Trade bodies give mixed response to draft national planning 4 framework


TWO trade bodies have issued polarising responses to the Scottish Government’s draft national planning 4 framework.

Homes for Scotland (HFS) warned that the plans risk making the housing crisis worse, warning that the shortfall is approaching 100,000 homes. However, the Royal Town Planning Institute (RTPI) welcomed the ‘ambitions’ of the Scottish Government.

In its submission to the consultation, HFS highlighted that the document, as drafted, ‘will likely reduce the number of homes delivered, thereby exacerbating the housing crisis’. It also highlighted ‘the lack of recognition’ given to the ‘housing crisis’; ‘lack of detail’ in relation to the delivery strategy and associated financial interventions; and failure to address the ongoing resources challenges within local authorities.

It added that, of particular concern is the figure proposed as the minimum all tenure housing land requirement. HFS argues that the tool used for calculating this relies too heavily on past population trends and fails to identify the full range of housing need, with many excluded from the count (eg single adults living with parents or sharing a flat, families living in a home with inadequate bedroom space). This follows a recent report showing that the cumulative housing shortfall since the global financial crisis is now approaching 100,000.

HFS head of planning, Liz Hamilton, said, “Whilst we do welcome the focus upon the ‘deliverability’ of sites and broadly agree with the intent and purpose of several of the policies, we are extremely concerned that, as it currently stands, NPF4 will lead to significantly fewer homes being built. Indeed, it appears that Scotland’s housing crisis has been forgotten but this is equally as important as the climate emergency and nature crisis.  A better balance must be struck to respond to all.

“With regard to the Housing Land Requirement, the purpose of a target was to shift focus away from numbers and on to the delivery, design and function of our future places.  In order to do that, however, the numbers must at least reflect completions over the last ten years as an absolute minimum.  Unfortunately, draft NPF4 falls short on this and looks like it is planning for decline. The Scottish Government intends to have NPF4 passed before the parliament’s summer recess but, given the importance of this document and the extent of revision that we believe is required, we are calling for a pause until updated proposals are published in full and properly consulted on and scrutinised by MSPs.

“We all have our own examples, whether it’s ourselves or people we know, of the struggle it is to find a home that meets your needs and that you can afford. That is why we need to deliver more homes, both private for sale and social affordable housing, not less.  It is crucial that the public understand what is at stake if our young people, growing families, ageing population and future generations are to have the safety and security of calling somewhere home.”

RTPI, however, said it was ‘very pleased’ with the draft, but warned that ‘more robust’ policies and a ‘focused’ delivery plan are needed to make the ambitions in it a reality. It added that there is also a need to ensure planners have the skills and resources required to implement the ambitions of the framework.

Andrew Trigger, convenor of RTPI Scotland, said, “RTPI Scotland is very pleased to see the framework recognise that planning can play a pivotal role in addressing the key challenges of our age, including the Global Climate Emergency, improving health outcomes and supporting inclusive green growth post-Covid-19. For this to happen, our places to address the needs of our communities and support net zero targets.

“This means that policies must provide the utmost clarity for those submitting planning applications, as well as for those who will be using the framework to inform decisions on development proposals. We also need to know how the ambitions of the framework will be financed and resourced through a detailed delivery plan setting out what resources will be deployed where.

“We believe that there is a need for some important redrafting to ensure policies provide the certainty required, and to develop the delivery plan. This may take longer than originally anticipated, however, we should take the time to get it right. RTPI Scotland stands ready to support Scottish Government.”