Appendix C - Homes
Perth and Kinross Council · 5 March 2025
Back to Perth and Kinross Council — 5 March 2025 and its agenda
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Perth and Kinross LDP3 2027 Draft Evidence Report Appendix C Homes March 2025
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Issue: Homes Acronyms used in this section BPC Big Place Conversation HLA Housing Land Audit HMA Housing Market Area HMO Houses in Multiple Occupation HMP Housing Market Partnership HNDA Housing Needs and Demand Assessment HST Housing Supply Target LDP Local Development Plan (i)LHLR (Indicative) Local Housing Land Requirement LHS Local Housing Strategy MATHLR Minimum All Tenure Housing Land Requirement NPF National Planning Framework NRS National Records of Scotland PKC Perth and Kinross Council RSL Registered Social Landlord SDP Strategic Development Plan SHIP Strategic Housing Investment Programme SME Small to Medium sized Enterprise Corresponding NPF4 policies: • NPF Policy 16: Quality Homes • NPF Policy 17: Rural Homes (part) • Other key NPF4 policy connections - 1: Tackling the climate and nature crises; 2: Climate mitigation and adaptation; 4: Natural Places; 7: Historic assets and places; 8: Green belts; 9: Brownfield, vacant and derelict land and empty buildings; 10: Coastal development; 13: Sustainable transport; 14: Design, quality and place; 15: Local living and 20 minute neighbourhoods; 18: Infrastructure First; 19: Heating and cooling; 20: Blue and green infrastructure; 21: Play, recreation and sport; 23: Health and safety; 27: City, town, local and commercial centres; 29: Rural development; 30: Tourism. Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 020: Homes https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume nts/TP020_Homes.pdf Information required by the Act and NPF4 regarding the topic: Sections 15(5), 16(2) and 16B of the Town and Country Planning (Scotland) Act 1997, as amended: • the housing needs of the population of the area, including in particular, the needs of persons undertaking further and higher education, older people and disabled people • the availability of land in the district for housing, including for older people and disabled people • persons seeking to acquire land for self-build housing • the action taken to support and promote the construction and adaptation of housing to meet the housing needs of older people and disabled people in the area, and the extent to which the action has helped to meet those needs • the action taken to meet the accommodation needs of Gypsy / Travellers in the area, and the extent to which the action has helped to meet those needs Under Policies 16 and 17 NPF4 expects Local Development Plans to: • Identify a Local Housing Land Requirement • Allocate deliverable land to meet the 10-year Local Housing Land Requirement • Identify areas which may be suitable for new homes beyond year 10
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• Allocate land for Gypsy / Travellers and Travelling Showpeople where need is identified Policy intent for Policy 16: • To encourage, promote and facilitate the delivery of more high quality, affordable and sustainable homes, in the right locations, providing choice across tenures that meet the diverse housing needs of people and communities across Scotland. Policy intent for Policy 17: • To encourage, promote and facilitate the delivery of more high quality, affordable and sustainable rural homes in the right locations. Policy outcomes for Policy 16: • Good quality homes are at the heart of great places and contribute to strengthening the health and wellbeing of communities. • Provision of land in the right locations to accommodate future need and demand for new homes, supported by the appropriate infrastructure. • More energy efficient, net zero emissions homes, supporting a greener, fairer and more inclusive wellbeing economy and community wealth building, tacking both fuel and child poverty. Policy outcomes for Policy 17: • Improved choice of homes across tenures so that identified local needs of people and communities in rural and island areas are met. • Homes are provided that support sustainable rural communities and are linked with service provision. • The distinctive character, sense of place and natural and cultural assets of rural areas are safeguarded and enhanced. The Scottish Government’s LDP Guidance (May 2023) under it’s ‘Step by step guide’ provides advice on relevant evidence for the NPF4 policy topics to help planning authorities in considering the national planning policies when preparing their Evidence Report. With respect to NPF4 Policy 16, the Guidance advises that planning authorities should take into account the MATHLR figure for the area, any identified need for land to ensure the provision of accommodation for Gypsy / Travellers and Travelling Showpeople, annual HLA, and SHIP. With respect to NPF4 Policy 17, the Guidance advises that planning authorities should take into account the MATHLR figure for the area, any identified need for land to ensure the provision of accommodation for Gypsy / Travellers and Travelling Showpeople, annual HLA, an understanding of population change over time, locally specific needs and market circumstances in rural and island area, identification of Remote Rural Areas, SHIP, and local economic strategy. Due to the cross-over with NPF Policy 29 Rural Development, some of the above is discussed in Appendix E4: Rural Development. Links to Evidence: • Housing to 2040 • Perth and Kinross HMP HNDA Final Report • NPF4 Annex E MATHLR • NPF4 Perth and Kinross MATHLR Assessment Report • TAYplan2 Strategic Development Plan Examination Report • Perth and Kinross LHS Framework 2022-27 • Perth and Kinross LHS 2022-2027 Appendix: HST 2022+ • Perth and Kinross LHS 2022-27 Annual Progress Report 2022/23 and 2023/24 • PKC SHIP 2025/26 – 2029/30 • PKC STLs Evidence Research Report • Existing Housing Need in Perth and Kinross – Report commissioned by Homes for Scotland • Extract from the PKC Self and Custom Build Register
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• Perth and Kinross HLA – 2022 and 2023 • Edinburgh City Council HLA and Completions Programme 2022 p.11-13 • Briefing Paper: The Barriers to Housing Delivery • The Scottish Land Commission: The role of land in enabling new housing supply in rural Scotland • Planning and the Housing Emergency – Delivery Plan • Perth and Kinross LDP2 • BPC - Results Summary of Evidence: The key expectation of NPF policies 16 and 17 at Evidence Report stage is the identification of a LHLR and the LDP Guidance specifically requires the Evidence Report to include an indicative LHLR when setting out what the evidence means for the Proposed Plan. To make this section of the Report easier to navigate and avoid repetition, the summaries of evidence below also consider the potential impact of individual pieces of evidence on the setting of the iLHLR. Where the evidence is lengthy or more complex an ‘issues considered’ summary is included. Housing to 2040 Housing to 2040 is the Scottish Government’s first national housing strategy. It was published in 2021 with an ambition to deliver a further 100,000 affordable homes in the period to 2031/32 with at least 70% of these for social rent. Recognising the unique challenges faced by rural island communities, the strategy commits to specific action to support housing development in these areas, helping to stem rural depopulation and supporting communities to thrive. The Strategy aims that everyone has access to a home that is affordable, and people have choices about where they live, no matter what tenure they live in. This includes action to scale up opportunities for self-provided housing, so people have more choices about the kinds of home they want to live in. New building standards will be introduced from 2025/26 to underpin the new Scottish Accessible Homes Standard to future-proof new homes for lifelong accessibility. Action will be taken so that all homes, no matter what their tenure, are required to meet the same standards and the aim is that this will cover all homes new or existing. Potential impact on the iLHLR This is a high level strategy document the implications of which will have influenced the preparation of NPF4. Perth and Kinross Housing Market Partnership Housing Needs and Demand Assessment Issues considered: • Housing market drivers • Estimating future housing need and demand • Specialist provision • Housing stock profile and pressures The starting point for the consideration of housing-related issues for the LDP is the HNDA for the area. HNDAs are designed to give broad, long-run estimates of what future housing need might be, rather than precision estimates. They provide an evidence-base to inform housing policy decisions in the LHS and land allocation decisions in the LDP. The LDP Guidance confirms that where the Scottish Government is satisfied that an HNDA is robust and credible, the approach used will not normally need to be considered further at Gate Check. The Perth and Kinross Housing Partnership HNDA was confirmed as robust and credible on 9 May 2023. The Guidance does, however, go on to state that where stakeholders consider further evidence may be relevant after this date this may be raised in engagement and reflected in the Evidence Report. The HNDA first considers the relevant HMAs for data analysis. The PKC area is divided into six HMAs as shown in the map below. The Greater
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Dundee HMA refers to the small part of the PKC area falling within the wider Greater Dundee HMA which includes Dundee City Council area plus parts of Angus and Fife Council areas. Housing Market Areas in Perth and Kinross There is no longer a requirement for the LHLR in LDPs to make reference to housing market areas, but it is considered relevant to assess whether there are any particularly strong influences on the housing market in Perth and Kinross coming from outwith the area. The HNDA concluded that 63% of property purchasers originate from within Perth and Kinross indicating that the PKC area is a relatively self-contained housing market area. That said, a strong relationship was observed between the Kinross area and Fife Council area with 24% of properties being sold to purchasers from Fife. Also, that migration into parts of Perth and Kinross from the rest of Scotland / UK was over 20%. 1 Note that this includes those who live within Perth and Kinross but work outwith the area. Average incomes for those living and working in Perth and Kinross are below the national average. The HNDA then goes on to consider the core outputs for the analysis of need and demand. These are based on a combination of primary and secondary data sources. Housing Market Drivers (Core output 1) Core output 1 considers the key demographic, affordability and economic factors and how these are driving the Perth and Kinross housing market. Demographic issues: • 12.5% increase in population between 2000 and 2019. Population projections from 2018 predict a marginal decline in population of 1%. Significantly, however, the 75+ cohort is expected to increase significantly over this period by 76%. • 6.1% increase in households between 2008 and 2018 with a further 6-8% increase expected from 2021 to 2043 depending on migration levels. Single person and 2 adult households are expected to increase with declines in all other household groups. Affordability issues: • Average income in Perth and Kinross is higher than the Scottish average1 yet the average house sale value increased by 13% from 2009 to 2019. • 49% of people cannot afford a lower quartile market value property. Economic issues: • Employment rates increased by 16% between 2009 and 2019. Key industries include agriculture, forestry and fishing; professional, scientific and technical sectors; and construction. • More than twice the number of people travel out of the area for work than travel in.
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• In 2020, seven of the Scottish Index of Multiple Deprivation data zones in Perth and Kinross were in the top 15% most deprived data zones in Scotland. Estimating Future Housing Need and Demand (Core Output 2) Core output 2 estimates the number of new homes, disaggregated by tenure, that are likely to be required over the next 20 years to meet local need and demand using the Scottish Government’s HNDA calculation tool. The calculations in the tool are underpinned by an affordability assessment which splits overall housing estimates into the requirement for different housing tenures. Calculation of future housing estimates = existing housing need + new need for housing For the estimate of existing housing need, a local estimate (as opposed to the default estimate in the HNDA tool) was developed informed by housing system evidence held by PKC of households currently in unsuitable housing and who need to move to an alternative property. For this local estimate existing need is that driven by factors including homelessness, insecurity of tenure, overcrowding, concealed households, poor quality housing or a lack of basic amenities, and unmet need for specialist housing. For the purposes of the HNDA calculation it was assumed that the backlog of existing need would be addressed over the first 5-year period of the 20- year projection. Source: HNDA Note: MHP above should read HMP ‘Housing Market Partnership’ For the estimate of new need for housing, this was assessed in the HNDA using the NRS 2018-based Household Principal Projections, and the NRS 2018-based Household High Migration Projections. This resulted in an estimate of 4,060 to 5,131 new households over the 20-year period, or an average of 203 to 257 households per year.
