Housing to 2040: consultation analysis
Report summarising and describing the responses to the public consultation on Housing to 2040.
This document is part of a collection
Analysis of Question 1. Do you have any comments on the draft vision and principles?
It should be noted that some of the comments presented in this section will have been based on the vision and principles leaflet, which is an abbreviated version of the full draft vision and principles document.
In general, the responses to this question were quite positive, and the draft vision and principles were broadly supported by respondents. Comments from those who were supportive of the draft vision and principles included praise for the clarity and breadth of the document and its aspirational and ambitious vision.
"Overall the draft vision provides a clear indication of what the housing system needs to provide, in order to meet people’s needs. There is very little to disagree with in terms of the vision." - Local authority
Some respondents had reservations about how realistic and achievable the aims were given the challenges faced by the housing sector. A few expressed concern that the Scottish Government has set ‘unrealistic targets’ and has not fully set out how the principles and vision will be achieved.
Some respondents suggested that if the aims are to be achieved, this would require a multi-level collaborative approach to housing.
"Translating this ambitious vision into reality by 2040 will require partnership, courageous collaboration, resources and creativity – moving beyond traditional silos to seek stronger outcomes." - Registered social landlord
A minority thought there were not enough references to those with disabilities or long-term health conditions in the draft vision and principles. They suggested the vision should include a section which addresses the specific needs of groups such as wheelchair users and people with dementia.
A well-functioning housing system
High quality sustainable homes
Homes that meet people’s needs
Respondents also provided feedback on each of the individual visions and principles. This feedback is presented throughout the remainder of this chapter under the four headings which correspond to those set out in the draft vision and principles:
The analysis presented in this chapter is based on comments made specifically about each of the draft visions and principles.
A well-functioning housing system
There were several comments about the vision for a well-functioning housing system but most respondents opted to give feedback on the individual principles.
Of those that did comment on the vision, their responses were generally positive and included some suggestions about enhancing the language used in the vision and accompanying statements. For example, a few respondents suggested that the ‘Finding the right home’ section should also acknowledge the importance of maintaining a home that meets the owners’ needs.
Principle 1: The housing system should supply high-quality affordable homes for living in, to shift the balance away from the use of homes as a means to store wealth.
There was mixed feedback on Principle 1. Some respondents embraced the proposal to shift the balance away from homes as a means to store wealth. They felt that this would achieve stabilised house prices and were positive about the proposed people-centred approach to housing, rather than a market-driven approach.
However, others expressed concern over the implications this would have on those who rely on housing investments, for example those who have chosen to invest in housing as a means of supporting themselves through retirement.
"This could potentially suggest some unnecessary market intervention. It also fails to take account of the fact that building and storing wealth, through the main asset of a home, has served many people well; as housing has proved to be a stable investment. People have been able to release equity to fund retirement and reduce reliance on the state." - Architects and design/development organisation and professional/umbrella organisation
A minority of respondents sought clarity on some of the language used in Principle 1, for example ‘means to store wealth’ and ‘affordable’. One felt that care should be taken not to confuse the term ‘affordable homes’ with ‘affordable housing’.
Principle 2: Government policy (including taxes and subsidies, for example) should promote house price stability, to help underpin Scotland’s standard of living and productivity and promote a Fairer Scotland.
There was no clear consensus in the feedback provided on Principle 2. A minority of respondents drew attention to the lack of suitable housing supply and how this was a key factor in addressing house price stability.
"Our members are firmly of the view that the current pressure on the housing market is driven by a lack of supply across all tenures. While this leads to perceived conflict between tenures/uses, it masks the underlying issue to which the only solution is a step change in the supply of new dwellings." - Architects and design/development organisation and professional/umbrella organisation
A few respondents raised concerns about the effect that increased government involvement would have on the operation of the housing market. Respondents felt that this could lead to negative financial and economic consequences such as a supressed market in some areas.
