5 Summary and Conclusions
5.1 The Scottish Government instructed Ryden to research housing land audits (HLAs). The project has considered all current HLAs produced by Scottish planning authorities, their consistency, conformity with guidance, and potential for standardisation. The project has also considered the relationships of HLAs with Local Development Plan (LDP) Action Programmes to inform and support planning, market and infrastructure decision-making. The overarching aim is to help HLAs improve the planning system and deliver more housing in Scotland.
5.2 Housing Land Audits (HLAs) began as simple monitoring documents. In the modernised planning system however, with its focus on effectiveness and delivery, and in a development industry dominated by housing and constrained by infrastructure or a lack of it, these monitoring reports have become significant undertakings for local planning authorities and a major focus for the development industry.
5.3 In the context of this growing importance of HLAs, the research finds that the current suite of HLAs across Scotland is not consistently defined, researched, analysed, consulted on, tested, reported or integrated with development planning or delivery.
5.4 There are clear, numerous and significant inconsistencies against the variables and objectives set out in Scottish Government advice. All HLAs monitor the effective supply of housing land and provide a snapshot of land available for construction. Methodologies, definitions and outputs are however inconsistent, other than in the Clydeplan and Aberdeen City and Shire SDP areas where a common approach is shared. Some basic information such as tenure and site type (greenfield or brownfield/ previously developed) can be missing. Particular gaps across HLAs are the lack of information on site constraints and remedial actions, and information on sites removed from the audit.
5.5 These inconsistencies and gaps identified are of particular concern due to:-
5.5.1 The strategic local, regional and national challenge of planning for housing and monitoring progress with delivery.
5.5.2 The weight that HLAs can carry within the planning system via PAN 2/2010 and SPP in potentially rendering LDPs as not up-to-date due to the lack of a 5-year effective housing land supply.
5.5.3 The emerging local challenge of formally linking HLAs with Action Programmes and thus delivery of development plans.
5.6 It is important to stress that HLA consistency here is mainly not about ‘neatness’ or presentation. It concerns the uncertainty created in the planning and development system and the (unacceptable) possibility that applying the HLA methods used by one authority to another authority’s area would lead to different planning outcomes. Consistent, reliable housing land and development information is required by the planning system, developers, landowners, infrastructure providers, service providers and communities. It could also assist in reducing delays in producing HLAs and resources expended on disputed views.
5.7 Looking forward, it is crucial to understand whether HLAs will continue to be stand-alone monitoring reports, or are increasingly a critical, integrated element of delivery programmes for development plans. The research demonstrates that the large majority of HLAs at this time are locally evolved monitoring reports. A small number of authorities though – the exemplars noted here are Aberdeen City and Shire and Edinburgh City Councils – are now thorough in terms of consultation and site progress, constraints and remedial actions. This allows integration with Action Programmes and thus development plan delivery.
5.8 Other authorities do indicate an aim to make HLAs more delivery-focused. However, it would be of concern if the inconsistencies in current HLAs were transferred into a more complex, integrated, digitised, delivery-focused process. The opportunity afforded to this research project, to ‘unpick’ the HLA definitions, methodologies and trends, could be gradually lost if continuing evolution further embedded separate and different local planning-and-development-delivery system.
5.9 The planning system is currently being reformed. In that context, the Scottish Government asked Ryden not to produce a ‘new methodology’ for HLAs, but rather to highlight the areas for attention and suggest any interim guidance. In light of the inconsistencies identified by the research and the increasing delivery focus noted above, the potential actions in the table across pages 42 to 47 are presented as options to standardise HLAs, both for short to medium term benefit, and in advance of the next planning system, which is expected to be operational post-2020.
5.10 The table presents the HLA components and options for HLA data and analysis; reporting; integration; consultation; and implementation. The table does not comment on components of HLAs which appear from the research to operate as intended, for example the use of appropriate functional housing market areas, or the reporting of regeneration housing units net of any demolitions. The table concludes with some (out-of-scope) suggestions for the planning system and thoughts on the future of HLAs based upon this research.
5.11 The route to implementation of any of these options is a matter for the Scottish Government. However, the extent of the findings would suggest that some form of planning guidance  would be required. If left unguided, HLAs’ roles in delivery could gradually improve through closer working with action programmes, and some inconsistencies may be ironed out. However, fundamental elements such as housing tenures, types, completions and projections will still be undertaken in different ways and using different local judgements, potentially undermining any consistent links with Action / Delivery Programmes, continuing the prospect of dispute around what could be presented as ‘facts’, and frustrating any attempts to assemble large market area, regional or national analyses of housing land.