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Source: HNDA The HNDA calculation combines the components of housing need to create a 20-year range of housing estimates depending on whether the principal (main) or high migration population projections are used. The high migration projection is based on the principal projection but with an alternative assumption on migration. For the inputs relating to income growth, income distribution, house prices, affordability, rental threshold, and rental growth, as they relate to the new need for housing, the default assumptions within the toolkit were used. Source: HNDA The housing estimates in each of the Perth and Kinross HMAs across the 20-year period range from: • 714-862 in the Strathearn HMA • 736-887 in the Strathmore and the Glens HMA • 167-206 in the Greater Dundee HMA • 2,956-3,521 in the Greater Perth HMA • 420-503 in the Highland Perthshire HMA • 394-480 in the Kinross HMA The following table sets out the tenure split associated with the principal and high migration scenarios. Tenure Percentage (principle projection) Percentage (high migration projection) Social rent 36 32 Below market housing 13 14 Market rent (private rented sector) 26 27 Market housing 25 27 Total 100 100 Specialist Provision (Core Output 3) Core Output 3 considers the future property requirements in Perth and Kinross associated with specialist housing provision including accessible and adapted housing, wheelchair housing and non-permanent accommodation for key client groups, the future care and support requirements to enable independent living including supported housing for key client groups, and the future site provision to meet the needs of the gypsy / traveller and travelling showpeople communities. The Perth and Kinross Housing Contribution Statement is an integral part of the Perth and Kinross Housing and Social Care Partnership Strategic Commissioning Plan and considers the role of supported housing provision in enabling key client groups to live well in the community they chose. The Statement sets out that housing plays a vital role in providing services and support to intervene early to prevent later, longer term issues arising, and
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in enabling people to be empowered to live independent lives at home or in a homely setting. Specific Housing Contribution Statement actions set out in the Strategic Commissioning Plan include: • Increasing the provision of affordable housing, particularly in areas where shortages have been identified • Identifying and planning for new housing developments for people with specialised support needs There are 1,344 units of specialist housing provided by social landlords in Perth and Kinross: • 63% provide housing for older people including sheltered housing • 29% are accessible houses • 2.5% are fully wheelchair accessible There are 292 temporary accommodation units to meet the needs of homeless households and 45 care homes for adults accommodating 1,336 residents. A research study in 2016 into the accommodation needs of Gypsy / Travellers and Travelling Showpeople in the TAYplan area showed that there were 435 Gypsy / Travellers and Travelling Showpeople in Perth and Kinross in over 185 households. 69% of the population lived in settled housing. There were two Council sites providing a total of 26 pitches. The extent and nature of future provision required across each category of specialist housing identified in the HNDA over the 20 year period to 2041 is summarised below. Accessible, adapted and wheelchair housing: • Up to 3,200 households may require a more accessible form of housing such as accommodation without stairs. • 640 households may require wheelchair housing. • 7,000 households may require adaptations to their current home. Supported housing: • Approximately 1,500 households may require housing for older people. • 3% of the annual homeless population in Perth and Kinross (700) have complex support needs and may benefit from Housing First tenancies. • There is a need for 144 commissioned tenancies/spaces for key care groups with learning disability clients accounting for most anticipated future need. Student accommodation: • A backlog of 50 students have expressed demand for Perth College accommodation. Specialist site: • At 2016 there was projected to be a -2 shortfall to 4 surplus in site pitches over the following 5 years. • The study included a recommendation that the potential for transit site provision be explored further. Plans for a transit site in Perth are currently being progressed. Housing Stock Profile and Pressures (Core Output 4) Core output 4 considers the stock profile, and the key stock condition issues and housing pressures which are influencing the operation of the Perth and Kinross housing system. Much of the data was derived from a primary research survey which was carried out to inform the HNDA. Stock profile: • Tenure – 66% of households own their property, 16% privately rent, and 17% rent social housing • Dwelling type – 76% are houses / bungalows and 21% flats / tenements • Dwelling size – 39% of homes have 1-2 bedrooms and 55% have 3-4 bedrooms • There were 78 registered HMOs in Perth and Kinross in 2020
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Condition: • Across all tenures 2% of dwellings are Below the Tolerable Standard, 27% are in urgent disrepair, and 78% have evidence of disrepair • 8% of properties across all tenures have low energy efficiency ratings which is twice the Scottish average Pressures: • At 2019 3.9% of dwellings were unoccupied (2,849 properties) of which 1.8% had been empty long term • Scottish Government estimates indicate that 2% of households are overcrowded and 1% are concealed whereas the HNDA survey indicated that 2% are sharing amenities with another household and 17% have too few rooms in their current homes • There are approximately 5 applicants for each empty social rented property • Options for future policy around the 1,081 second homes in Perth and Kinross could be considered Potential impact on the iLHLR The HNDA outputs for future housing need and demand are based on the 2018-based principle and high migration population projections. These are still the most recent available projections. Since the HNDA was produced, however, several datasets have been updated. For example, the number of commissioned tenancies / spaces for key care groups has fallen slightly. Plans and strategies too are being reviewed. The Perth and Kinross Housing and Social Care Partnership Strategic Commissioning Plan and Housing Contribution Statement, for example, are both due to be reviewed in 2025/26. Whilst is it difficult to compare directly due to the different timescales, and even though datasets and plans have and will continue to be reviewed and updated since the HNDA was prepared, even the highest end of the 20-year range identified in the HNDA (6,459) is considerably below the 10-year MATHLR set for Perth and Kinross in NPF4 of 8,500 units. National Planning Framework 4 Minimum All-Tenure Housing Land Requirement Issues considered: • Council input to MATHLR calculation • Council evidence submitted to Scottish Government on newly forming households • Council evidence submitted to Scottish Government on the existing housing need • NPF4 Perth and Kinross MATHLR Assessment Report NPF4 sets out the MATHLR for each authority area. The MATHLR is the minimum amount of land, by reference to the number of housing units, that is to be provided by each planning authority for a 10-year period. The MATHLR was calculated by adding the projected increase in households (newly forming households) to existing housing need in each local authority area and then applying a flexibility percentage to allow for changes in sites coming forward. Council input to MATHLR calculation Interim draft MATHLR figures were produced by Scottish Government in February 2021 and planning authorities were given the opportunity to submit comments on these. The draft 10 year figure proposed for Perth and Kinross was 2,650. At the time work was well advanced on the HNDA which meant the Council were able to propose a well-informed locally adjusted estimate MATHLR for Perth and Kinross. The evidence for this adjusted estimate, which was submitted to Scottish Government by the Council, is summarised below. In addition to the two scenarios considered in the HNDA based on the principal and high migration population projections, a further scenario was developed as the HNDA was being prepared which tested the impact of moving beyond the high migration scenario to reflect an ambition for housing-led growth in the area. This assumed 0.5% growth over the NRS
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2018-based principal projection. The table below sets out the three different projections in 5-year bandings. Cumulative housing need: All tenures 2021- 2025 2026- 2030 2031- 2035 2036- 2040 Scenario 1 Principal 2,946 3,786 4,522 5,388 Scenario 2 High Migration 3,125 4,237 5,271 6,459 Scenario 3 Growth 4,743 7,451 9,729 10,595 Source: HNDA table 6.2 – 2021 PKC HNDA calculation scenarios This additional ‘growth scenario’ was not included within the final HNDA given that it was policy-based (assuming an additional 0.5% growth) rather than evidence-based (using published projections). It was, however, discussed with the HMP as set out in the Stakeholder Engagement section below. There was unanimous support from partners for using a growth scenario to inform future housing supply targets and so this informed the Council’s response on the interim draft MATHLR for Perth and Kinross. Council evidence submitted to Scottish Government on newly forming households NRS population and household projections for Perth and Kinross have been projecting a fall in the growth rate. Yet over the same period house completions have been steadily increasing. The birth rate has continued to fall, and we are still to fully understand the impact that Brexit and the pandemic will have on future inward migration, yet there is an inherent difficulty in relying purely on a projection of past trends as these take no account of policy ambition in the area or make any allowance for potential post pandemic changes within society. House completions exceeded 900 several times in the 1990s / 2000s. The financial crisis in the late-2000s obviously impacted significantly on completions post 2008 but they had very nearly reached 900 again in 2020. Despite the restrictions of the Covid pandemic completions were back above 600 by 2021. Based on the house building activity seen during the 2021 survey, future completions are likely to reach approximately 800 per year in the medium term. A housing land requirement figure which is significantly below what has been previously delivered runs the risk of a serious under supply of housing land for the next LDP. With an undersupply comes higher house prices and an increased difficulty for some households to be able to access the type of housing they need. Reduced build rates will also impact on the construction industry and ultimately the ability of the economy to grow in the future. Pre-covid, about 70% of PKC migration came from either Scotland or the rest of the UK with 30% from overseas. The effects of the pandemic are still unclear at PKC area level but there may be potential for an increase on the UK side as the area may become a more realistic option for families, attracted by the quality of life on offer and the flexibility offered by homeworking meaning more people can choose to live in less populated areas. The area is well placed to generate additional growth and jobs. The Council’s Corporate Plan places emphasis on supporting businesses to grow and attract investment and higher value jobs, deliver new investment to the Tay Cities Region, and develop the workforce and retain and attract young people to the area. 45% of the total registered enterprises in 2020 were in Growth sectors and the Tay Cities Deal will invest more than £150m over 15 years in Perth & Kinross. These elements will contribute to at least a modest real growth scenario, possibly even strong growth, and a greater equality of income distribution with more people accessing job opportunities in sectors with higher paid jobs. In-house projections, based on gradual increase to 0.5% growth by 2029 and then onwards to 2037, to derive a locally adjusted estimate is ambitious yet achievable and reflects the growth agenda promoted by the Council. Council evidence submitted to Scottish Government on the existing housing need A revised existing need estimate has been calculated through the HNDA process incorporating results from a telephone and online survey. Homeless households and those in temporary accommodation information
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was taken from HL1 data (the statutory statistical return to the Scottish Government on homeless applications) and data from the survey on households in insecure tenure who were under threat of eviction / repossession. Concealed households and overcrowding information was taken from the survey for households who share rooms with another household or who identified overcrowding as the main reason as wanting or need to move. Specialist housing and housing related services information was taken from waiting list information on households needing to move due to their house being unsuitable to meet specialist needs and newly forming households requiring specialist housing. Poor quality housing information was taken from an in-house all-tenure stock condition survey. Combining these requirements results in a local existing need estimate of 1,369. Housing to 2040 includes a target of 100,000 over the next 10 years. This appears at odds with the initial default estimate proposed for NPF4. For example, assuming 3% of the 100,000 affordable homes target would be allocated to Perth and Kinross based on the share of the national population, the target would be 2,763. This is already higher than the initial default estimate and excludes private tenure development. Furthermore the 2021-26 SHIP projects 1,270 affordable housing completions which is half the initial default estimate but covers only five years. NPF4 Perth and Kinross MATHLR Assessment Report The Scottish Government confirmed that: A) The locally adjusted estimate for Perth and Kinross was primarily driven by the use of alternative in-house household projections. These in-house projections were based on a gradual increase in households to 5% by 2029 and on to 2037. B) A revised existing need estimate had been calculated through the HNDA process. This incorporated results from a telephone and online survey which was confirmed as statistically robust. The HNDA was confirmed as robust and credible by the Centre for Housing Market Analysis on 9 May 2023. As a result of the Council’s input, informed by the HNDA and discussion with the HMP, the final MATHLR in NPF4 was more than three times higher than the initial default estimate – from 2,650 to 8,500. A breakdown of how the 10-year MATHLR calculation for Perth and Kinross evolved is set out in the following table. Component Initial default estimate Locally adjusted estimate MATHLR Existing need 100 1,350 1,350 Households 1,950 5,200 5,200 Flexibility (30%) 600 1,965 1,965 TOTAL 2,650 8,500 8,500 Potential impact on the iLHLR It is expected that the iLHLR will exceed the MATHLR. It must, however, be evidence based. The revised existing need estimate for Perth and Kinross was calculated using a combination of data from the HNDA survey, Scottish Government HL return statistics, waiting list and specialist housing report data, and local estimates of poor-quality housing. As will be discussed below, more recent survey data is presented by Homes for Scotland. This is not, however, considered an appropriate basis for altering the existing need estimate and the reasons for this are also discussed below. Much of the HNDA inputs came from the survey work carried out specifically for the HNDA. Some updates are available, for example, the HL statistics for 2023/24 show that there were 65 households in temporary accommodation which is an increase from the 38 households included in the HNDA. There is not, however, considered to be justification at present for altering the existing need estimate. This will, however, be reassessed in setting the final LHLR in the Proposed Plan. By that time some relevant detailed information may also be available from the 2022 Census.
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Strategic Development Plan TAYplan 2 Examination Report In considering the options for the iLHLR, it is relevant to consider the previous housing land requirement upon which the current LDP2 was based. This was set by the SDP, TAYplan2, which identified an average annual housing land requirement for Perth and Kinross of 1,000 units per year. TAYplan2 is no longer in force yet it is useful to consider the Examination Report in relation to the Reporter’s views on setting a realistic housing land requirement for Perth and Kinross. The requirement of SDPs was to set both a HST and a HLR for each local authority area. The HLR was to reflect the HST plus a flexibility allowance of 10-20%. For Perth and Kinross, however, the proposed SDP set both the HST and the HLR at 1,000. This was because the SDP Authority considered there was no evidence that increasing the HLR above the HST would result in any more houses being delivered. The Reporter concluded that the: ‘…target to build an average of 1,000 homes a year would require more homes to be built annually than has ever been achieved in any year over the period since 2002, and 24% more homes than the average annual figure even for the pre-recession years of 2022 to 2009….It is clear that the authority believes fewer than 1,000 homes will be delivered on average in Perth and Kinross in the Plan period, and the consensus among the housebuilding industry is also that this level of target is challenging. I therefore conclude that the proposed housing supply target [of 1,000 per year] for Perth and Kinross is too high.’ (TAYplan2 Examination Report p.222) The end result of the examination was to instead identify a lower HST with a HLR of 1,000 to allow for flexibility which the Reporter considered ‘…the most pragmatic way to ensure that the plan contains a more realistic housing supply target and housing land requirement for this area….’ (Examination Report p.226). Potential impact on the iLHLR It is acknowledged that the Examination Report for TAYplan 2 dates from 2017 and since then there have been significant changes and challenges faced by the house building industry, not least of which the impacts of the covid-19 pandemic and Brexit. The TAYplan Examination does, however, highlight the importance of setting a realistic HLR. The Homes Topic Paper included as a possible option for the iLHLR using the same 1,000 units per annum requirement as had been set for Perth and Kinross in TAYplan2. There was some support for this option from consultants responding on behalf of a landowner or developer. Homes for Scotland did not comment on this as an option but stressed that they would dispute any attempt by the Council to set an LHLR that does not exceed the MATHLR. Analysis of historic house completion rates before and since TAYplan 2 was approved demonstrates that identifying a land requirement of 1,000 per annum, which at the time was higher than completions that had ever been achieved in any one year, does not automatically result in those higher build rates being achieved. 0 200 400 600 800 1000 1200 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Annual completions over 25-year period Completions MATHLR TAYplan HLR
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Source: Perth and Kinross Housing Land Audits Note: completions from 2010 have not been included as this year only covered a 9-month period due a change in audit date The iLHLR must be evidence based. After carrying out further analysis of the evidence following engagement with stakeholders it is concluded that there is no evidence to support setting an iLHLR in the Evidence Report at 1,000 units per annum to reflect the higher land requirement which was set in the previous SDP for Perth and Kinross. This option has therefore been discounted. Local Housing Strategy 2022-27, Appendix: Housing Supply Target, and Annual Progress Report 2022-23 and 2023-24 Issues considered: • Key issues • Actions • Setting the Housing Supply Target • Progress The LHS sets out the vision of the Council and local partners for the supply of housing across all tenures and types of housing provision. The LHS was approved by Committee on 15 March 2023. The strategy aligns to national housing priorities, maximising investment opportunities, and building on the ambitious economic growth objectives set out in the Tay Cities Deal. The purpose of the LHS includes setting out a shared understanding of need and demand for all types of housing, and for housing services now and in the future, and providing clear strategic direction for housing investment including the development of new homes as well as investment in existing. The LHS is required to identify a HST. LHS priorities are defined as: Priority 1 – Providing more affordable homes to support liveable and sustainable communities Priority 2 – Providing a range of housing options that people can easily access, afford and keep Priority 3 – Delivering housing for people with varying needs Priority 4 – Delivering quality homes with affordable warmth, zero emission, and SMART technology Key Issues Key issues identified through engagement in relation to these priorities include: • Overcome development barriers such as land availability and development constraints which is key to increasing the scale and pace of delivery • Make better use of existing buildings to meet housing need including bringing redundant buildings or low demand housing back into effective use • Provide a wide range of housing options that deliver tenure diversity, including development and growth of the private rented sector through Build to Rent and mid-market rent • Affordability in the private rented sector is problematic and opportunities to deliver quality market and mid-market rent options should be explored • Access to affordable housing options is severely limited in many rural areas of Perth and Kinross • Improve design guides for all housing tenures and all types of housing for varying needs • Ensure sufficient supply of housing options for older people as demographics change and the elderly population grows Actions Actions to address the key issues include: • Maximising the development of social housing through the SHIP delivering a diverse mix of property sizes and more accessible, adaptable homes • Seek opportunities to deliver a wider range of affordable housing options
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• Developing an empty homes strategy which targets areas where housing pressure is evidenced • Maximise the potential to generate more homes through brownfield regeneration • Developing policy through LDP3 where appropriate for STL control areas • Ensure planning policy, placemaking and housing investment programmes contribute to improved and sustainable homes, outdoor space, health and wellbeing for all including people with varying needs • All affordable homes are built to revised Housing for Varying Needs standard and New Build Design Guide, with a minimum of 10% of all affordable homes delivered being built to wheelchair and adaptable standard • Work with Gypsy / Traveller community members to have a better understanding of their accommodation needs and preferences There are 11,557 affordable homes across Perth and Kinross with two thirds provided by the Council and a third provided by RSLs. Around 7% become available for letting each year with roughly five applicants for every tenancy that becomes available. Demand for tenancies is focused on smaller properties (82%) but there are also significant pressures for larger homes with seven applicants for every property with four or more bedrooms. 33% of Council tenants are under-occupying a property by two or more bedrooms so there is a need to address the mismatch in household composition and property size within social housing stock. Setting the Housing Supply Target The HST in the LHS sets out the estimated level of additional housing that can be delivered on the ground. The LHS HST is different to the LDP2 HST, but it will inform the definition of the LHLR within the LDP. In preparing the LHS there has been close partnership working between Council housing and planning officers to ensure that housing delivery and land use principles are informed and well aligned. The detailed calculation of the HST is set out in the Perth and Kinross LHS 2022-2027 Appendix: Housing Supply Targets 2022+. During the life of the LHS a need for 4,743 new homes is estimated across Perth and Kinross with the following approximate tenure split: • 29% market housing • 30% market rent • 25% social rent • 15% below market rent such as shared ownership / equity and mid- market rent Through discussion between PKC’s Housing and Planning Services, and Homes for Scotland it was agreed that in setting the HST for the LHS the most realistic and preferred scenario for Perth and Kinross is one which assumes an element of additional growth over and above that in the high migration projection in the NRS 2018-based Household Projections. The following table summarises the estimated total housing needs over a 20- year period based on this growth scenario. Growth Scenario 2021-25 2026-30 2031-35 2036-40 Social rent 1,881 393 256 107 Below market rent 639 489 309 133 Private rented 1,129 920 673 314 Owner occupation 1,092 906 651 313 Total 4,741 2,708 1,889 867 Average per annum 948 542 378 173 Cumulative 4,741 7,449 9,338 10,205 Source: Perth and Kinross LHS 2022-2027 Appendix: HSTs In setting a HST in their LHS, local authorities must take account of economic and market factors. Influences and challenges include previous levels of affordable housing delivery (see table below) and the availability of resources (see SHIP section below).
