Planning and the housing emergency: delivery plan details: EIR release

Information request and response under the Environmental Information (Scotland) Regulations 2004.


Information requested

I refer to the just published Planning and the housing emergency: delivery plan which states that since 2014 on average there have been c. 10,000pa fewer houses completed (19,160) than were given planning permission (29,000). In addition, there appears to have been a gap prior to 2014, since you state that the total number of unbuilt houses with planning permission is 164,000. You further state that this gap between housing starts and completions appears to be even wider. Please advise if any of the above figures include purpose built student accommodation (PBSA) and if so, what percentage of permissions and completions pertains to PBSA. Further, please advise how many sites included in the above statistics have obtained ordinary residential planning permission and for PBSA for the same or substantially congruent site (this is the case for at least sites in LCCC's area) and how this has been reconciled on the above statistics.

Response

The figures on the number of units approved originate from the Home Builder Federation's quarterly Housing Pipeline report, which is available online. These reports state that "Elderly people's homes, hostels and student accommodation have been excluded from the analysis."

The figures on housing completions and starts-on-site are based upon data collected from local authorities through Housing Forms "NB1" and "NB2" forms. These forms are not intended to include "communal establishments", which would include PBSA. Therefore, although we cannot guarantee that there will not be exceptions, we would expectthat PBSA is unlikely to be included in these figures.

The "164,000 unbuilt approvals" figures is based in data from the schedules of local authority Housing Land Audits. Housing Land Audits are completed by local authorities, following guidance set out by the Scottish Government in Planning Advice Note 2/2010: Affordable Housing and Housing Land Audits. This guidance does not specifically refer to whether or not PBSA should be included.

However, the purpose of the Housing Land Audit is primarily to monitor progress against housing targets, which do not include PBSA, so to the best of our knowledge consents for PBSA would not generally be included in Housing Land Audit data.

With regard to your question as to how many sites included in the statistics have obtained residential planning permission and for PBSA for the same or substantially congruent site, the Scottish Government does not hold this information.

Under the terms of the exception at regulation 10(4)(a) of the EIRs (information not held), the Scottish Government is not required to provide information which it does not have. The Scottish Government does not have the information you have requested because the Scottish Government is not responsible for collating site level data on planning permissions. This exception is subject to the â€˜public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exception. We have found that, on balance, the public interest lies in favour of upholding the exception. While we recognise that there may be some public interest in information about sites with permission for PBSA, clearly we cannot provide information which we do not hold.

About FOI

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Contact

Please quote the FOI reference
Central Correspondence Unit
Email: contactus@gov.scot
Phone: 0300 244 4000

The Scottish Government
St Andrew's House
Regent Road
Edinburgh
EH1 3DG

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