National Planning Framework 4: explanatory report
This explanatory report accompanies our National Planning Framework 4 revised draft. It provides a summary of the representations made through our consultation on Draft National Planning Framework 4 and sets out the changes made in response to those reviews.
Annex B – Housing Numbers
Summary of representations
Aspects that respondents liked included how the Scottish Government took an inclusive approach to arriving at MATHLR numbers with Local Authorities being consulted during the process, with most Local Authorities agreeing with the MATHLR figures set out. A different perspective was that there was a lack of input from some Local Authorities during the preparation of the MATHLR figures, while there were concerns that the MATHLR was not aligned to Housing 2040.
A number of respondents noted a lack of ambition in the MATHLR figures, with alternative MATHLR figures suggested for some Local Authorities. There were concerns raised regarding the methodology and the HNDA tool used to inform the MATHLR figures. There were some respondents who considered the approach to the MATHLR has artificially inflated housing figures and has not taken into account population declines.
|Differing views of MATHLR figures being too high and too low.||MATHLR figures have been updated where new HNDA information was available as shown in Figure 5 below.||To ensure figures are based on up-to-date evidence. MATHLR is evidence based, transparent and reasonable: it is a minimum to prevent it being interpreted as a cap - it is expected to be exceeded where evidence justifies.|
|Lack of ambition in MATHLR.||Policy strengthened to 'expected to exceed'.||To respond to Committee (LGHP) and stakeholder views. LGHP wrote to all local authorities in February 2022 regarding the MATHLR and their locally adjusted estimates. The majority of the 18 responses noted that their locally adjusted estimates increased the MATHLR from the initial default estimate supplied by the Scottish Government in February 2021. MATHLR is evidence based, transparent and reasonable: it is a minimum to prevent it being interpreted as a cap - it is expected to be exceeded where evidence justifies.|
|Impact on affordability of homes where the level of homes is too low.||No change.||The affordability of homes relates to a range of complex factors in addition to housing land. These can include wider economic circumstances, e.g. interest rates, finance availability, cost and availability of materials and skilled labour, as well as individual business decisions, e.g. site programming and build out rates linked to local housing markets.|
|Suggestion to review HNDA tool.||No change.||LGHP Committee request. HNDA is a well-established and well-understood tool that uses best available data to provide a consistent approach. It informs both Local Housing Strategies and LDPs – and maintains the necessary shared evidence base between the planning and housing systems. The MATHLR uses the first two steps of the HNDA tool as a basis, which local authorities have then considered and adjusted using local knowledge and evidence, and informed by local stakeholders.|
|Alignment with Housing to 2040.||No change.||LGHP Committee request. Housing to 2040 and NPF4 are aligned around providing more, good quality homes at the heart of great places: Housing to 2040 indicated we would make a substantial shift in our approach to planning for housing to achieve this.|
|Level of input from local authorities during preparation of the Draft MATHLR was not consistent.||No change||The statutory requirement for and approach to the MATHLR are new. It uses a consistent method, which included providing a consistent opportunity to all authorities to provide local adjustments to address local circumstances. It is expected that the HNDA process will be completed in full as part of the Evidence Report stage of the LDP preparation process and planning authorities will be able to use the outcome of the full HNDA to inform setting the Local Housing Land Requirement for the LDP, which is expected to exceed the NPF4 MATHLR figure. Meantime, we are content the MATHLR process provides a robust, evidence based approach to establishing the national requirement.|
|MATHLR methodology is not appropriate for low volume build, low populous areas.||No change.||The NPF figures are intended to be broad and reasonable. The MATHLR for Eilean Siar has not been rounded. This is because of the effect rounding to the nearest 50 can have on numbers at this scale. NPF4 expects that in rural and island areas, authorities are encouraged to set out tailored approaches to housing, which reflect locally specific market circumstances and delivery approaches.|
|MATHLR process does not sufficiently recognise the role of regional and local housing markets, or how markets operate across boundaries.||No change.||Housing is an important cross local authority boundary consideration – the approach to the MATHLR provides for cross authority working where this is preferred – see the Housing Land Requirement Explanatory Report (November 2021), para 46.|