"While this shouldn’t hold Scotland back in continuing to pursue more progressive housing policy there must be appreciation of the potential wider implications. For example this could potentially lead to further financial/ economic issues if banks and investors continue to invest money purely on the basis of greatest financial return, as opposed to pursuing more ethical and sustainable investment policies." - Local authority
One respondent had concerns that Government intervention to increase the amount of homes being built could lead to inflationary tendencies and workforce capacity issues with local contractors.
Local authorities and other organisations representing rural and island areas were pleased to see consideration given to rural areas in this section of the strategy. However, one respondent felt it was important to recognise that not all rural communities experience the same issues with regard to the housing sector.
"The housing market in Skye is immensely pressured with a number of supply and demand factors leading to house price inflation and problematic access for lower income household. On the other hand, parts of Sutherland have lower demand issues." - Local authority
Principle 3: Everybody should be able to save for the future (as well as be secure in their home and make significant changes to it) whether they rent or own.
Many respondents agreed that it was important to be able to save for the future, regardless of tenure. However, some disagreed that homeowners and tenants, especially those on low incomes, would have the ability to save for the future or improve their homes.
A minority of respondents described innovative ways in which this could be addressed.
"Hybrid approaches could provide opportunities to combine an ownership/investment stake with renting, whereby households could invest in a collective housing scheme with a secure tenancy to allow for saving over time." - Private company
"Our Rent to Buy Scheme - where the tenant saves for their deposit through an element of their rent and they purchase the property at a previously agreed price (with no link to increase in market value) at 5 years - has proved immensely popular." - Private company
Others made comment on how it was not always possible for significant changes to be made to housing stock in some cases, for example where there are legal or financial barriers or limitations related to ownership.
Principle 4: Housing provision should be informed by whole life economic costs and benefits in the round and help to address inequalities in health, wealth and education.
Feedback on Principle 4 was positive, with many respondents highlighting the importance of considering whole life costs in housing provision. Others applauded the principle as broad and well-rounded, taking into account the upfront build cost, running costs and environmental impact of new homes.
It was recognised that considering whole life costs in housing provision would ultimately reduce costs for public services such as health and social care.
A minority of respondents felt that it should be more explicit that whole-life economic costs include environmental costs such as carbon costs, and that environmental benefits should have more credence in this principle.
High-quality sustainable homes
The main comment about this section from some respondents was the need for more focus on the importance of retrofitting sustainability measures in existing homes. They felt that it is crucial to include references to energy efficiency and low carbon measures that can be retrofitted in existing homes.
"It is also crucial that energy efficiency and low carbon retrofit is highlighted throughout the statement, so we encourage deeper and wider integration of low and zero carbon ambitions." - Local authority
Principle 5: Tenure-neutral space and quality standards for new homes (and existing homes where possible) should be set specifically to improve and protect quality of living and of place.
A minority of respondents provided specific feedback on Principle 5 and for those that did, their comments generally supported this principle. However, a few felt that this part of the strategy was already addressed through existing Building Standards Regulations.
A few of the respondents expressed concern over the cost implications of applying new space and quality standards to existing homes.
"To attempt to introduce retrospective space and quality standards to existing homes would be extremely difficult to implement, and costly to administer and control at local government level. Additional local government resources would need to be employed and funded and it could create a negative impact on the housing market." - Architects and design/development organisation and professional/umbrella organisation
Two respondents felt that it was important to include a reference to environmental standards relating to low carbon energy and heat supplies.
Principle 6: Government policy should promote a greater diversity of home builders and broader availability of land for development to reduce prices and improve building quality.
There was no clear consensus in responses to Principle 6. Some of those who provided feedback supported this principle, agreeing that the Scottish Government has an important role to play in promoting greater diversity in the supply chain and in making land available for development.
A minority of respondents commented that there has not been enough consideration given to barriers to competition in the construction market, for example issues around public sector procurement regulations, contractor capacity and cost. In rural areas in particular, factors such as the number and capacity of contractors, and additional costs associated with travel and accessibility of sites which limit contractor availability and market competition.
A few others thought that Principle 6 did not focus enough on environmental issues, and that in order to address the climate emergency, there needs to an improvement in minimum environmental standards of new and existing housing.
