6. Using HOPS Planning Performance Data to Establish Housing Land Availability For Scotland
6.1 The purpose of this assessment is to discuss whether the HOPS planning performance data submitted as part of the SPP Consultation can be used to establish a Scottish wide perspective regarding housing land availability. In addition, assuming the data could be used, it considers what conclusions can be drawn from it.
Planning Performance Data
6.2 HOPS planning performance data was included as Appendix B to HOPS response to the SPP Consultation. For each of the 34 planning authorities in Scotland it contains 6 data sets for 2018/19 and 2017/18:
- Established housing supply;
- 5 year effective housing land supply (programming);
- 5 year housing supply target;
- Number of years effective supply;
- Housing approvals; and
- Housing completions over the last 5 years.
6.3 The information used in Appendix B of the HOPS response is derived from the annual planning performance framework reports from each planning authority for the period 1 April - 31 March. HOPS has published a guidebook, which includes various templates to ensure consistency.
6.4 Nonetheless, the data is compiled from each council's own report. A key source of the information used in Appendix B is the housing land audit. A draft housing land audit or an older audit may form the basis of the report because of the different timings of the land audit process and the performance reporting process. Some rural councils do not produce annual land audits. Different councils adopt different approaches to the housing land audit and it is assumed the data used is the council's position and not necessarily shared by stakeholders.
6.5 The 5 year housing supply target figure will also be sensitive to the date of the adopted local development plan. For example, a different figure may apply if a new local development plan has subsequently been adopted. In SESplan authorities, SESplan did not set a housing supply target as set out in the current SPP because it was approved before 2014. In Fife, calculating a single housing supply target is difficult because Fife is split between two SDP areas. We note from West Lothian's framework report that they have used SESplan 2 figures, which has no planning status.
6.6 Different councils monitor house completions in different ways. Some use building control completion information. Others, do their own independent monitoring. Completion data may not therefore be strictly comparable.
6.7 Our interpretation of Appendix B of the HOPS report has been undertaken with caution as it appears that there may be examples of missing data and some potential inconsistencies.
6.8 Nonetheless, it is a Scottish wide data set derived from published sources using common definitions and capable of verification and sufficient for the purposes of providing a broad indication of the scale of housing land available across the country as a whole.
Comparing the 5 year effective housing land supply (programming) with the 5 year housing supply target
6.9 Assuming that the figures in Appendix B are more or less correct, comparing the forward programmed 5 year effective supply with the 5 year housing supply target would indicate for Scotland and each council area whether there was sufficient housing land available. Making this comparison, only 5 councils would have a shortfall; Moray, Falkirk, East Ayrshire, Dumfries and Galloway and Clackmannanshire. If the National Parks are removed from Appendix B (in order to avoid any risk of double counting) then for Scotland in 2018/19 at least, approximately 160,000 units were programmed over the next 5 years. This compares to a planned requirement of 110,000 units. These two figures equate to an annual average of 32,000 and 22,000 respectively. It should be noted that the recent highest annual completions in Scotland (ignoring conversions and rehabs) was approximately 26,000 in 2007/08.
6.10 That suggests that there is a very healthy supply of land not only with potential for housing but actually programmed to be built over the 5 years from 2018/19. The total programmed is not only significantly higher than the scale of development set out in development plans but significantly higher than the recent maximum number of annual completions.
6.11 If the 5 year housing supply target is effectively the 5 year supply requirement using the average method, it also indicates that if the average method is used (as advocated in the SPP consultation) it is likely that only a few council areas would have a shortfall, where an exceptional release of land would be justified. However, the above comparison does not take into account any previous shortfalls.
Comparing the 5 year housing supply target with the previous 5 year completion data
6.12 In making this comparison it is important to note that we are trying to compare a 5 year forward projection with 5 years of historic completion information. They cover different time periods. However, when this is done, and again assuming Appendix B is accurate, only 8 councils have previous completions higher than the planned requirement; Aberdeenshire, Western Isles, East Dunbartonshire, East Renfrewshire, Edinburgh, Orkney, Renfrewshire and South Lanarkshire. Across Scotland, a planned requirement of approximately 110,000 (equivalent to 22,000 a year) can be compared to previous completions of 88,000 (equivalent to 17,500 a year).
6.13 It would therefore appear that in many council areas and certainly for Scotland as a whole, previous completions have fallen behind planned requirements. However, as the forward programmed supply of effective land is 160,000 units (32,000 a year) it would appear unsound to attribute this to a lack of effective housing land.
6.14 It is not easily possible to compare the number of councils who would have a shortfall if the residual method was used, apart from acknowledging that it is likely that it would be many more than using the average method. To calculate the 5 year supply requirement using the residual method requires a council specific calculation based on completions during the development plan period and how many years the approved development plan has left to run. The premise of the residual method is that the only way to rectify a backlog in housing completions (compared to planned requirements) is to release more land. This would only be an appropriate policy response if the reason for the shortfall was primarily and/or solely due to housing land availability. Housing land availability may well be a local factor, but most commentators would argue that low completions at a Scottish level compared to planned requirements (and especially future programming) is most likely due to a combination of factors including the capacity of the housebuilding industry, wider economic context, finance availability and social housing programmes.
6.15 Assuming that Appendix B is more or less accurate, the Scottish wide picture is that land has been identified as suitable for housing for approximately 390,000 units. In 2018/19, 160,000 of these were programmed to be built over the next 5 years (i.e. 32,000 a year) compared to a planned requirement of 110,000 (22,000 a year. These figures can be compared with 88,000 completions over the last 5 years (i.e. 17,500 a year).
6.16 Analysis of the HOPS Scottish wide data does not support the hypothesis that the only reason that completions in Scotland have lagged behind planned requirements is due to insufficient effective housing land. Instead, it suggests that there are wider issues in terms of delivering more housing units than has been achieved over the last few years.
6.17 Using the average method would mean that most councils would not have an identified housing shortfall. On the other hand, if the residual method was used it is expected that more would. Neither method can be viewed as entirely accurate or reliable in reaching a firm conclusion on the adequacy of the land supply.