Housing Land Audits: components and options
Data and analysis
HLAs should differentiate between housing types and the tenures of completions using a standard approach. Chapters 3 and 4 identified that approaches are not consistent and some HLAs do not differentiate at all.
Market housing for sale is straightforward to define. Affordable housing less so as it has two dimensions in HLAs: the type such as social rented or shared equity; and the delivery route which may be directly by an RSL or involve the private sector through a planning permission. Programming and linking to Action Programmes requires both dimensions.
Differentiating between houses and flats should form part of a standardised approach, while noting that the mix at a site may change in future from that currently consented.
Care is required around any more detailed differentiation of house types and tenures. The research identified interest in sectors such as private rented, self-build and custom-build housing. SPP requires local authorities through their HNDAs to identify accessible and adapted housing, wheelchair housing and supported accommodation, including care homes and sheltered housing. HNDAs will also evidence need for sites for Gypsy Travellers and Travelling Showpeople. This requirement does not flow through into HLAs. If monitoring of any of these types and tenures is pursued for policy reasons, then the analysis should nest them with the main headings (market or affordable), and note that these may measure a point in time rather than existing in perpetuity (for example a resold self-build home is simply a market unit).
The research  identified a surprising range of data sources, methods and checking / validation used to calculate housing completions in HLAs. Given that completions are physical facts and require completion certificates, and the data is aggregated by Scottish Government Housing Statistics, a standardised approach around definitions of house types and tenures should be a priority in order to minimise delays in producing HLAs and promote a consistent approach.
A first objective could be for HLAs to move onto the Scottish Government’s quarterly reporting basis for house completions and seek to reconcile or explain any differences. This could smooth the annual data collation task and speed-up the production of HLAs. Monthly and eventually real-time (see below) monitoring of completions could be further objectives.
For both tenure / type and completions, there may be a requirement to parallel-run existing and new approaches for an overlap period. That would also be the time
Projections and programming
As the HLA process moves forwards from confirming historic house completions into projecting and programming future delivery, so the research finds that the methodology becomes more localised, variable and subjective (although based upon experience). An extensive mix of information sources is collated and interpreted. The modelling approach is a mix of evidence-based and operator adjustment.
Dissemination of best practice beyond the existing Homes for Scotland industry guidance on projecting completion rates is required. This will require specific analysis and advice using historic performance and a range of adjustments.
Programming will though remain a forecasting exercise, based upon best information, but entirely open to misestimation, new information and changes in circumstances.
It is noted that the more sophisticated HLAs linking with Action Programmes are separating out the supply of effective land from the programming of house building (while recognising that these are interdependent).
The research has identified that all HLA data is already stored electronically. Subject to creating consistent definitions and format, it should be capable of being stored, linked, aggregated and interrogated in a standard manner. This process is required in order to create the baseline for integration set out below.
Report formats can learn from best practice and present data in a consistent manner. However, the requirements of different planning authority areas – from major cities to rural communities and stand-alone settlements to overlapping housing market areas – would suggest that a uniform reporting template is not appropriate. Standardisation should therefore be around HLA data, as above, to create baseline information on types, tenures, completions and projections, as well as anomalies such as the varied treatment of small sites. Report formats may then be more or less detailed and sophisticated, depending upon the requirements of the local authority or market area.
It would be useful if a clear, upfront non-technical summary or dashboard could be provided within all HLAs, identifying what has been achieved in meeting the housing requirements in the LDP, including the levels of completions expected in previous audits and what has actually been delivered.
Interactive mapping should continue to be encouraged to provide open access to housing land data with planning portals. Again, authorities not yet providing this functionality can learn from those who have established interactive mapping.
HLAs within development planning
The research has identified that a small number of local planning authorities are well advanced in integrating HLAs with their LDP Action Programmes. Others are undertaking or examining this integration between what are currently separate, but mutually informative reports.
HLA information should form part of the GIS planning history held by authorities, tracking sites from proposals, to allocations, consents and development, and linked directly to the Action Programme and the timing of investments to release site constraints, all within the same suite. The Scottish Government or Heads of Planning Scotland, supported by the Digital Task Force, could work with those planning authorities currently at the cutting edge of this approach in order to assist in rolling out systems to other authorities.
