteration of the National Planning Framework (NPF4).
The revised draft has improved on the original in terms of structure and readability of policies. Homes for Scotland welcomes the greater flexibility that some policies now offer, allowing them to adapt to the context of their application, for example, Local Living, 20 minute neighbourhoods.
We also recognise the importance of tackling both the climate emergency and nature crisis through the planning system. This must, however, be balanced with ensuring that Scotland’s housing needs are also met.
Whether NPF4 will deliver on this (and the associated social, economic and environmental benefits this would bring) remains to be seen. We remain disappointed that that the housing crisis is not specifically mentioned and concerned over the seeming lack of ambition to address it.
Giving home builders the tools to deliver more homes (whether social or private) would mean that more Scottish families would have the high-quality housing they need in the areas they want to live in. With every private new home estimated to contribute £30,500 by way of developer contributions to affordable housing, local infrastructure and other facilities, and the sector overall adding £3.4bn to the economy each year and supporting 80,000 jobs, prioritising housing growth seems a no-brainer.
It's most likely that housing will be delivered in spite of NPF4 rather than because of it. This is counter to the planning system that placed housing delivery at its core when the notion of NPF4 was first tabled. What we have now is, at best, passive in meeting these initial aims, with underwhelming minimum housing targets that will do little to drive forward the amount of new homes required.
One of our primary concerns is the lack of transitional guidance which risks causing considerable unnecessary delay to those applications already in the system awaiting a decision. That means fewer homes of all tenures being built in 2023 and fewer jobs created and protected whilst decision-makers, already under considerable strain, face more resourcing pressure.
There is still no mechanism for fixing an under-delivering land pipeline if longer term sites cannot come forward to fill the gap and it is unclear how an over-delivering pipeline can / will allocate further land in the event there are no available and / or deliverable brownfield sites. With the next Local Development Plans set to last for 10 years this is a concerning policy proposition and, without intervention, is likely to lead to less land coming forward to supply essential housing delivery.
While we are disappointed that Planning Minister Tom Arthur has announced there is “no scope” for any further updates ahead of the parliamentary vote, an evaluation period is likely to take place next year - a process Homes for Scotland will participate positively in. We were also pleased to hear the Minister say that he is “keen to maintain positive engagement” with us and have noted his interest in the workshop we have offered to facilitate regarding the flaws of current Housing Need & Demand Assessment methodology.
Throughout this year, we have always spoken up for those in need of a new home. We will continue to amplify their voices in 2023 and to push for a better regulatory environment that encourages home building where it is needed most.
After all, good planning should be focused on proactively enabling essential residential development as opposed to restricting it.
Liz Hamilton is Director of Planning at Homes for Scotland - www.homesforscotland.com
