New guidance from the Scottish Government shows the role of local development plans (LDPs) in delivery of housing.
LDP guidance
The LDP guidance has general provisions on timing, relationship with NPF4, format and content, etc. It also indicates the approach to be taken to delivery of housing.
Local Housing Land Requirement
The key role for LDPs is to identify a Local Housing Land Requirement (LHLR). NPF4 requires that to exceed the 10 years Minimum All Tenure Housing Land Requirement (MATHLR). There is no requirement for the LHLR to refer to Housing Market Areas.
HNDA and Evidence Report
The evidence report is a new concept. It is to include an indicative LHLR, with a transparent and understandable explanation of how it has been arrived at. Where stakeholders consider further evidence may be relevant, that should be reflected in the evidence report.
The HNDA process is to be completed in full prior to the evidence report being submitted.
Gatecheck
The new gatecheck procedure involves a Scottish Government reporter assessing whether the evidence base for the proposed LDP is sufficient. It is not expected that the evidence base will be revisited later in the procedure at the subsequent examination of the proposed LDP.
The HNDA is a key part of the evidence base. Where the Scottish Government (Centre for Housing Market Analysis) is satisfied that the HNDA is robust and credible, the approach used will not normally need to be considered further at the gatecheck. However, the reporter can consider any request for further information from stakeholders which is mentioned in the evidence report.
Call for ideas/ sites
A call for sites is an opportunity for landowners/ developers to promote their sites. Although it is not a statutory requirement, the guidance acknowledges that planning authorities might undertake a general call for ideas/ sites. Carrying it out after the gatecheck would allow stakeholder views and ideas to be informed by the contents of the evidence report.
Proposed LDP
The LDP must allocate the amount of land necessary to meet the LHLR. It should also identify which allocations would help contribute to meeting specific needs, including affordable housing, further and higher education, older people, disable people, self-build, and Gypsy/ Travellers. It should consider the potential for all types of homes across all tenures.
The LHLR can be met by sites with planning permission; sites allocated in the plan; and windfall development, where that is supported by evidence of past delivery and supported by sounds assumptions about future likely trends.
All sites for new homes should be assessed using the site appraisal methodology which was considered at the evidence report and gatecheck. No sites should automatically roll forward from one plan to the next.
The proposed plan should ideally include a site brief or masterplan for medium or long term allocations within the pipeline.
Delivery programme
Another new concept is the delivery programme. Its purpose includes establishing a deliverable housing land pipeline for the LHLR. It must set out the expected sequencing of, and timescales for, delivery of housing on allocated sites. However, it should not set targets for each pipeline period: the LHLR is an overall requirement for the plan period.
A clear pathway should be set out, to facilitate the delivery of homes, particularly where action is needed to overcome identified constraints. That includes identifying any interventions required, any costs and constraints and a clear pathway to addressing them eg. funding sources, timescales / phasing.
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