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Affordable housing completions 1 April 2016 – 31 March 2022 Financial year Perth and Kinross Council RSL partners Affordable homes completed 2016/17 45 41 86 2017/18 66 168 234 2018/19 93 106 199 2019/20 69 251 320 2020/21 40 84 124 2021/22 179 129 308 Total 492 779 1,271 Source: Perth and Kinross LHS 2022-2027 Appendix: HSTs The market housing element of the HST was taken from the HNDA estimate with a growth scenario applied for years 1-5. The HST therefore includes meeting the demand for market housing in full over the life of the LHS. For affordable housing, adopting a growth scenario results in a need for a total of 2,520 affordable houses over the 5-year period. The supply of land available over that period, however, would only facilitate around 1,000 affordable houses from the application of the Council’s 25% affordable housing policy alone. Even taking into account the potential for buy-backs of ex-local authority houses and bringing empty homes back into use, it was not considered achievable for the Council and it’s RSL partners to deliver the affordable housing element of the growth scenario within the life of the LHS. It was therefore proposed instead to aim to deliver the affordable housing component over the 20-year period of the HNDA. This would mean addressing the backlog of existing need over the full 20 years period rather than in the first 5 years as was assumed in the HNDA. The resulting HST in the LHS is therefore 654 houses per year comprising 210 affordable houses (social and below market rent) and 444 market houses (owner occupied and private rent). Progress Local authorities must review LHS actions annually to evidence progress on how the LHS is implementing its priorities and plans within the five-year period. The report covers the periods 2022-23 and 2023-24 and achievements include: • Delivery of 394 affordable homes including 269 for social rent, 25 for low-cost home ownership, and 100 for mid-market rent • Delivery of 50 Council new build homes, including three wheelchair accessible properties and 11 adapted properties, and 84 buy-backs • Support for minor and major adaptations for local authority and private tenants and homeowners • Delivery of a refurbishment project and two core and cluster supported accommodation projects for individuals with a range of housing and support needs • Securing funding of almost £4m to transform the Council Gypsy / Traveller site with new energy-efficient accommodation and upgrades to create a sustainable environment • Continuing work with the Gypsy / Traveller community to better understand their accommodation needs Potential impact on the iLHLR The LHS assumes the demand for market housing identified in the HNDA will be met in full over the lifetime of the strategy. The availability of funding for affordable housing, however, dictates that this will need to be met over a longer timeframe than that assumed in the HNDA. The resulting HST of 654 per annum is considerably lower than the annualised MATHLR (850). There are several actions set out in the LHS designed to maximise the use of existing housing stock and land resources. It is considered therefore that, rather than indicating a need for a higher iLHLR, currently the LHS highlights a need for a targeted approach to the delivery of affordable housing. The work being undertaken to establish the unmet needs of transient Gypsy / Travellers may, however, affect the setting of the final LHLR in the Proposed Plan.
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Perth and Kinross Strategic Housing Investment Programme Issues considered: • Housing need and demand • Available resources • Affordable housing delivery • Connection with other LHS priorities • Prioritisation framework • Development constraints The latest SHIP covers the five-year period 2025/26 – 2029/30. It has been approved by committee and was submitted to Scottish Government in October 2024. The SHIP is designed as a working tool which, among other things, improves longer term strategic planning, details how investment in affordable housing will be directed, sets out key investment priorities and demonstrates how these will be delivered, and informs the allocation of resources from a national to local authority level. As well as supporting the LHS priorities, the SHIP also aligns with the aims of the Perth and Kinross Strategic Commissioning Plan and Housing Contribution Statement. Housing need and demand The LHS has set a target of 210 new supply affordable homes per year. This is across a range of delivery types including new build, buybacks, conversions, and empty homes, by both Council and RSL partners with a mix of social rent and other tenures such as shared equity and mid-market rent. Available resources Funding resources to support the delivery of SHIP priorities include: • Affordable Housing Supply Programme • Housing Revenue account and Prudential borrowing • Developer contributions – currently £1.5m available • Council tax reserve income from the reduction of discount for empty and second homes including the 100% council tax surcharge on second homes from 1 April 2024 • Housing Infrastructure Fund which funds stalled housing development due to excessive cost or nature of the infrastructure works required • Vacant and Derelict Land Investment Programme – whilst there are currently no housing sites in the SHIP with this funding attached, the Council have agreed that priority for affordable housing would be given when disposing of surplus land or buildings • Rural Housing Fund – the Council is exploring sites and partnerships with bodies who are eligible to apply • Affordable Rural Homes for Key Workers Fund which enables local authorities to purchase existing suitable properties in rural areas which can be rented directly or leased to employers Affordable housing delivery The programme is based on operating at 139% of the current Resource Planning Assumption in order to effectively manage slippage and respond to funding increases. Financial Year Starts (including buybacks) Completions (including buybacks) 24/25 177 223 SHIP period 25/26 – 29/30 25/26 341 159 26/27 224 265 27/28 212 259 28/29 174 269 29/30 209 200 Total 1,160 1,152 Yearly average 232 230 Source: SHIP
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Connection with other LHS priorities The following are of particular relevance to this topic: Empty homes – the Council’s aim is to bring 135 privately owned properties back into use each year. The Private Sector Housing Team works in tandem with the Housing Options Team to ensure empty homes are targeted in appropriate areas and to those in housing need. Gypsy Travellers – there are two permanent sites operated by the Council at Double Dykes and Bobbin Mill providing 26 units of chalet-style accommodation. There are no temporary or short stay pitches on these sites and occupancy rates are typically at 100%. There are a further 24 pitches across three private sites. A major capital project at the Double Dykes site is underway to replace the 20 chalets with high quality energy efficient accommodation. Feasibility studies are planned for the Bobbin Mill site to establish what improvements can be made and significant progress is being made to develop at transient site in Perth city. Accessible homes / supported housing – the LHS includes a target that 10% of new build affordable homes will be wheelchair accessible or adaptable but there is no mechanism to enforce a similar requirement in private sector housing. Over the 5 year course of the SHIP 104 fully wheelchair adapted properties will be funded. Rural and community led housing – the LHS sets out the aim that the urban / rural population split (53/47%) should be reflected in new affordable housing delivery. This SHIP will fund 398 new affordable homes in rural areas (61%) and 625 in urban areas (39%), but these projections do not include buybacks or new delivery supported via the Rural Housing Fund. In addition to the SHIP, the Council’s Housing Strategy Team work with communities to enable Community Led Housing. The Council are also working to deliver a ‘key worker policy’ which will include an updated definition of key worker priority groups as part of ongoing work to seek to address the shortfall of suitable housing in some rural areas for key workers. City / Town centre living – Perth and Kinross has a substantial urban population and a focus of town centre living can boost the local economy and community vibrancy. In this SHIP 104 of the new affordable homes are projected to be in or very near city and town centre boundaries. Prioritisation Framework This assesses proposals based on the Council’s strategic aims, priorities, and project deliverability. Investment decisions are balanced through a mix of Council, RSL and developer delivery, considering various affordable housing tenures to meet housing need across all the HMAs. A renewed focus on deliverability has resulted in some less deliverable sites in the previous SHIP moved to the ‘pipeline’ list, with more deliverable projects introduced. SHIP 2024/25 – 2028-29 Year Expected total site starts Expected total completions 24/25 713 516 25/26 369 471 26/27 246 285 27/28 163 239 28/29 197 150 5-year period 1,688 1,661 Development Constraints There are several challenges that can affect development including market volatility in the construction sector impacting on private sector delivery timescales, increased energy prices, high material prices and shortages, shortages of labour, economic uncertainty and inflation. Whilst these issues need careful management, they also present opportunities for affordable housing providers. Off-the-shelf opportunities with private developers are explored to increase affordable housing supply.
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Potential impact on the iLHLR The SHIP sets out how investment in affordable housing will be directed and how the LHS target for new supply affordable homes per year will be met. It focuses on implementation rather than the setting of the iLHLR. Perth and Kinross Council Short Term Lets Evidence Research Report Detailed research was commissioned by the Council on housing affordability and an analysis of housing system pressures specifically to inform policy considerations in relation to STLs but some of the findings are also relevant to the wider homes issue. The outcomes of housing affordability modelling across Perth and Kinross show that: Source: PKC STLs Evidence Research Report – note that £274,907 is the average PKC house price Pressures Housing tenure and dwelling pressures – the tenure profile in Perth and Kinross is dominated by home ownership accounting for 62% of dwellings. 17% are social tenancies and 14% are in the private rented sector. Ineffective housing stock pressures – across Perth and Kinross 8% of the housing stock is ineffective (2% second homes, 2% STLs and 4% empty homes). This varies significantly, however, in different parts of the Council area with as much as 24% of stock ineffective in the Highland Perthshire HMA.
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New supply pressures – just over half the housing land supply is concentrated in the Greater Perth HMA with only 5% of the supply in the Highland Perthshire HMA. The majority of affordable housing projects (59%) are also located in Greater Perth. Household income pressures – average annual incomes across Perth and Kinross are higher than the national average but this overall figure hides the considerable variations which exist across different HMAs. Housing market pressures – across Perth and Kinross there has been an average turnover of 7% with 59% of sales made to local households and 41% to households from outwith PKC. This varies significantly, however, in different HMAs with the highest levels of in migration in the Kinross and Highland HMAs. Average house prices also vary considerably. Housing affordability pressures – average house price to income ratio varies significantly across the area from 5.84 in the Strathmore HMA to 10.49 in the Kinross HMA. Private rented sector pressures – the private rented sector can frequently be the default tenure for households who can’t afford home ownership but can’t access social housing. The majority of private rents are in the Greater Perth HMA at 60% with only 4% in the Kinross HMA. Social housing pressures – the availability of social housing varies considerably across the Council area with 64% in the Greater Perth HMA to only 4% in the Kinross HMA. Demand is, however, also highest in Greater Perth and lowest in the Kinross HMAs. Potential impact on the iLHLR A key element of this research is to highlight the variations that exist between the different HMAs across Perth and Kinross in relation to the access to and affordability of housing. The research highlights a number of issues including: • the existing stock is dominated by home ownership, • there is a concentration of land supply, affordable housing projects, and private and social rents in the Greater Perth HMA with significantly lower levels in some other HMAs, and • there are considerable variations in household income, average house prices, house price to income ratio, and levels of migration across the area. Some of these issues, such as the distribution of the housing land supply, can be considered in identifying the spatial strategy for LDP3. Overall, however, as highlighted above in relation to the LHS, these housing system pressures are more appropriately tackled by targeting the delivery of affordable housing rather than simply increasing total land supply in the iLHLR. In relation to ineffective stock, the latest Scottish Government statistics on empty homes (Dec 2023) indicates that since 2021 the number of second homes in Perth and Kinross has remained relatively static at around 1,200. Until recently there were no specific means available to the Council for controlling the number of second homes in the area. The introduction from 1 April 2024 of an increase in Council tax charge to 200% levied on second homes in Perth and Kinross, however, may result in the number of second homes reducing and either being sold or moving to short-term letting. Conversely, the new STL licencing requirements may result in a move from STLs to second homes. So, whilst there is not currently considered evidence in relation to ineffective stock which would justify making an allowance for this within the iLHLR, more data on the impact of the increase in the Council tax charge and the STL licencing requirements will be available to inform the setting of the final LHLR in the Proposed Plan.
