Local Development Plans - evidence reports and gate checks: action plan and advice

Annex C: DPEA expectations on sufficiency

Indicative Local Housing Land Requirement (iLHLR)

Set out the summary evidence clearly. Explain the basis for your iLHLR and how it was arrived at including through engagement with relevant stakeholders.

The focus of the Evidence Report should be to highlight more up-to-date information or evidence and explain how it leads to an iLHLR that is higher than the MATHLR. Care should be taken to ensure there is no double-counting.

Consider its purpose in setting the context for a deliverable supply of land, its links to other evidence report sections, and its role in helping you explain its basis to others - including in responding to future representations to the Proposed Plan.

Step 1: The MATHLR

Legislation requires NPF4 to be taken into account. NPF4 in turn points to an ambitious approach above the MATHLR. The origins of the MATHLR do not need to be revisited. The MATHLR should be the starting point for explaining the iLHLR.

Step 2: Updated Evidence

Evidence can be drawn from the following sources to arrive at an iLHLR exceeding the MATHLR:

• Housing Need and Demand Assessment (HNDA) - including a growth scenario. Where it has robust and credible status and is up-to-date it does not need to be revisited. This is the most straightforward basis for the iLHLR, but for transparency the Evidence Report should still include a summary explanation. The Scottish Government (SG) Centre for Housing Market Analysis (CHMA) can provide advice if useful, contact CHMA@gov.scot.
• Local Housing Strategy. If this has been approved by council and is up-to-date, this can help translate the housing need and demand inputs to an anticipated land requirement reflecting wider policy objectives and delivery.

Further sources of information can also be referred to and factored into, but it is important that they are clearly justified and planning authorities should be ambitious, but not unrealistic. This may include, but is not limited to, those noted below.

• Any new or updated evidence on existing need and demand assumptions. Care should be taken, however, not to undermine established methodologies, for instance on overcrowding, and authorities should be as clear as possible as to the sources and robustness of the approach. The SG CHMA can provide advice if useful, contact CHMA@gov.scot.
• Updated evidence from new household projections. As a key input to the MATHLR and HNDA, newly published household projections can be substituted when they are used in an equivalent way to that previously agreed with stakeholders. This should prevent delay of awaiting future HNDAs. The SG CHMA can provide advice if useful, contact CHMA@gov.scot.
• Economic growth and investment assumptions. This should be evidenced preferably from an approved study or strategy but at least sufficiently explained with an estimate of potential increased housing demand or justification for additional flexibility.
• Uplift to assist with planned investment or approaches to delivery of affordable housing or to address known infrastructure constraints as part of established or proposed strategy.
• Other demand-side evidence. Planning authorities should bear in mind past completions can be a helpful benchmark but are not a measure of future need and demand.

Overly complex explanations and scenarios should be avoided. Reporters will look for a coherent explanation based on the above, accepting there is opportunity for policy ambition and that statistically based predications over a 10-year period are not an exact science. In that context, a sufficient narrative explanation may support further uplift or percentage flexibility, with consideration of benchmarking as set out below.

Source figures should be checked and explanations sense checked, including with stakeholders.

Step 3: Benchmarking

Stakeholder views can be used to test and validate the views of the planning authority. Key interests are likely to include housing colleagues and the development industry. Community engagement may help to sense check the evidence and provide other relevant information.

Information on past completions – what has proved feasible in the past – may be a helpful reference point, but the approach should be forward-looking and authorities should avoid making assumptions based on past rates of build-out which are influenced by a number of wider factors.

The latest available Housing Land Audit and delivery pipeline will also be relevant for comparison in broad terms. Accepting that the future land supply cannot be predicted at this stage, the current supply, programming assumptions and constraints can be a further sense check on the likely deliverability of the iLHLR.

Step 4: What the evidence means for the plan and next steps

Planning authorities should set out the likely implications of the iLHLR relative to the established supply of land and delivery pipeline, acknowledge the next steps and reflect an infrastructure first approach.

As far as possible, broad links should be made to the evidence on infrastructure capacity and the changes that might occur - specifically for education, health and transport - accepting that the details of delivery will fall to next steps. The evidence on infrastructure and planned and future funding can help to inform site appraisal.

