Audit Scotland published a report on the Scottish Government's affordable housing target in April. The findings were that a number of factors (not including the coronavirus lockdown) could adversely affect delivery of the targeted 50,000 affordable homes by end of March 2021.
Coronavirus
The Scottish Government has conceded that the current lockdown will delay the target beyond March 2021.
The extension of certain planning deadlines in Scotland (recognising the effects of Covid-19) has been generally welcomed by the housebuilding industry and councils are continuing to process and approve planning applications. Scottish Government has temporarily shared the AHSP lead contacts with the construction industry with a view to enabling purchases of completed and partially completed houses. We have been instrumental in making introductions between housebuilders with affordable private stock to RSLs and have already seen block sales progressing.
Once attention moves to the economic recovery, construction activity could be boosted if the Scottish Government suggests a focus on consenting housing sites to planning authorities, especially those for/and including affordable housing.
Planning issues
Planning issues were among the factors identified in the Audit Scotland report as barriers to the delivery of the 2021 target. Those included delays in planning permissions because of funding reductions and stretched resources in planning authorities. In addition, an ageing workforce was identified with an anticipated loss of skills and expertise. The responses received by the Audit Commission included references to developer contributions and S75 policies. The anticipated review of application fees may remedy the reductions in funding. Although an increase in fees would be unpalatable developers can take steps to mitigate delays in completing section 75 agreements by ensuring that the details of contributions have been identified, fully considered and (where possible) agreed in advance with the case officer. Detailed heads of terms are useful and can reduce the need for solicitors to negotiate the terms of an agreement resulting in the earlier release of permission.
Future
Publication of the consultation draft NPF4 has been delayed until 2021. NPF4 will undoubtedly include statements on the continuing role of the planning system in the provision of affordable housing and we can expect developer contributions and section 75 agreements to remain as part of the planning regime.