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Existing Housing Need in Perth and Kinross – Report commissioned by Homes for Scotland Homes for Scotland commissioned a primary research-led approach to understanding housing need across the whole of Scotland. A report has also been published for the Perth and Kinross area specifically. The research only considered existing need and not future need. Homes for Scotland is concerned that the Scottish Government estimates of existing housing need included within the MATHLR calculations are based on counts of homeless people in temporary accommodation and of households that are both overcrowded and concealed. This is considered too strict a definition of need as it only takes account of those households with a particularly pressing need. Homes for Scotland argue that this tight definition overlooks those households whose need may not be pressing, but which should still be considered in the planning and housing processes. The inclusion of primary data from a survey allows for wider definitions of need and demand to be incorporated. Homes for Scotland is also concerned that the extensive and costly traditional means of collecting primary data for HNDAs means that the fuller approach to data collection is now quite rare. Through the research Homes for Scotland sought to undertake shorter surveys of housing need and demand and to assess the calculations in a straightforward, robust and efficient way, allowing for the production of more accurate and meaningful local assessments (report p.7) The research surveyed households using an online panel (Scotpulse). The panel has a membership of over 47,000 adults in Scotland meaning it can produce reliable and robust estimates at national and, in most cases, at local / regional levels. For the Perth and Kinross report 482 households were surveyed and extrapolating these results to c.71,000 households in Perth and Kinross the following conclusions were drawn: • 12,000 households have at least one concealed household • 6,000 households are living in properties that they were struggling to afford • 3,000 households in the area are overcrowded • 2,000 households were living in properties with very poor conditions • 1,000 households are living in properties where they do not have the specialised adaptations or support they require The research acknowledges that meeting these needs will not all require the provision of additional houses. Some needs can be met by in-situ solutions e.g. the provision of adaptations, or by the freeing up for another household a property of an unsuitable size e.g. an overcrowded household moving to a larger house would free up that property for a smaller household. Potential impact on the iLHLR A key concern identified in this research is that some HNDAs are being carried out based only on secondary data. That is not the case in in Perth and Kinross. The primary research included in the HNDA helped inform the Council’s input to the identification of the MATHLR for the area in NPF4. The Homes for Scotland research is, however, more up to date (August 2023 whereas the HNDA survey was carried out in March / April 2021) and so it is relevant to review the data inputs to this research. Whilst the HNDA was based on both a telephone survey and an online survey (415 responses in total), the Homes for Scotland survey was online only. The latter did, however, have a larger number of responses (482). Both surveys are confirmed as statistically robust. A significant difference was in the length of the survey – 33 questions for the online HNDA survey and 44 questions for the telephone survey, compared to 16 questions for the Homes for Scotland online survey. Direct comparison of the results of the HNDA with the Homes for Scotland research is not possible due to the differences in the way in which survey questions were framed. A very general comparison of the results as they relate to the different categories of need, however, reveals the following.
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Issue HNDA Homes for Scotland research Concealed and overcrowded households 403 concealed and overcrowded households which is derived from those identifying themselves in the survey as overcrowded or sharing amenities with another household with double counting eliminated Survey identified 12,000 households with at least one concealed household, and 3,000 households that are overcrowded Poor quality housing 350 households in housing identified as Below Tolerable Standard using local house condition survey outcomes Survey identified 2,000 households living in properties with very poor conditions Specialist housing 154 households who need to move due to medical needs or who require specialist housing applications as a measure of housing waiting lists Survey identifies 1,000 households living in properties where they do not have the specialised adaptations or support they require Affordability No comparable measure in the survey although the research carried out to inform policy considerations on STLs found that 51% of households can’t afford market entry level prices, and 10% are unable to afford even the lowest social housing rents Survey identifies 6,000 households living in properties they are struggling to afford Homeless households 421 homeless households and those with insecure tenure using HL1 statistics and the HNDA survey 100 households that are homeless or in temporary accommodation sourced from the Scottish Government, Homelessness in Scotland, 2022-23 Total existing need 1,328 21,100 gross but when in-situ solutions and the ability of households to afford to buy out of need are taken into account the gross figure reduces to c.12,200 households in net housing need who require an affordable housing solution plus a further 6,600 households in need and who could afford a market solution Homes for Scotland acknowledge that their research does not constitute a full HNDA but considers that it provides ‘a robust assessment of actual need based on primary research of households in Perth and Kinross that is up to date’. It is suggested that the figures provided in the research can be used in conjunction with other data sources as part of the HNDA process. The research identifies considerably higher levels of housing need than that in the HNDA or that could be accommodated within the MATHLR. The HNDA was carried out using the Scottish Government’s HNDA tool and incorporated both primary research and secondary data sources. The HNDA was confirmed as robust and credible. The research prepared for
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Homes for Scotland was not considered in partnership with the Council or with other housing partners. It is noted, however, from Homes for Scotland’s response to the Homes Topic Paper, that this research is to be discussed at Scottish Government level. If the conclusion of those discussions is that the methodology used in this research, or elements of it, are to be preferred nationally over those derived through the HNDA process, then they can be used to inform the setting of the final LHLR in the Proposed Plan. Until then it is considered that the results of the HNDA, together with the evidence the Council provided in relation to establishing the MATHLR, are preferred in informing the iLHLR. Perth and Kinross Self and Custom Build Housing A specific requirement of the Act is consideration of persons seeking to acquire land for self-build housing. A self and custom build register has been set up for Perth and Kinross on the Council’s website and is gathering interest even although there has been little done so far in the way of promotion. To date 26 people have registered their interest and of these, 12 have indicated that they would intend to start to build within one year. A total of 22 respondents confirmed that they have the finance in place to build. It was suggested through the Topic Paper engagement that the company ‘Buildstore’ also maintain a register of people who have expressed an interest in acquiring land for self or custom build. Buildstore is a private company established in 1998 which provides support and services for individual homebuilders. Buildstore have provided the Council with the overall number of expressions of interest for land for self or custom build for those postcode areas which are either wholly or partly within Perth and Kinross. At the end Sept 2024 there were nearly 550 expressions of interest in postcode areas which are wholly within Perth and Kinross – PH1, PH3, PH5, PH7, PH8 and PH9. Around a further 380 people had expressed interest in postcodes areas which are partially within Perth and Kinross. More detailed analysis is required to accurately quantify this demand, but if it is assumed that 50% of these were for areas within Perth and Kinross this would result in a total of around 740 people who have so far expressed an interest in acquiring land for self or custom building in Perth and Kinross. Postcode Total demand Wholly within PKC Partly within PKC PH2 227 227 PH1 324 324 KY6 23 23 PH7 79 79 PH6 26 26 PH3 116 116 KY4 21 21 DD8 20 20 PH9 4 4 KY5 20 20 DD2 28 28 PH4 13 13 PH5 12 12 PH8 10 10 Total 1190 545 378 Source: Buildstore Land Database As part of the housing land audit, completions on small sites (of less than 5 units) are recorded. It is considered reasonable to assume that a significant proportion of these small sites are likely to be some form of self or custom build e.g. houses in the countryside. The first Perth and Kinross LDP was adopted in February 2014 so looking at the data from the 2015 onwards there were 942 houses built on small sites, an average of 105 per year.
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Potential impact on the iLHLR In preparing the LDP, section 16(2) of the Act requires the planning authority to have regard to the list published under section 16E of persons seeking to acquire land in the authority’s area for self-build housing. This could mean having a local level policy in LDP3 to support self-build proposals and this is considered further in the Summary of Implications for the Proposed Plan section below. Alternatively, or additionally, this could mean allocating sites within the LDP specifically for self-build or to include a proportion of self-build as a developer requirement on specific sites. In the past the LDP has tended not to allocate sites of less than 10 houses. Instead, small sites have been facilitated though the Housing in the Countryside policy and by allowing scope within settlement boundaries where appropriate. No decision has been made as yet, however, as to the scale of sites which will be allocated in LDP3. The other option would be to make some provision for self-build within the iLHLR. The HNDA toolkit takes into account a considerable number of variables in determining the HNDA outputs. No specific reference is made, however, to the demand / need for land for self-build. This could be because the requirement on local authorities to maintain a register is relatively new in Scotland, or because self-build has by default been included within a small sites contribution which some authorities have incorporated into their housing land requirement. It could therefore be appropriate to make an allowance for self and custom build houses in setting the iLHLR and this is considered further in the Summary of Implications for the Proposed Plan section below. Perth and Kinross Housing Land Audits Issues considered: • Past performance • Future housing land supply o Longer-term strategic sites o Non-constrained sites which remain undeveloped o Constrained sites • Deliverability of the land supply Local authorities are no longer required to refer to HMAs. That is not to say that the authority cannot still choose to use HMAs as the basis for considering housing land supply. Given that the existing HLAs give data at Perth and Kinross and HMA level, this has been continued in the analysis of audit data below. Past performance The main source of information on housing completions comes from the annual HLA. The most recent published housing land audit for Perth and Kinross reflects the position on 31 March 2023. The chart below shows past completion rates on all sites over the two periods for LDP1 and LDP2. The overall trend line shows a steady increase in completions over the two Plan periods.
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Source: Perth and Kinross HLAs The annual HLA records those completions which have occurred on sites of less than 5 units. As shown in the table below, small sites have historically contributed varying proportions to total completions but have been particularly significant in the Highland and Greater Dundee HMAs. HMA 2015-2023 Total small sites Average Small sites as % of all completions 2015-2023 Perth 313 35 10 Greater Dundee 34 8 63 Highland 179 20 53 Kinross 144 16 18 Strathearn 153 17 15 Strathmore 119 13 19 Perth and Kinross 942 105 15 Source: Perth and Kinross HLAs As well as completions on small sites, the annual housing land audit records those completions which have occurred on ‘windfall’ sites. These are defined in the LDP as sites which become available for development unexpectedly and are therefore not included as allocated land in the LDP. The calculation of the housing land requirement for LDP2 assumed that 10% would be met on windfall sites. An assessment of historic completions on windfall sites has been undertaken, again covering the two LDP periods. This is important as it is generally the case that the level of windfall opportunities increase the further it gets from the Plan adoption date. The assessment showed that on average completions on windfall sites constituted 30% of all completions on sites of 5 or more. As assessment of the tenure split between local authority, RSL, and private sector completions on sites of five or more houses during the two Plan periods shows that the tenure split between affordable and market housing across Perth and Kinross is 30% / 70% although this varies in the different HMAs. For this calculation local authority and RSL completions have been classed as affordable and private sector completions as market sector although there may be an element of affordable provision within the private sector, for example, discounted for sale. HMA 2015-2023 split Affordable / Market Perth 35% / 65% Greater Dundee 0% / 100% Highland 28% / 72% Kinross 18% / 82% Strathearn 24% / 76% Strathmore 32% / 68% Perth and Kinross 30% / 70% Source: Perth and Kinross HLAs 0 100 200 300 400 500 600 700 800 900 1000 2015 2016 2017 2018 2019 2020 2021 2022 2023 Annual completions over LDP1 and LDP2
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Future housing land supply The Act requires planning authorities to set out their views on the availability of land for housing, including for older people and disabled people. At March 2023 there was a total non-constrained (previously referred to as ‘effective’) land supply of 17,411 units. Homes for Scotland disputed the effectiveness of 489 units leaving an agreed land supply of 16,922 units. There are no sites allocated specifically for housing for older people or disabled people in LDP2. The map below shows the distribution of the remaining housing land supply where 50+ houses are still to be built (2023 Housing Land Audit).