At this stage however from an HLA perspective, there may be a risk in this increasing specialisation and integration within some authorities, when the wider methodological underpinnings of HLAs remain so inconsistent. The data and analysis issues noted above are therefore at least a parallel action to systems integration, if not a precursor.
From the research it could be queried how appropriate a complex integration process would be in smaller and rural areas, where there is limited certainty over what will be built and where year-to-year.
HLA consultation process
The research indicates that consultation is a valued part of the HLA process, particularly around the programming of future development. However, while some local nuance may be expected, the current consultation process varies greatly. Some of that engagement is information gathering to better inform the HLA, while some takes the form of a formal consultation to agree the outcome of the HLA.
The private sector house building industry is typically consulted via Homes for Scotland as an umbrella organisation for its members. Non-members may be also approached directly for discussions and may or may not respond. Affordable housing providers are consulted in market areas where they are very active (or are the local authority), but potentially not in other areas. Engagement with the Scottish Federation of Housing Associations to match the Homes for Scotland consultation seems to be essential, particularly given interlocking delivery with market housing via affordable housing quotas and also the Scottish Government’s current, major affordable housing programme.
The withdrawn 2016 Draft Planning Delivery Advice: Housing and Infrastructure expanded PAN 2/2010’s promotion of participation in HLA production, to HLAs actually being informed by engagement with developers, agencies and infrastructure providers. Some of the consultations currently undertaken with key agencies and other infrastructure providers may however be replaced by closer integration with Action Programmes, as those will include extensive consultation and joint working.
If the formal process to agree HLA outputs as well as inputs is to continue, then the forum with an independent chair used by one authority may be worthwhile. This type of forum followed by an approved HLA may also shorten the consultation period and thus the currently long HLA production periods.
Implementation of greater HLA consistency and quality
The Scottish Government could confirm the renewed purpose of HLAs as moving beyond monitoring reports into integrated elements of development plan delivery. As part of this, a suite of work as indicated above is required around HLA data and analysis, programming, consultations, reporting, systems and integration. Some of this can be achieved through dissemination of best practice; other elements are more complex and require research and design of solutions (possibly including software).
At the Scottish level, the objective should be a clear and consistent ‘national’ HLA.
A formal forum operating during the period 2019-2021, possibly convened by the Scottish Government, and including Heads of Planning Scotland and the Improvement Service, in consultation with house builders and infrastructure agencies, would assist with the standardisation of HLAs in the run-up to planning reform.
If the Scottish Government decides to support a standardised and consistent approach to HLAs, then the areas for consideration noted above could be assessed then included in national planning guidance. A further review and evaluation would be required by 2019/ 2020 to establish progress with HLAs at that time, using this report as a March 2018 baseline.
Future of HLAs
The standardisation of HLAs set out above can help to drive planning reform post-2020. A fully integrated, digitised development planning system - from site proposals through to completed developments - may mean that an HLA is simply a real-time progress report, which can be commissioned and run as required, layered with market area, sites, completions and Delivery Programme data from digital interfaces.
At this future point, the housing land focus could potentially move from intensive data gathering and analysis, onto planning, monitoring and evaluating outcomes.
Planning System (out-of-scope additional comments)
5-year effective housing land supply
SPP’s requirement for a continuous 5-year effective housing land supply, in tandem with PAN 2/2010’s effectiveness criteria, mean that the findings of an HLA can lead to the release of additional housing sites, or refusal of planning permission for unallocated sites.
A calculation to establish this 5-year housing land supply is set out in different draft documents but is not yet published as a standard to be adopted. A standard approach could also confirm the treatment of shortfalls in completions from previous HLA periods and the treatment of any new HNDA information (see paragraph 4.14) when undertaking future programming.
HLAs in the planning system
HLAs evolved to monitor the erosion of housing land and to ensure effective future supply. If they are to move beyond being a planning audit of whether there is ‘enough’ land, to become part of a programmatic approach to delivery of a range of housing and complex infrastructure, then a formal statement could support this transition.
If LDPs are to remain extant for 10 years rather than 5, Housing Land Requirements may decay over time. In the absence of any adjustment mechanism the ‘new need and demand information’ problem noted above could compound over time.
As noted here, the move from Action Programme to Delivery Programmes would potentially enhance the role of HLAs in delivering development plans.
The removal of Strategic Development Plans may affect some of the more considered HLA and regionally standardised work currently produced in Scotland (noting however that new strategic/ regional planning approaches are proposed).
Email: Deborah McLean