"Building quality at even the most basic level should be fit for the 2050 climate mitigation and adaptation standards, we should not be building a future retrofit burden as that will reduce economic, health and environmental benefits from now until they are finally delivered, undermining all other aspects of a vision for a better future." - Local authority
Furthermore, one respondent felt that the statement ‘Developers offer a real choice and new homes are customised to the first occupants’ wants and needs’ should include a caveat with a minimal energy standard of the energy consumption of all homes.
Principle 7: All tenures should apply the same high quality and safety standards and levels of consumer protection.
There were limited comments made about Principle 7. Some respondents expressed support for this principle and agreed with the need for high quality and safety standards and levels of consumer protection, and noted that conversely, poor quality development standards will have widespread negative consequences in the future.
However, others expressed concern over the following statement: ‘Homes that cannot reasonably be adapted to meet the standards (taking account of technical feasibility and cost effectiveness) are considered for demolition or are repurposed’, specifically the reference to demolition. A few respondents questioned the circumstances under which homes could be demolished. Others felt that demolition of homes could be counter-productive in meeting net-zero carbon targets.
"The statement…should be treated with extreme caution. Energy Performance Certificate (EPC) ratings do not, at present, accurately rate many traditionally built properties." - Local third/community sector organisation
"Demolition/Repurpose – very broad. Can your home be taken off you if you don’t agree to standards? Definition would need clarification." - Registered social landlord
Principle 8: New homes for sale should be built to high standards, defects should be identified and remedied quickly and all owners should be required to maintain the condition of their home.
Most respondents supported Principle 8. Some pointed out specific elements of the principle that they agreed with, such as the emphasis on the quick identification and remedy of defects in housing, the principle that all owners be required to maintain the condition of their home and that the Scottish Government has an important role to play in promoting high quality and safety standards.
However, a minority of respondents noted that they felt that high standards should be applied to all new homes from across the three main housing tenures, not specifically new homes for sale.
A few respondents felt that the phrase ‘sometimes required’ in the accompanying descriptor was not strong enough and would not drive behaviour change.
"The statement that people are ‘encouraged, sometimes required, to cooperate over communal repairs’ should be strengthened so that participation in communal repairs is not an option and all properties in such situations should be required to appoint a property factor for the management of property repairs." - Local authority
Principle 9: Decisions around the quality, location and utilisation of existing stock and new build should be ambitious in enhancing biodiversity, promoting Scotland’s energy security, and be consistent with the target for Scotland’s emissions to be net zero carbon by 2045.
Some respondents expressed strong support for Principle 9, describing it as ‘excellent’ with particular support for the statement that ‘New build homes are built so that they are net zero carbon (i.e. built to high standards of energy efficiency and use renewable heat or very low carbon heating)’.
However, there were others who felt that fuel poverty was not sufficiently addressed in this principle, given the increasing number of households facing extreme fuel poverty in Scotland. They suggested that further effort needs to be made to tackle this. One participant suggested that having a warm home and how this impacts on people’s health should have its own principle.
A few suggested that the principle’s main focus should be changed, or that new factors should be considered as part of Principle 9. There was no consensus on the changes that should be made, and examples of individual suggestions are given below:
- More focus should be placed on creation of sustainable heating in homes
- Include a reference to proposed regulatory requirements to achieve specific energy performance targets
- Consider the development of net zero carbon communities, not just individual homes
- Include a reference to water efficiency
Most of the feedback on ‘sustainable communities’ was positive. They recognised the importance of achieving sustainability and the vision was described as aspirational. A few respondents were pleased to see a specific reference to flood and storm resilience.
"We welcome the ambition for flood resilience and would encourage that to be strengthened for provision of homes that can withstand extremes of temperature and are resilient to storm damage, not just flooding." - Local authority
Principle 10: New housing, and the required community resources, should only be provided where they help to create safer, stronger, attractive, sustainable and integrated communities.
There were limited comments made about Principle 10 but those who did respond showed clear support and felt the proposals in Principle 10 were to be commended. A few respondents drew attention to the important role of collaboration between planning and other policy areas in building infrastructure to create safer and stronger communities.