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As shown in the map above, by far the largest proportion of the land supply is in and around Perth (71%). Smaller proportions are in the Strathmore area primarily at Blairgowrie (13%) and the Strathearn area split between Crieff and Auchterarder (9%). The least supply is in the Highland Perthshire area at Aberfeldy and Pitlochry (4%) and in Kinross- shire (3%). Less than 1% of the supply is within the Greater Dundee area but, as abovementioned, this is only a small part of a much larger cross- boundary HMA. Longer-term strategic sites – 65% of the remaining land supply at March 2023 was on eight strategic scale sites. Three in Perth City, three in the Greater Perth HMA (at Bridge of Earn, Luncarty and Scone), one at Blairgowrie, and one at Crieff. All of these sites are currently programmed to extend beyond the year 3035. Of the eight sites, three are currently under construction. Of the five sites yet to start, three are programmed to begin construction in the short term, one in the medium term, and one in the long term. Site Timescale Perth City (Perth West) Medium term Perth City (Berthapark) Under construction Perth City (Almond Valley) Short term Bridge of Earn Short term Luncarty Short term Scone Under construction Blairgowrie Long term Crieff Under construction Source: 2023 HLA Non-constrained sites which remain undeveloped – There are 153 sites in the 2023 HLA. 33 of these sites (totalling nearly 6,800 units) are allocated in the LDP but do not yet have planning permission. LDP2 was adopted in 2019. This is a considerable proportion of allocated sites which, at March 2023, had not yet progressed to planning application stage. Furthermore, a number of these sites were carried forward from LDP1. In some cases, there may be legitimate reasons for the delay in bringing a site forward but there is concern that in some instances sites are simply being land-banked for a future date. This is a particular problem in areas where the land supply is under the control of a small number of housebuilders who may also have development interests elsewhere in the Council area. The willingness of individual house builders to deliver on their existing supply of allocated sites is an important factor. Constrained sites – Of the 153 sites in the 2023 HLA 16 of these (totalling around 350 units) have some form of constraint which is currently preventing development from taking place. The number of units by type of constraint is shown in the chart below. Although land use constraint accounts for more than half of constrained units this is due to the inclusion of two larger sites within this category both of which are in the Perth HMA. Source: Perth and Kinross Housing Land Audits 12% 11% 3% 5%2% 55% 12% FACTORS CONSTRAINING LAND SUPPLY Marketability Ownership Infrastructure Physical Programming Land use Multiple
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As abovementioned, a further four sites (totalling nearly 490 units) are considered constrained and are disputed in the 2023 Audit by Homes for Scotland. Two are disputed on marketability grounds, one on land use, and one on programming. Deliverability of the land supply There is a greatly enhanced emphasis in NPF4 on deliverability. As such LDPs are to consider de-allocation where sites are no longer deliverable. Previous HLAs have included an assessment of the land supply against the housing land requirement set by TAYplan by providing an update to LDP Table 1: Housing Land Requirements and supply by Housing Market Area. The most recent update was included in the 2022 HLA. Housing Market Area Greater Dundee Strathmore and Glens Highland Perthshire Kinross Strathearn Greater Perth PKC total HLR 2016- 2029 78 1,859 995 983 1,846 7,239 13,000 Completions to 2022 40 438 245 576 645 2,163 4,107 Effective supply 2022-2029 60 886 405 486 802 3,332 5,971 Windfall assumption 0 100 60 59 99 378 696 Small site allowance (Highland) 89 89 Surplus / shortfall 22 -435 -196 138 -300 -1,366 -2,137 Source: 2022 HLA The commentary in the 2022 HLA identified shortfalls in housing land supply in four of the six HMAs across Perth and Kinross but notes that ‘ultimately the issue is not one of land allocation but in the delivery of the land in the short-medium term’. At 2022 the agreed non-constrained effective land supply stood at 18,292 units. By the 2023 HLA TAYplan2 was no longer in force. For the 2023 audit, factors which are currently affecting site delivery were apportioned to those sites under discussion with Homes for Scotland (approximately 25% of all sites). This was based on the approach which has been used by Edinburgh City Council for a number of years. Factors relate to the ownership or control of a site, the planning system, or to the development industry. For nearly half the sites considered the key factor affecting delivery was identified as the need to align ownership with the intention to develop i.e. the site is allocated for housing but it has not been progressed by the owner. These sites are not in the hands of a house builder and in some cases the owner has indicated that they do not intend to market the site at present. For most of the other sites the delivery factors identified were associated with the development industry either: • the site is under construction and the rate of delivery is determined by market demand, • the site is in the control of a developer with all consents in place, but development has yet to start, or • planning consent is in place, but the consent was obtained by the landowner or development company rather than a housing developer. The intention is to extend this assessment of factors affecting site delivery to all sites for subsequent HLAs and to discuss these with Homes for Scotland as part of the annual HLA engagement process. It is recognised, however, that whilst market factors will play a significant role in assessing
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the continued deliverability of housing sites, other elements of the NPF4 strategy must also be taken into account. NPF4 policies on tackling the climate and nature crises, climate mitigation and adaptation, sustainable transport, local living, and infrastructure first are just a few of the factors which could also affect the deliverability of land for new housing. Potential impact on the iLHLR Analysis of past completion rates as an indicator of future delivery must be treated with a degree of caution as house completions are so heavily dependent on peaks and troughs in the market. The key point to note from historic completions data is that over the period since the adoption of LDP1, only twice have the total completions exceeded the annualised MATHLR of 850. Average completions over the period were just under 680. There is not therefore considered to be evidence for making an allowance based on historic completion rates within the iLHLR. The existing land supply is concentrated in the Greater Perth HMA in line with the previous strategic development plan spatial strategy. There are several issues which will need to be considered in the identifying of the spatial strategy for LDP3. These are considered in the Summary of Implications for the Proposed Plan section below but could potentially include some redistribution of the housing land supply. There is no longer a requirement for the LHLR within LDPs to refer to HMAs so even if some redistributions were required this would not result in a need to make an allowance for it within the iLHLR. Any change to the scale of sites allocated in LDP3 to meet the LHLR, for example, a move away from large scale strategic sites to a larger number of smaller sites, could potentially result in a higher number of allocations given that a large proportion of the existing land supply is concentrated on a small number of strategic sites. It is not possible to determine the impact of such a change to the spatial strategy on the LHLR, however, until the spatial strategy for LDP3 has been identified in the Proposed Plan. Any impact of a change to the spatial strategy in terms of site size will therefore be considered in setting the final LHLR at Proposed Plan stage. In relation to the deliverability of the existing land supply on setting the iLHLR, much of the current land supply is longer term and there have been shortfalls in short-term land supply identified in previous housing land audits. The new planning system requires a full review of all allocated sites for the next LDP, and it is possible that this could highlight some sites which should be de-allocated if they have little or no prospect of delivery within the plan period. If this is the case, then alternative deliverable sites will be identified in LDP3. There is not therefore considered a need to include within the iLHLR an allowance for current allocated sites failing to come forward. Furthermore, the MATHLR already includes a 30% flexibility allowance designed to help compensate for this eventuality. Homes for Scotland Briefing Paper: The Barriers to Housing Delivery Homes for Scotland identify the barriers to housing delivery as including: • Net-zero transition including supply chain and grid capacity. • Infrastructure funding and delivery causing significant impact on development viability. • Access to labour and skills impacting build programmes, costs and introduction of new technologies and practices. • Planning and consents including low minimum housing targets, and a lack of deliverable available land. • Market conditions including consumer confidence, mortgage constraints, cost inflation, and the attractiveness of Scotland as a place to invest. • Regulatory impact making it easier to build elsewhere. • Unintended consequences of unevidenced policy making increases risk and uncertainty and impacts decision making.
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• SMEs are struggling including difficulties accessing development finance – such enterprises are vital to the rural housing supply but the existence of many are under threat. Potential impact on the iLHLR This research for Homes for Scotland highlights barriers to the delivery of housing in Scotland. It is clear from the variety, scale and significance of the barriers set out in the research that these will not be solved by simply increasing the supply of land. Issues such as supply chain constraints to achieving a transition to net zero, infrastructure funding and delivery, access to labour and skills, mortgage constraints, and cost inflation all impact on the ability of the house building sector to deliver. The existence of these barriers do not therefore in themselves justify making an additional allowance within the iLHLR. The Role of Land in Enabling New Housing Supply in Rural Scotland This report by Savills for the Scottish Land Commission in 2019/20 to consider the extent to which land, specifically the cost of land and access to land, is a barrier to new housing delivery in rural and remote rural Scotland finds: • Landowners and land price – lack of land transaction data makes it harder for landowners to establish whether the price they have been offered is best value and can lead to unrealistic expectations. • Market failure in rural areas – the model of speculative housebuilding that delivers the vast majority of new homes does not work across the majority of rural Scotland as there is often not sufficient depth of demand or value to generate adequate levels of profit to sustain their business models. This does, however, perhaps create an opportunity for smaller custom build contractors in partnership with landowners and the not-for-profit sectors to manage risk. • Cost of development in rural Scotland – the more remote the market the more expensive it is to build and house and the less affordable it is for many people living and working in rural communities. • The role of not-for-profit organisations – generally target housing need rather than market demand. The price of land is often heavily influenced by the grant funding available. • Site effectiveness / deliverability – can be very difficult to get the economics of a project to stack up where land is expensive to service or unlock. Many sites in LDPs are zoned without first understanding if that land is deliverable. • The role of the community sector – many community groups and development companies lack the time, resources, and skill set to progress what are often challenging projects to unlock. • The role of grant regimes – the lack of long-term clarity and stability in the grant funding regimes is debilitating for the housing sector in rural Scotland. • The role of the planning system – early forms of rural planning was driven by a need to protect the countryside from urbanisation, and this has perhaps created an overly protective and relatively static approach to planning for rural areas across much of Scotland. A general lack of land being made available restricts supply and can increase house prices and thus land prices. Potential impact on the iLHLR As with the Homes for Scotland research above, this report highlights barriers to the delivery of housing but concentrates on those which relate specifically to rural and remote rural Scotland. As above, whilst these impact on the ability of the house building sector to deliver, they will not be solved by simply increasing the supply of land. The existence of these barriers do not therefore in themselves justify making an additional allowance within the iLHLR.
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Planning and the Housing Emergency – Delivery Plan Published in November 2024, the Delivery Plan sets out the Scottish Government’s approach to addressing the national housing emergency. Key objectives and actions are identified including: • Identify mechanisms to stimulate the build-out of housing sites with planning permission at a faster pace – for several years build- out rates have been significantly lower than permissions. • Work with SME householders to better understand the challenges they face. • Help planning authorities to bring forward new style development plans including a pipeline of deliverable housing land and delivery programmes – new guidance to be published on HLAs to enable consistency in approach. Potential impact on the iLHLR High level document focusing on delivery rather than the setting of the iLHLR. Big Place Conversation The housing and community indicator for the BPC Place Standard consultation asked participants whether the homes in their area supported the needs of their community. In some parts of Perth and Kinross housing needs were being met with a strong sense of community, good housing mix and, evidence of community development work supporting housing needs. In other areas, however, the following issues were highlighted: • Limited or no affordable housing in some more rural areas • A significant lack of housing in some rural communities • Housing shortages impacting on other parts of the community, for example in attracting and retaining workers • Short term lets and holiday / second homes reducing housing availability and affecting house prices • Few opportunities for smaller and lower income households • People move outwith the area because of housing shortages • Impact of new housing developments on infrastructure and the character of local areas • A lack of temporary supporting / independent housing • Older housing stock across the area requires significant maintenance / energy retrofit • Fuel poverty • Historic land allocations need to be reviewed To address some of these issues the following suggestions were made: • More affordable / social housing needed (including rentals) to meet different needs e.g. families, young people, key workers • Integrate affordable / social housing into new developments • Provide smaller housing units for downsizing / independent living • Protect housing for local people / workers • Improve infrastructure as part of new housing developments • Restrict short term lets and second / holiday homes • Find a balance between providing new housing and protecting the character of existing areas • Prioritise brownfield development • Re-use and repurpose existing buildings to create housing • Provide more support / funding for those living in older properties • Communities should determine housing priorities, not developers • Micro-homes could help deal with homelessness • Promote self-build housing Potential impact on the iLHLR Discussion on the place standard housing and community indicator highlighted several issues of concern and suggestions as to how these
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could potentially be addressed. The need for more housing to meet a wide range of needs is already taken into account above in relation to the HNDA, LHS, SHIP and STL research. Issues are also considered in other sections of the Evidence Report such as Rural Development, Tourism and, Brownfield, vacant and derelict land. The issues raised through the BPC are not therefore considered in themselves to justify making an additional allowance within the iLHLR. Summary of Implications for the Proposed Plan: Issues considered: • An indicative Local Housing Land Requirement for Perth and Kinross • Meeting the Local Housing Land Requirement o Windfall and brownfield sites o Small sites o Reallocation of requirements between HMAs o Review of existing LDP allocations o Allocation of new sites • Proposed Plan spatial strategy • Proposed Plan policy framework • LDP Delivery Programme • Gaps or uncertainties in data The key expectation of NPF policies 16 and 17 at Evidence Report stage is the identification of a LHLR. The LDP Guidance specifically requires the Evidence Report to include an indicative LHLR when setting out what the evidence means for the Proposed Plan and to provide a transparent and understandable explanation of how the iLHLR has been arrived at. Thereafter the Proposed Plan will need to consider how to meet the LHLR, 2 Note that windfall is seen as a potential contributor to meeting the LHLR rather than influencing the setting of the iLHLR. set out a spatial strategy and policy framework to support the delivery of the LHLR, and monitor progress in the delivery of the LHLR through the LDP Delivery Programme. An Indicative Local Housing Land Requirement for Perth and Kinross In identifying the iLHLR the planning authority are expected to take into account the housing needs of the population in particular the needs of older people, disabled people, and people in higher and further education, and the availability of land for housing, including for older people and disabled people as required by Section 5(5) of the Act. Consideration should also be given to the MATHLR, the HNDA, HLAs, the demand for self- build, the contribution from windfall development2, the LHS and SHIP, and the impact of ineffective housing stock. The table below brings together the potential impact of the evidence considered in the preceding section on the setting of an iLHLR for Perth and Kinross.