It is accepted that authorities can indicate questions that will need to be revisited at the Proposed Plan stage.

Where the plan will include a developer obligations policy, fuller consideration is expected, in line with Circular 4/2025.

Transport

Evidence on existing and proposed transport infrastructure is needed to understand opportunities and capacity constraints. This is important for informing the spatial strategy, subsequent site appraisals, seeking developer contributions in line with established tests, and responding to representations at Proposed Plan stage.

The Evidence Report should focus on the purpose of the evidence for plan-making and aim to identify available capacity spatially to help inform an infrastructure first approach (i.e. making best use of existing capacity) at the Proposed Plan stage.

It should look ahead and set out the likely implications for the plan – as far as it is possible to do so at this stage – for example, to identify areas which are constrained or have capacity.

It should include fuller explanation where developer contributions are expected to be sought for education, health or other infrastructure in the context set out in Circular 4/2025.

Sufficiency Expectations: Transport

• Present baseline capacity and planned changes.
• Outline the current approach to transport investment, cross-boundary issues, funding and priorities – as far as it is possible to do so at this stage.
• Identify known opportunities for future transport investment or other improvements.
• Set out known constraints drawing on above - which parts of the area are more constrained?
• Be clear about any evidence gaps – importance and any next steps.
• Transport Appraisal: confirm commitment to appraisal - progress/intended approach (when, how, who).
• Relationship with other transport strategies – regional and local.
• Developer contributions – current approach, and issues going forward.

Authorities should summarise the final position of Transport Scotland and any regional transport partnership using the template in Annex B and provide a copy with the submission to DPEA.

A copy of the Transport Scotland response should be provided.

In broad terms at this stage, explain as far as possible what the evidence means for the plan iLHLR, site appraisal and development of the spatial strategy. The next steps should be considered and explained.

Other Infrastructure

Evidence on existing and proposed education, health and other infrastructure is needed to understand opportunities and capacity constraints. This is important for informing the spatial strategy, subsequent site appraisals, seeking developer contributions in line with established tests, and responding to representations at Proposed Plan stage.

The Evidence Report should focus on the purpose of the evidence for plan-making and aim to identify available capacity to help inform an infrastructure first approach (i.e. making best use of existing capacity) at the Proposed Plan stage.

It should look ahead and set out the likely implications for the plan – as far as it is possible to do so at this stage – for example, to identify areas which are constrained or have capacity.

It should include fuller explanation where developer contributions are expected to be sought in the context set out in Circular 4/2025.

Sufficiency Expectations: Education

• Existing and projected school rolls - the evidence should be as transparent as possible and should detail information on specific catchments and schools to be understood spatially.
• If projections are not available or only cover part of the period, the implications of this should be recognised and next steps set out to address this gap.
• Evidence Reports should recognise the 10-year timeframe of the plan - school capacity now may not be a reliable indicator going forward as the baseline in terms of demographics will change. Reporters will look for confidence there is a robust and transparent approach going forward.
• Programmed changes to the school estate.
• Potential interventions to resolve constraints, for example developer funding or guarantees.
• The local authority’s plans to address any gaps.
• Stakeholder involvement, including the council as education authority and the development industry, should be set out. Where disputes remain, these should be responded to – even if this will be addressed at the next stage.

Sufficiency Expectations: Health

• Public health evidence (including the SIMD, Demography).
• Health and social care infrastructure (capacity/programmed improvements and planned changes).
• Potential interventions to resolve constraints.

• The local authority’s plans to address any gaps.
• Stakeholder involvement, including the NHS and local Health and Social Care Partnership, should be set out.

It is recognised that available data and extent of engagement have been variable. In circumstances where developer contributions are a likely approach, gaps in evidence should be explained and an indication provided of how these would be addressed, including any joint working.

Other Infrastructure

Similar considerations should be applied to other infrastructure components, including communications, drainage, water supply and energy supply. However, it is recognised that these items are less likely to prove critical to the spatial strategy of the plan, and are less often the subject of developer contribution policies. A higher-level approach to these topics may therefore be acceptable.