Principle 11: Local communities should be empowered to respond to housing need in their area, as part of a coherent regional economic approach (creating and maintaining jobs) and supported by provision of the right infrastructure.
Principle 11 was welcomed by many respondents who were pleased to see that the importance of community involvement was recognised in the approach to housing. Participants supported the notion that local communities should have input into determining local housing needs.
"Community engagement is a key part of major development and should be meaningful, timely and efficient." - Architects and design/development organisation and professional/umbrella organisation
As well as community involvement, a few stressed the importance of collaboration in achieving this principle, specifically supporting a cross-sector, joined-up approach to housing.
Principle 12: Government intervention should help existing and new communities to be physically, digitally, culturally and economically connected within a coherent geographic region; this includes retaining and attracting vibrant communities in areas facing depopulation.
Principle 12 attracted positive feedback from many respondents. Several endorsed the principle for addressing of the role of the Scottish Government in supporting and regenerating communities across Scotland.
Although many were supportive of Principle 12, some expressed doubt over how achievable this would be and noted some barriers to its implementation.
"Although it is always preferable to house people near work, education and other services as set out in principles 11 and 12, high demand areas in a market-led system are likely to prevent this from being attainable on every occasion." - Local authority
Others felt there would be challenges achieving this principle in rural areas, where there are wide range of complex reasons why people may move away from the area.
Homes that meet people's needs
Feedback was limited about the vision overall although the majority of respondents commented on the individual principles contained within the vision. A few respondents suggested that the reference to veterans in the ‘my rights’ statement should be changed to include other protected groups who may require additional support, for example care leavers, ex-prisoners or those with additional needs.
Principle 13: Government should ensure that there are affordable housing options across Scotland for households at all income levels.
The majority of respondents agreed with Principle 13 and supported the objective to provide fully sustainable communities across Scotland.
"We fully endorse this statement and believe that development in large conurbations, providing multi tenure residential led large scale regeneration projects which are suitable for a wide variety of end users and customers, creates better places." - Trade association
However, a minority felt that the statement did not go far enough or contain sufficient detail, describing it as too simplistic and lacking explicit detail on low carbon sources of heat and power. One felt that the term ‘affordability’ in this principle could be extended to "affordability including running costs".
A few were critical that the principle seemed to suggest that only those at the higher end of the income scale were able to afford the home of their choice. They felt an element of choice in housing is important and should not just be reserved for ‘households at the higher end’ of the income distribution.
"While it is acknowledged that assistance is given through the provision of social rented housing and assistance with housing costs on the basis of need, the wording of Principle 13 could be improved to recognise the importance of households across all income groups being able to exercise choice." - Local authority
Principle 14: Housing and the housing market should be highly flexible to enable people to meet their changing needs.
This principle was welcomed by many respondents. The reference to supporting ‘the diverse people of Scotland’ was received particularly well by some respondents. Many respondents also agreed that adaptability of homes will enable people to live longer in their existing communities.
Some respondents highlighted the importance of ensuring flexibility in new builds and future-proofing homes. Smart design solutions, such as wider door thresholds and wet room flooring in bathrooms were identified as ways in which housing can meet demand in the future.
Further examples of this are included in our analysis of Question 4, "Do you have any proposals that would increase the accessibility and/or functionality of existing and new housing (for example, for older and disabled people)?"
Principle 15: Everyone has a right to an adequate home
The majority of responses to this principle were positive. The respondents who commented on this principle unanimously agreed with its sentiment and appreciated that housing was being recognised as a human right.
"Housing as a human right should be the foundation of housing policy and the starting point for setting out our ambitions for our housing system." - National third sector organisation
A recurring suggestion about Principle 15 was that it should appear earlier in the list of principles. Some respondents suggested it should be the first principle in this list.
A few respondents had reservations about the choice of the phrase ‘adequate home’ and felt it should be replaced with more ‘ambitious’ language, for example ‘housing which is affordable and meets all statutory standards’.
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