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Source Considers How evidence has informed the iLHLR Housing to 2040 The national housing strategy for Scotland High level strategy document the implications of which will have influenced the preparation of NPF4 – no change Perth and Kinross HMP HNDA The housing needs of the population including the needs of older people, disabled people, and people in higher and further education Even the highest end of the 20-year range identified in the HNDA is considerably below the 10-year MATHLR in the NPF4 – no change NPF MATHLR A locally adjusted estimate of newly forming households using in-house household projections, and a locally adjusted estimate of existing need PKC evidence informed the MATHLR and, whilst some updates are available, there is not considered to be justification at present for altering the existing or new housing need estimates – no change SDP TAYplan2 Examination Report The previous HLR set for Perth and Kinross No evidence to support setting an iLHLR to reflect the land requirement which was set in the previous SDP – no change LHS and associated documents Information relating to different tenures of affordable and market housing including housing for older people and disabled people, and ineffective stock Rather than indicating a need for a higher iLHLR the LHS highlights a need for a targeted approach to the delivery of affordable housing – no change SHIP The availability of land for affordable housing and information on local authority housing investment priorities The SHIP focuses on implementation rather than the setting of the iLHLR – no change Perth and Kinross STLs Evidence Research Report Affordability and housing system pressures including ineffective stock As with the LHS, the housing system pressures considered are more appropriately tackled by targeting the delivery of affordable housing rather than simply increasing total land supply in the iLHLR – no change Existing Housing Need in Perth and Kinross – Report commissioned by Homes for Scotland Alternative existing need estimates The results of the HNDA, together with the evidence the Council provided in relation to establishing the MATHLR, are preferred in informing the iLHLR – no change Perth and Kinross Self and Custom Build Housing Demand for self and custom build There does appear to be demand for self and custom build in Perth and Kinross which was not taken into account in the calculation of the HNDA. It would therefore be appropriate to make an allowance within the iLHLR to help accommodation the demand for self and custom build.
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Source Considers How evidence has informed the iLHLR Perth and Kinross HLAs The availability of land for housing Much of the considerations arising from the HLAs, such as the distribution of the land supply, site scale, and deliverability relate to the spatial strategy and review of existing allocations for the Proposed Plan rather than Evidence Report stage – no change Research on the Barriers to Housing Delivery The barriers to housing delivery The variety, scale and significance of the barriers identified will not be solved by simply increasing the supply of land, and the existence of these barriers do not in themselves justify making an allowance within the iLHLR – no change Research on the Role of Land in Enabling New Housing Supply in Rural Scotland The barriers to housing delivery in rural Scotland Planning and the Housing Emergency – Delivery Plan The Scottish Government’s approach to addressing the national housing emergency Focuses on delivery rather than the setting of the iLHLR – no change Big Place Conversation Consultee views on whether homes support community needs The need for more housing to meet a wide range of needs is already taken into account in the HNDA, LHS, SHIP and STL research and some of the other issues identified are considered in other sections of the Evidence Report – no change Whilst the HNDA and MATHLR are the starting points, consideration needs to be given to any local factors and / or new evidence which has arisen since their publication in setting the iLHLR in the Evidence Report. The iLHLR must be evidence-based. There is an agreed land supply for housing of nearly 17,000 units. The chart below shows that in very simplistic terms there is more than enough non- constrained housing land identified in the most recent published HLA to accommodate even the highest PKC or Scottish Government need estimate. There is even sufficient supply to meet the vast majority of the significantly higher Homes for Scotland identified need. At a build rate of 850 units per year (the annualised MATHLR) there is sufficient land to last nearly 20 years, almost double the 10-year LDP period. It is acknowledged, however, that this is not a straightforward calculation and that ultimately it is the bringing forward for development of that non-constrained land supply which results in the end delivery of houses on the ground.
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In proposing a locally adjusted MATHLR the Council wished to reflect its ambitions for the sustainable growth of Perth and Kinross, and this was reflected in the challenging figure put to Scottish Government. Whilst the Council was acutely aware of the risks of failing to allocate a generous supply of land for housing in the new LDP when proposing a revised MATHLR, it must also be recognised that an oversupply of land could also pose significant risks. Key questions to consider are firstly, what capacity is there within the industry to deliver houses at a higher rate and secondly, what would be the impact of increasing the supply of land for housing on the overall delivery of housing in Perth and Kinross. One concern is that a significant increase in the allocation of sites could dilute the market and / or lead to developers ‘cherry-picking’ the easiest sites in the most profitable areas to the detriment of achieving regeneration goals and sustainable development in other parts of Perth and Kinross. The MATHLR set out in NPF4 for Perth and Kinross already includes a generous flexibility allowance of 30% to compensate for sites stalling or not delivering as expected. As identified earlier in this section, it is expected that some new or updated information will be available by the time the LHLR in the Proposed Plan is prepared and this may result in a final LHLR which is different to the indicative figure set out in the Evidence Report. This includes: • Updates to HNDA inputs, for example from the 2022 Census • LHS Annual Reports • Information on the unmet needs of transient gypsy / travellers • New evidence relating to ineffective stock: o Impact of 200% Council tax levy on second homes o Impact of STL licencing requirements • Changes to HNDA methodology at national level • Self and custom build register • Enhanced deliverability assessment of all HLA sites • Impact of the Proposed Plan spatial strategy The suggestion of setting the iLHLR at 10,000 units over 10 years to reflect the SDP has been discounted as there is no evidence to support it. The other option considered in the Topic Paper of no increase on the MATHLR is also discounted as LDP Guidance expects that the LHLR will exceed the MATHLR. Furthermore, Homes for Scotland have made clear that, as the representative body of private sector housing providers, they would not support this approach. Taking all of the currently available information into account, however, there is considered little evidence at this stage for setting an iLHLR which is significantly higher than the MATHLR. This is because the HNDA for the area is up to date and because the factors which could justify an increase 0 2000 4000 6000 8000 10000 12000 14000 16000 18000 20000 LHS HST (5 years) MATHLR (10 years) HNDA (upper estimate over 20 years) Homes for Scotland Research total existing need Comparison of need estimates against supply Need Non-constrained land supply Total supply (incl. constrained sites)
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to the iLHLR (such as housing market drivers, estimated future need and demand including for elderly people and disabled people and those in higher or further education, and housing stock pressures) have already been considered in the setting of the MATHLR. The exception to this is taking account of the demand for self-build. The data from Buildstore suggests that the demand for self build may be considerable. As abovementioned, however, only data on the overall number of expressions of interest within Perth and Kinross postcode areas has so far been obtained and this may include individuals registering an interest in more than one postcode area. It cannot therefore be considered an absolute indicator of demand at this stage. It is, however, considered appropriate to make an initial allowance within the iLHLR to accommodate the apparent demand for self and custom build in Perth and Kinross. Of the 26 people who have indicated an interest on the Council’s register, 12 have said that they would intend to start building within a year, and a further 8 (with unknown timescales) have indicated that they have got the finances to pay for the build. It is therefore considered appropriate to make an initial conservative allowance of 20 units per year, 200 in total over the 10 year period of the Plan, to help accommodate the demand for self and custom build. This will be considered further at proposed plan stage once more detailed information on demand is known. The iLHLR for Perth and Kinross is therefore set at 8,700 over the 10-year period on the grounds that: • The MATHLR already takes account of the Council’s commitment to sustainable growth by seeking a challenging land requirement which balances the need to ensure a generous supply of housing land against the potential risks associated with oversupply. This commitment led directly to a more than 3-fold increase in the MATHLR from the interim draft figure of 2,650 to the final figure in NPF4 of 8,500. • It is considered appropriate to include an initial conservative allowance of 200 units to help accommodate the demand for self- build as this was not included in the HNDA. • Taking account of stakeholder views that the iLHLR is expected to exceed the MATHLR although, with the exception of Homes for Scotland, respondents did not appear to be seeking a significant increase over the MATHLR. Meeting the Local Housing Land Requirement In meeting the identified HLR, the calculations for LDP2 assumed that 10% of the requirement would be met on windfall sites, 15% would be met on small sites in the Highland HMA only, 10% of the requirement would be reallocated from the Kinross HMA to the Greater Perth HMA for environmental reasons, and 10% would be reallocated from the Highland HMA to the Greater Perth HMA due to environmental constraints. The paragraphs below identify issues which will need to be considered in meeting the LHLR in the Proposed Plan. Windfall and brownfield sites The LDP Guidance allows authorities to take account of the contribution of windfall sites to meeting their LHLR. Any assessment of the expected contribution of windfall sites must be realistic and based on clear evidence of past completions and sound assumptions about likely future trends. The Brownfield, Vacant and Derelict Land and Empty Buildings section of the Evidence Report highlights the work currently being carried out to develop a register of potential brownfield regeneration sites which arose from an action in the LHS to maximise the potential to create more homes through brownfield regeneration. This study is still at an early stage and will take some time to complete but it may well identify sites which can be considered for allocation in the Proposed Plan. This in turn should mean that going forward completions on windfall sites as a percentage of overall completions is most likely to reduce. At this stage is it not therefore
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considered that sound assumptions can be made about the likely future contribution from windfall sites and as such it is not currently proposed to include a contribution from windfall sites in meeting the iLHLR, rather these will provide a further element of flexibility in the land supply. Small sites Small sites have historically made a significant contribution to overall completions in Perth and Kinross, particularly in the Highland HMA, and as such the previous housing land requirement included an assumption that 15% of the housing land requirement in the Highland HMA would be met on small sites. There is, however, no specific mention of small sites within the LDP Guidance. As above mentioned, in the past the LDP has tended not to allocate sites of less than 10 houses and no decision has been made as yet as to the scale of sites which will be allocated in LDP3. It may therefore be that some smaller sites will be included in meeting the LHLR as site allocations. It is not proposed at present, however, to include an assumption that an overall percentage of the LHLR will be met on small sites. Instead, these will also add flexibility in the supply. Reallocation of requirements between HMAs As above mentioned, there is no longer a need to consider housing land supply or requirement at the HMA level so reallocation between HMA is no longer relevant. Review of existing LDP allocations Currently some settlements rely on a very small number of sites for their supply of housing land which leaves a shortfall if these fail to deliver. The new planning system requires a full review of all allocated sites for the next LDP. No site should just roll forward from one plan to the next as has sometimes been the case with past LDPs. This means that any sites which are uncertain in terms of their deliverability should be considered for removal from the next plan. This will require suitable deliverable alternative sites to be identified. Allocation of new sites As identified in the calculation of the iLHLR above, there is currently sufficient housing land supply overall to comfortably accommodate the MATHLR. Should a review of the deliverability of existing allocated sites identify a need for new sites, however, these will be assessed using the site assessment methodology. As discussed in the Design Quality and Place section of the Evidence Report, Homes for Scotland have invited the Council to utilise the Site Assessment Methodology and Deliverability Checklist they have prepared when considering ‘call for sites’ submissions. This is still in draft form, and it is noted that it may require revision once the Scottish Government’s new HLA guidance is published. The site appraisal template that the Council proposes to use is included as an annex to the Evidence Report. It is largely based on the agreed LDP: Site Assessment and SEA Checklist template developed by the Consultation Authorities, but with consideration given to the deliverability criteria suggested by Homes for Scotland. It should be noted that there are other pieces of work which will need to be carried out before selecting new sites, for example, review of the green belt and work on 20-minute neighbourhoods, as these will inform the site selection process. In identifying new sites, as well as assessing the suitability and deliverability of the site itself, it also may be appropriate to take in account wider considerations such as: • the range and / or size of existing allocations within a settlement or distribution within the wider HMA • the potential for a site to deliver on wider corporate objectives or provide multiple benefits • the need for a particular tenure or type of housing, or housing for specific groups
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Proposed Plan Spatial Strategy The spatial strategy for the current LDP2 was established by the then SDP which directed LDPs to focus the majority of development in the area’s principal settlements. Below these the LDP2 strategy allocated limited growth to those settlements with a range of facilities capable of serving local needs. Growth within the smallest and least accessible settlements with few or no local facilities was restricted. Section 4: Perth and Kinross LDP2 Monitoring reviews the implementation of the Plan’s spatial strategy themes and land allocations. Specifically in relation to the above hierarchical approach adopted from the SDP, the restriction on growth within the smallest and least accessible settlements has made the delivery of affordable housing in these communities particularly challenging and this will be considered in the preparation of the Proposed Plan. The NPF places new and / or enhanced emphases on some of the issues to be considered in defining the spatial strategy for an area. The Proposed Plan spatial strategy as it relates to land for housing will need to take particular account of: NPF Policy 8 Brownfield, vacant and derelict land and empty buildings This issue is considered in Section 5 and Appendix A: Sustainable Places of the Evidence Report under Brownfield, vacant and derelict land and empty buildings. This policy seeks to ensure that ‘development is directed to the right locations, maximising the use of existing assets and minimising additional land take’. The spatial strategy for LDP3 will need to consider the options to achieve this, for example, increasing densities on established sites, and the actions that the Council can take to accelerate the delivery of houses on sites which are currently constrained. Policy 15 Local living and 20-minute neighbourhoods This issue is considered in Section 5 and Appendix B: Liveable Places of the Evidence Report under Local Living and 20-minute neighbourhoods. This approach seeks to create connected and compact neighbourhoods where people can meet the majority of their daily needs within a reasonable distance of their home. This will clearly have a significant impact on where new sites for housing should be identified. NPF Policy 16 Quality Homes One specific requirement of Policy 16 not considered so far under the Homes issue is the identification of areas that may be suitable for new homes beyond the 10-year lifespan of the LDP. This does not impact on the iLHLR which is to consider the 10-year Plan period but will be relevant to take into account in the identification of the spatial strategy for the Proposed Plan. NPF Policy 17 Rural Homes There is a specific requirement under Policy 17 to identify in the spatial strategy any previously inhabited areas that are suitable for resettlement. This issue is considered in Section 5 and Appendix E: Rural Development of the Evidence Report. NPF Policy 18 Infrastructure first This issue is considered in Section 5 and Appendix D: Infrastructure and Transportation of the Evidence Report which look at cemetery provision, communications and digital, education facilities, healthcare, transport, and water and wastewater. The Infrastructure First approach will inform the Proposed Plan spatial strategy by helping identify those areas with existing infrastructure capacity, areas where development could help support existing infrastructure, or areas which are currently constrained but where development could help secure new infrastructure. It will not be appropriate to identify sites for housing in isolation without considering the potential impacts on infrastructure and infrastructure needs.