|MATHLR would be more appropriately established through regional partnership working and should remain a function of the Regional Spatial Strategies.||No change.||The Town and Country Planning (Scotland) Act 1997, as amended, requires at Section 3A(3)(d) that the National Planning Framework contain "targets for the use of land in different areas of Scotland for housing". To meet this, Annex E of Revised NPF4 proposes a Minimum All-Tenure Housing Land Requirement (MATHLR) for each planning authority in Scotland.|
|Focusing on a minimum MATHLR may discourage ambition when it comes to identifying enough land to build the number of affordable homes the Scottish Government has committed to building in the next 10 years.||No change.||The figures are all-tenure as for national spatial planning purposes it is the scale of land that is required that is relevant. We expect tenure (market and affordable) to be considered at the local level through LDPs, which should consider the potential for all types of homes across all tenures, informed by Local Housing Strategies, and where appropriate make provision for these. Affordable housing is not all delivered through new housing developments, Revised NPF4 Policy 16(f)(iii) 'Quality Homes' supports developments of less than 50 affordable homes as part of a local authority supported affordable housing plan, on unallocated land within LDPs.|
|The population data used for the MATHLR calculations needs to be up-to-date, rather than anticipating a continuation of recent trends. Current figures reflect the pre-Brexit and COVID situation.||No change.||The 2018-based household projections were the most up to date projections available at the time of producing the MATHLR. Authorities, as they prepare their next LDPs, will be able to consider whether more up to date information and evidence is available to inform whether the NPF minimum should be increased.|
|No justification is given for the additional flexibility allowance of 25% in urban and 30% in rural areas, and that these percentages are too high.||No change.||Justification for the flexibility is set out within the Housing Land Requirement Explanatory Report (November 2021) paras 52 and 53.|
|Concern that the MATHLR process has been undertaken without reference to other NPF policies or the climate or biodiversity crises.||No change.||The MATHLR process has been undertaken looking at NPF4 as a whole. Revised NPF policy 16 Quality Homes has a number of connections to other policies within NPF, including Tackling the climate and nature crises, Climate mitigation and adaptation, Brownfield, vacant and derelict land and empty buildings, Local living and 20 minute neighbourhoods and Infrastructure First.|
|Close monitoring and biennial review of the impact of MATHLRs will be required.||No change.||The figures will inform the Local Housing Land Requirement and associated pipeline, which will be monitored via Housing Land Audits and LDP Delivery Programmes.|
|Lack of transparency for members of the public on the basis for these numbers.||No change.||A Housing Land Requirement Explanatory Report was published alongside Draft NPF4, which sets out how we have moved from the statutory requirement to the figures proposed in Draft NPF4. An Assessment Report for each authority is available, as is the material authorities provided.|
|Order of local authorities within Annex.||Local authorities have been reordered in alphabetical order.||For ease of reference.|
Review of MATHLR Figures
The MATHLR figures have been reviewed and refined to reflect up-to-date HNDA information, using the latest available existing need figures. This has resulted in a revised MATHLR figure for Local Authority areas below. Figures which have changed from Draft NPF4 are shown in bold in Figure 5.
- City of Edinburgh
- Dundee City
- East Lothian
- Fife (Central and South)
- Fife (North)
- West Lothian
Details of the above changes are set out within the Housing Land Requirement Explanatory Report – Addendum.
|Local, City Region and National Park Authority||Proposed MATHLR||Finalised MATHLR||Completions (2010-19)||Proposed MATHLR||Finalised MATHLR|
|Existing Need||Households||Flexibility %||Flexibility Amount||Existing Need||Households||Flexibility %||Flexibility Amount|
|Argyll & Bute||2,150||2,150||2,025||850||800||30||495||850||800||30||495|
|Cairngorms National Park||850||850||850||50||600||30||195||50||600||30||195|
|City of Edinburgh||41,300||36,750||16,654||8,950||24,100||25||8,263||5,300||24,100||25||7,347|
|Dumfries & Galloway||4,550||4,550||2,966||700||2,800||30||1,050||700||2,800||30||1,050|
|Fife (Central and South)||5,650||5,550||9,613||1,750||2,750||25||1,125||1,700||2,750||25||1,110|
|Loch Lomond & Trossachs N.Park||300||300||300||100||150||30||75||100||150||30||75|
|Perth & Kinross||8,500||8,500||5,560||1,350||5,200||30||1,965||1,350||5,200||30||1,965|
* The total includes Fife North and Fife Central and South. This reflects that Fife was formerly part of two Strategic Development Plan areas and contributed to separate Housing Need and Demand Assessments.
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