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NPF Policy 29 Rural development This issue is considered in section 5 and Appendix E: Productive Places of the Evidence Report under Rural Development. This policy places a much greater emphasis on encouraging economic activity in rural areas in order to create vibrant and sustainable rural places and a balanced and sustainable rural population. The spatial strategy in the Proposed Plan will therefore need to balance this increased support for development in rural areas and the delivery of homes in sustainable locations. The spatial strategy will also need to set out an appropriate approach to development in rural areas which reflects the identified characteristics of those areas. LDP2 Policy 6 Settlement boundaries The existing spatial strategy in LDP2 presumes against development adjacent to defined settlement boundaries except in a small number of circumstances. There is no similar emphasis in NPF4 and as such consideration will need to be given in the Proposed Plan to the future role of settlement boundaries as a means of either restricting or encouraging additional development. This may be particularly relevant in relation to facilitating development in rural areas, especially for affordable housing. Proposed Plan Policy Framework The intention of NPF housing policy is to encourage, promote and facilitate the delivery of more high quality, affordable and sustainable homes, in the right places and providing choice across tenures that meet diverse housing needs. The existing suite of housing-related policies in LDP2 includes: • Policy 19: Housing in the Countryside • Policy 20: Affordable Housing • Policy 21: Gypsy / Travellers Sites • Policy 22: Particular Needs Housing Accommodation • Policy 23: Delivery of Development Sites • Policy 25: Housing Mix In addition to these the policy framework for the Proposed Plan will need to consider how best to plan for the following housing solutions and options. Increasing the provision of affordable homes The HNDA and Affordable Housing System Pressure Analysis discussed above identifies the percentage of the Perth and Kinross households who will rely on affordable housing options to meet their housing needs. The tenure split between affordable and market housing identified in the HNDA is nearly 50/50. The tenure split of past completions for Perth and Kinross over the last decade, however, is approximately 30% affordable to 70% market. The figure below superimposes the percentage split of need / demand by tenure over the past 10 years completions. This highlights that market completions have historically been consistently above the market demand identified in the HNDA, whilst affordable completions (RSL and Council) have been consistently below the identified affordable need. The SHIP identifies the challenges involved in the development of affordable housing projects and the extent to which the affordable housing programme is dependent on private sector build-out rates.
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Source: HNDA and HLAs NPF Policy 16e) requires an affordable housing contribution of at least 25% on market housing sites unless the LDP sets out locations or circumstances where a higher contribution is justified by evidence of need, or alternatively a lower contribution is justified. The latter could be by evidence of impact on viability, where proposals are small scale, or where there is a desire to incentive particular types of homes such as self-build or wheelchair accessible homes. Consideration will need to be given in developing the Proposed Plan policy as to whether an alternative affordable housing contribution is justifiable in some parts of Perth and Kinross and under what circumstances, or whether there are other suitable options such as the allocation of sites for 100% affordable housing, the opportunities for development of Council-owned land, or the scope for cross-subsidy with market housing. Self-provided homes Many houses built under the existing LDP2 housing in the countryside policy are already a form of self-build. There was also an attempt to make provision for self-build opportunities on larger sites through the preparation of LDP2 by introducing a requirement in policy 23: Delivery of Development Sites for developers to demonstrate how delivery on the site will be maximised including provision for self-build. The LDP examination Reporter amended the policy wording, however, to the ‘consideration of provision for self-build’ due to concerns raised by developers with regard to potential lending, complexity and health and safety-related problems especially on larger sites. Any local policy designed to encourage self-build opportunities will therefore need to take account of these concerns as well as evidencing demand for self-build. Rural homes There is a much enhanced emphasis on the delivery of new housing in rural areas in the NPF in order to improve choice of tenure to meet the needs of local people and provide homes that support sustainable rural communities. The existing LDP2 housing in the countryside policy supports proposals for single houses and small groups of houses in the countryside. The Proposed Plan, however, will need to consider whether there is a need for local level policy specifically to encourage and facilitate the accelerated delivery of affordable, sustainable homes in rural areas consistent with balanced consideration of the intent and outcomes of the suite NPF policies. This could be considered in tandem with a review of the existing LDP2 settlement boundary policy. Homes to meet particular needs The LHS and SHIP are the primary vehicles for the delivery of housing for specific groups which require affordable housing. It would be incorrect, however, to assume that every household containing an older or disabled person needs an affordable house. Some will have the financial means to meet their needs on the open market but only if market housing which is suitable to meet their needs is available. The Proposed Plan will need to consider whether there is a continued need for a local level policy in order to secure a greater proportion of homes within market developments to 0 20 40 60 80 100 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 Comparison of need against past completions % Market completions % Affordable completions % HNDA market demand % HNDA affordable need
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meet particular needs and / or to look at alternative means of provision, for example, allocating sites wholly or partly for market housing options particularly to meet the needs of older or disabled people. Given the high level of need for more accessible housing, wheelchair accessible housing in particular, the Proposed Plan will also need to consider the most appropriate way to address this need. The Council is already working with RSL partners to deliver wheelchair accessible housing in the affordable sector and the forthcoming changes to building standards to underpin the Scottish Accessible Homes Standard should have an impact on the numbers of more accessible market housing. NPF Policy 16c) already supports development proposals for new homes that improve affordability and choice by being adaptable to changing and diverse needs, and which address identified gaps in provision and consideration will need to be given as to whether local level policy is required to supplement this. LDP Delivery Programme There is a much enhanced emphasis in the NPF on the actual delivery of the LDP with an expectation that the LDP delivery programme will establish a deliverable housing land pipeline considering the short, medium and long term delivery of housing land. This will require the allocation of sites which are secure in their delivery and the regular and accurate on-going monitoring of these through the housing land audit process. PKC is committed to undertaking this review process and in bringing forward a pipeline of deliverable housing land and delivery programme as per the NPF and the Planning and Housing Emergency Delivery Plan. Gaps or Uncertainties in Data Short Term Lets More analysis is needed on the impact of residential properties as holiday accommodation. Data will become available on the potential for impact from the higher Council tax levy on second homes and the STL Licencing requirements on properties moving from STLs to second homes to inform the preparation of the final LHLR in the Proposed Plan. Gypsy / travellers and travelling showpeople A specific instruction in the NPF is for LDPs to allocate land for Gypsy / Travellers and Travelling Showpeople where need is identified. The HNDA concluded that over a 5-year period there would be a -2 shortfall to +4 surplus in permanent Gypsy/Traveller site pitches This was, however, based on 2016 data and is qualified by uncertainties in estimating demand. In relation to Travelling Showpeople, the HNDA referred to the then draft 2022-27 LHS which had no evidence on the needs of Travelling Showpeople to support estimating future requirements. It is acknowledged that the data relating to the accommodation needs of Gypsy / Travellers and Travelling Showpeople is in need of updating. An updated needs assessment is programmed to be carried out 2025/26 and PKC is exploring the possibility of working with neighbouring authorities on this. The updated need assessment will inform the final LHLR in the Proposed Plan. Deliverability of land supply Every year the audit is discussed with Homes for Scotland with a view to achieving consensus on individual site programming. With the changes brought about by the new planning system it was a more complicated process when discussing the 2023 HLA, especially given that the 10-year housing land pipeline is not yet in place. As a result, it was not possible to reach agreement on the programming of four sites within the 2023 audit, all of which Homes for Scotland consider constrained and should not be programmed within the 10-year period. Whilst this is far from ideal there will be further opportunities for discussion with Homes for Scotland and their members through the preparation of subsequent audits which will inform the preparation of the final LHLR in the Proposed Plan.
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The consideration of factors affecting delivery as used by Edinburgh City Council is still at an early stage and only some sites in the HLA have been discussed in draft form with Homes for Scotland as a pilot exercise in 2023. This highlighted that it may be appropriate to adapt the Edinburgh approach to more closely reflect some of the factors applicable in Perth and Kinross before rolling this out as a formal part of the HLA process. It is proposed that this will be carried out for future HLAs and will therefore be in place to inform the final LHLR in the Proposed Plan. Summary of Stakeholder Engagement: The LDP Guidance indicates that the stakeholders expected to be engaged in the preparation of housing related evidence for the Evidence Report includes – local authority housing colleagues, social housing providers, private housing providers, landowners, representative bodies of housing providers and landowners, and housing and specific interest groups. There is a particular requirement for the Evidence Report to be informed by the views of the Gypsy Traveller and Travelling Showpeople communities. Engagement on HNDA outputs A crucial element in producing the HNDA was in securing the scrutiny, feedback and support of external partners and stakeholders in building the HNDA evidence base and in validating the core outputs and housing estimates. To facilitate this, two engagement events were held in May and December 2021. The focus of the May event in particular was to help inform the Council’s response to Scottish Government on the interim draft MATHLR. Over 80 partners and stakeholders with interests across the whole Tayside HNDA area (Angus, Dundee, Fife and Perth and Kinross Council areas) attended the event. This included representatives from partner local authorities, RSLs, private developers, economic development agencies, health and social care partnerships and third sector organisations. As discussed in the summary of evidence section above, in addition to the two scenarios considered in the HNDA a further ‘growth scenario’ was developed as the HNDA was being prepared and although this was not included within the final HNDA it was one of the scenarios which was discussed with partners and stakeholders. There was unanimous support for using a growth scenario to inform future housing supply targets. This feedback informed the Council’s response on the interim draft MATHLR for Perth and Kinross which in turn led to a final MATHLR in the NPF more than three times higher than the draft figure. The second engagement event was an opportunity for external partners and stakeholders to scrutinise the HNDA evidence and validate the final HNDA housing estimates by sub-area and by tenure. A total of 54 partners and stakeholders with interests across the Tayside HNDA area attended and provided feedback on the contextual factors which should be considered when using housing estimates as the basis for future policy development. Big Place Conversation The Council carried out its ‘Big Place Conversation’ exercise to kick start the LDP3 process across Perth and Kinross communities during most of 2023. This was a substantial exercise involving over 100 events throughout the Council area. The events ranged from drop-in information sessions, meetings, and online surveys to workshops and online sessions using the Place Standard Tool to capture the views of local communities about different aspects of their places. The results of the BPC are summarised as part of a separate report on the outcomes and findings across the different locality areas. Engagement with Gypsy / Traveller communities In addition to the open public consultation there were also targeted sessions held with minority groups. This included discussions with
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members of the Gypsy / Travelling community on private and council sites and in bricks and mortar housing. The Participation and Engagement section of the Evidence Report sets out details of the engagement with the Gypsy / Traveller community and comments received are incorporated into the PKC Wide summary report and Cleish and Blairadam, and Tulloch Community Council reports. This includes an indication that waiting lists may be a poor indicator of demand, and also that there are people in social housing who would prefer accommodation more suited to their needs. LDP3 Evidence Report Topic Papers The Council produced a series of LDP3 Evidence Report Topic Papers, covering the individual subject matters of NPF4’s suite of national planning policies. These papers, which set out the detailed evidence the Council has gathered to help produce our Evidence Report and which we hope to use to help prepare our Proposed Plan, were published on the Council’s Consultation Hub and open for comments for a period of 6 week during July and August 2024. As part of our consultation process for LDP3 Topic Papers we welcomed the views of our key stakeholders (who were contacted specifically via email regarding the consultation exercise) and the public at large, on the sufficiency of the evidence gathered, our interpretation of the implications of that evidence to the Proposed Plan, and on how we intend to use that evidence to develop our LDP3. We also asked respondents to provide links to other sources of available information or data which they felt we had not included, alongside an explanation of why they considered any additional sources of information to be relevant to the preparation of the LDP. In addition to the key agencies prescribed under the Planning Act, the following stakeholders were contacted directly about the Topic Papers: local authority housing colleagues, members of the Perth and Kinross Housebuilders Forum (including social and private housing providers), larger estates / landowners in the area, the Scottish Federation of Housing Associations, Homes for Scotland, Scottish Land and Estates, Rural Housing Scotland, National Farmers Union Scotland, MECOPP, and Scottish Enterprise.
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Statements of Agreement/ Dispute: 11 responses were received on the Homes Topic Paper. Just over half of respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 020, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and / or highlighted other potential implications for the Proposed Plan. A summary of these comments, their status, and the Council’s response are provided in the table below. There were three responses on the Homes issue which the respondents wished to be treated as a formal dispute to the Evidence Report. Those responses have been highlighted in red in the table. Respondent Agree or Dispute Summary of Comments PKC’s Response Tactran Not stated List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: Tactran notes that it is difficult to understand the scale of the problem and the potential impact new development can have on quality homes without knowing the baseline data in ln relation to (traffic related) noise levels (see Scotland’s Noise Mapping), air quality – especially in the declared AQMAs in Crieff and Perth – and accident statistics. Formal Dispute: No The SEA for the Proposed Plan will consider the relevant environmental baseline to identify best sustainable locations for development considering any existing and likely future environmental impacts and appropriate mitigation measures to address these. Scottish Water Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Formal Dispute: No No action required Errol Community Council Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Formal Dispute: No No action required
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Respondent Agree or Dispute Summary of Comments PKC’s Response Aberfeldy Community Council Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Generally agree Further Comments: Highlighted key points around the need for more (affordable) housing in the area. Relevant to this topic: • Range of additional housing sites to be identified and not relying on current allocated site in Aberfeldy • Surrounding smaller settlements to support delivery of new affordable housing development to lessen impact on Aberfeldy • Loss of residential housing to holiday accommodation therefore suggestion for higher affordable housing % as part of new developments Formal Dispute: No Comments have helped inform the Summary of Implications for the Proposed Plan section of the Evidence Report. Earn Community Council Agree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: Appears there is sufficient land to meet housing needs – but also the opportunity to demote sites and potential/optional to allow for planning authorities to 'Call for Ideas'. There is also a need to make sure that homes are being built in the right places and meet the needs of age, education and health. The existing spatial strategy in LDP2 also presumes against development adjacent to settlement boundaries (LDP2 Policy Comments have helped inform the Summary of Implications for the Proposed Plan section of the Evidence Report.
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Respondent Agree or Dispute Summary of Comments PKC’s Response 6). There is no similar emphasis in NPF4 and as such consideration will also need to be given through the plan preparation process to the future role of settlement boundaries as a means of either restricting or encouraging additional development. Strongly Agree with this statement. Noted that the options proposed for the iLHLR are 8500 homes over 10 years or 10,000 over 10 years and what calculation to use in order to determine this. Formal Dispute: No Private Individual Disagree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): The data based upon Homes for Scotland is biased and should not be included. The premise that housing leads to growth should be removed. Further Comments: None Formal Dispute: The respondent wishes their comments to be recorded as a formal dispute on the grounds that using data from a self-interested source – Homes for Scotland – distorts the report. The premise that houses lead to growth should be substantiated. An estimate of available employment opportunities should be indicated. The Report is the foundation of other reports in the submission so should be accurate and unbiased. The LDP Guidance states that it is ‘vital that stakeholders get involved by providing data, information, and their views at an early stage’ (para 117). Stakeholders expected to be engaged in the preparation of housing related evidence for the Evidence Report includes private housing providers, and representative bodies of housing providers. It is therefore considered appropriate to take Homes for Scotland’s views and data into account in preparing the Evidence Report. Conclusion on dispute:
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Respondent Agree or Dispute Summary of Comments PKC’s Response It is not considered appropriate for the Council to disregard the evidence submitted by Homes for Scotland. The dispute therefore remains unresolved. Homes for Scotland Disagree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): 1. Further data on housing system pressures in Perth and Kinross must be available for review prior to the submission of the Evidence Report to the Gate Check process. 2. It is imperative that future LDPs reflect and respond to the national Housing Emergency and that this must act as a central pillar in determining housing targets at the local level. An accurate, dependable, and up to date evidence base is therefore essential. It is positive that the ‘Existing Housing Need in Perth and Kinross report’, commissioned by Homes for Scotland is referenced in the Topic Paper but more consideration must be given to it in setting the indicative LHLR. Where stakeholders consider further evidence may be relevant after the HNDA, this may be raised in engagement and reflected in the Evidence Report. Stakeholders expected to be engaged in the preparation of housing related evidence for the Evidence Report include representative bodies of housing providers and landowners. Where more recent information is available this should be used (LDP Guidance). The Homes for Scotland report is based on a household survey that includes families in over-crowded homes, young people 1. Further data was published and forwarded to Homes for Scotland on 21 August. This data has been incorporated into the Evidence Report. 2. The HNDA was carried out using the Scottish Government’s HNDA tool and incorporated both primary research and secondary data sources. The HNDA was confirmed as robust and credible. The Diffley Report prepared for Homes for Scotland was not considered in partnership with the Council or with other stakeholders. It is noted, however, that this research is to be discussed at Scottish Government level. If the conclusion of those discussions is that this research is to be preferred nationally over those derived through the
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Respondent Agree or Dispute Summary of Comments PKC’s Response still living with parents, and older people in homes that are unfit for their changing needs. Furthermore, the recent Chief Planner’s letter includes convening a discussion on the Homes for Scotland report and it is clear, therefore, that this research is an important cornerstone in seeking to deliver more homes. 3. The c.12,200 households figure referred to in table 19 of the Topic Paper does not reflect the results of the Existing Housing Need in Perth and Kinross report regarding estimated total existing need. The report identifies that there are around 19,000 households in existing need once those who can make in-situ repairs are deducted. 4. There must be continued engagement with the industry given the socio-economic benefits of home building. 5. The MATHLR is to be exceeded in setting the Local Housing Land Requirement. There is therefore no basis for Option 1. Homes for Scotland would robustly dispute any attempt to set an LHLR that does not exceed the MATHLR. 6. It is too early to say what the LHLR should be as this depends on a thorough analysis of all available evidence of existing and newly arising housing need and demand, and the extent to which those needs and demand can be addressed by existing housing stock. 7. Agree with the Council’s proposed approach to not include in the indicative LHLR a contribution from windfall sites or small sites. HNDA process, then it can be used to inform the setting of the final LHLR at Proposed Plan stage. 3. The Evidence Report has been amended to more accurately reflect conclusion 4 of the Diffley Report. 4. Agreed 5. There is an expectation rather than a requirement for the LHLR to exceed the MATHLR. The Topic Paper concluded that the MATHLR already seeks a challenging land requirement for Perth and Kinross and therefore option 1 was considered reasonable. That said, the Council wished to also seek views on setting a higher iLHLR for the Evidence Report hence option 2 which is nearly 18% higher than the MATHLR. Homes for Scotland’s views on the iLHLR exceeding the MATHLR have been incorporated into the Evidence Report.
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Respondent Agree or Dispute Summary of Comments PKC’s Response 8. The 2023 HLA non-constrained land supply figure of 16,922 is incorrect. 9. It is unclear why the 2022 HLA is referred to in the Topic Paper when the 2023 Audit is published. 10. There is a greatly enhanced emphasis in NPF4 on deliverability and LDPs are to consider the de-allocation of undeliverable sites (draft Site Assessment Methodology proposed). This process may affect many of the sites currently referred to as being non-constrained. 11. Projected completions post Plan adoption (Oct-Dec 2027) must be removed as they will be delivered outwith the emerging plan period. Across this period, the HLA actually demonstrates a non-constrained land supply of just 6,402 units (including sites which may be removed in the next LDP but excluding programming for 2035/36 onwards as no annualised completions projections are available for this period). Removing those sites which are currently disputed by Homes for Scotland reduces this further to 5,912 units. Formal Dispute: Homes for Scotland wish to formally dispute this issue on the grounds that the MATHLR is to be exceeded. 6. The Council is required to identify an indicative LHLR in the Evidence Report, based on currently available evidence, which will be replaced by a final LHLR at Proposed Plan stage. 7. Noted. 8. 16,922 is the agreed supply. This figure removes from the non-constrained / effective supply identified in the 2023 HLA the 489 units which were disputed that year by Homes for Scotland. 9. The 2022 Audit is only referred to in relation to the previous housing supply target set out in TAYplan2. This comparison was not carried out in the 2023 Audit as by then the TAYplan2 target had been superseded by the MATHLR in NPF. 10. It is acknowledged that any sites which are de-allocated through LDP3 will need to be replaced. Homes for Scotland’s proposed deliverability
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Respondent Agree or Dispute Summary of Comments PKC’s Response checklist has been taken into consideration in compiling the site assessment methodology template. 11. Those units which are programmed in the HLA beyond the Plan adoption date are so because of the capacity of the industry to deliver. If the delivery rate is increased, then the programming can be brought forward in the housing land pipeline as the sites are not considered constrained. Conclusion on dispute: The iLHLR set out in the Evidence Report exceeds the MATHLR so on strict interpretation, the dispute is resolved. It is acknowledged, however, that taking a broader view of Homes for Scotland’s concerns it is likely that they will be of the view that the iLHLR should be higher still than that proposed in the Evidence Report. Gray Planning and Development Ltd on behalf of GS Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: The differences between the HNDA and the Diffley Research is considered in the Evidence Report.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Brown Construction Ltd Noted that in the HNDA analysis there is a housing need of around 1,328 compared to a Homes for Scotland analysis of 21,000. This suggests considerably higher levels of housing need than that in the HNDA or that could be accommodated within the MATHLR. Agree with the principle of de-allocating sites which are constrained and in the current LDP – however this must be with a suitable deliverable replacement in terms of scale and form of proposals. We also agree with the method to look at sites which have consent to a landowner but have not progressed into control of a housing developer, to enable actual realisation of housing delivery. Preference would be Option 2 as this reflects Strategic Development Plan previously set out. Broadly supportive of a potential shift in spatial strategy of the new LDP to bring more focus on rural areas encouraging economic activity (NPF4 Policy 29 Rural Development). Formal Dispute: No Support noted in relation to other comments and preference for an iLHLR which exceeds the MATHLR. Savills on behalf of Scone Estate Disagree List of Evidence/Datasets: The Scottish Land Commission Research on rural housing should be taken cognisance of. Summary of Implications for Proposed Plan (PP): No comments Further Comments: The Scottish Land Commission Research has been included in the summary of evidence. 1. Noted that the respondent supports an iLHLR which exceeds the MATHLR. Disagree, however, that the number
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Respondent Agree or Dispute Summary of Comments PKC’s Response 1. PKC is predominantly rural, and work should be done to increase the resilience of settlements via innovative means to deliver critical Local Living focused services instead of a slavish adherence to 20-minute neighbourhoods and blanket restrictions on development based on current services and not growth potential. The facilitatory role that housing delivery can provide in assisting PKC achieve other Spatial Strategy aims should be recognised, not just in helping deliver affordable housing but also in other areas such as biodiversity enhancement, green infrastructure and active travel provision. Acknowledge that the Council has a generous MATHLR, but support Option 2 because the greater the choice and variety in housing sites the better. The Council should be confident in exceeding the MATHLR set and push for housing sites to help the Council achieve multiple benefits, ultimately the number is arbitrary. It is securing quality in delivery that is key and that can be controlled via a collaborative approach with all stakeholders in relation to housing and associated multiple-benefit delivery. 2. The evidence outlined towards self-build and custom- built need is flawed as it appears to rely on historic consents but makes no mention of pre-application enquiries or refusals of small sites. Buildstore data has shown large numbers of parties who desire self-build plots in the PH1 postcode. 3. If some allocated sites are found to be undeliverable then the scale of the supply goes down. There should therefore should be considered arbitrary. NPF policy 17 requires LDPs to set out tailored approaches to rural housing and where relevant include proposals for future population growth including provision for small scale housing. Plans are to reflect locally appropriate delivery approaches. Whilst it is relevant to take account of other benefits that new housing development can bring, it is considered that this is most appropriately done through the site assessment and allocation process. As discussed in the Summary of Evidence section, no decision has been taken as yet as to the size of site which will be allocated in LDP3. Furthermore, NPF policy 16f) is very clear on the circumstances under which unallocated sites should be supported. 2. The limitations of relying on past completions as an indicator of demand is acknowledged. More informed
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Respondent Agree or Dispute Summary of Comments PKC’s Response be acknowledgement that there might be additional need to that previously accounted for and this should have greater security of delivery in the relevant LDP pipeline because greater information is now required to ensure deliverability than in previous LDPs (for example the infrastructure first approach). 4. Need for flexibility on rural housing because there is no one-size fits all approach. The Council should not rely on the NPF4 rural homes policy alone as this has some significant omissions in routes to rural homes delivery. A balanced approach to use of NPF4 policies is essential to ensure appropriate and increased delivery of rural housing. One key area would be allowing limited market housing to encourage affordable housing delivery alongside in the Council's Housing in the Countryside policy and on the edge of settlements. Formal Dispute: Savills on behalf of Scone Estate wish to formally dispute this issue on the following grounds: a) Data to be used to reflect Self and custom build demand/need b) A lack of acknowledgement of the facilitatory role of housing in meeting other spatial strategy aims c) The need for a balanced approach to use of NPF4 policies to ensure appropriate and increased delivery of rural housing. evidence on demand for self and custom build has been sourced and included in the Evidence Report. 3. Comments have helped inform the Summary of Implications for the Proposed Plan section of the Evidence Report. 4. Comments have helped inform the Summary of Implications for the Proposed Plan section of the Evidence Report. Conclusion on dispute: The grounds of dispute a) and c) have been addressed and / or incorporated into the Evidence Report. These disputes are therefore considered resolved. Regarding dispute b), the Council considers the NPF housing policies are clear on the circumstances under which unallocated housing sites should be supported. This dispute therefore remains unresolved. Savills on behalf of Dupplin Estate Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Response is as point 1 of the Savills on behalf of Scone Estate response
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Respondent Agree or Dispute Summary of Comments PKC’s Response Further Comments: Through the Perth Sustainability Park, there is an opportunity for a development of high quality homes following the principles of Building with Nature. The Evidence Report and future LDP must recognise the facilitatory role that housing delivery plays in assisting PKC achieve other Spatial Strategy aims. It is a common theme that market value housing helps deliver affordable housing for example, but this model can be applied to other areas such as biodiversity enhancement, green infrastructure and active travel provision etc. PKC should work with landowners and housebuilders to maximise housing delivery and the multiple benefits housing can bring. If the Council are clear on this approach, then they should be confident in exceeding the MATHLR set and pursuing these multiple benefits across the region via a variety of approaches that delivery a variety of housing. Acknowledge that the Council have a generous MATHLR, but still support Option 2 because the greater the choice and variety in housing sites the better for Perth and Kinross and achieving the sustainable growth of the region which will sit along the aims of the next Spatial Strategy. In short, Perth and Kinross should push for housing sites to help the Council achieve multiple benefits. Securing quality in delivery is key and that can be controlled via a collaborative approach with all stakeholders in relation to housing and associated multiple benefits (active travel, services etc.) to ensure successful places are created in the currency of LDP3. above. This respondent has not raised a formal dispute, but the issue is highlighted for consideration by the Reporter by the preceding respondent in any event.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: No Ristol Consulting Disagree, but does not wish to register as formal dispute List of Evidence/Datasets: No comments Summary of Implications for Proposed Plan (PP): If green belt policy is continued into the review LDP, please explore the application of housing in the countryside policy particularly for the criteria of building groups and infill. The contribution these criteria make to local, rural housing is invaluable whilst the adverse impact on the intent and outcome is negligible and can be assessed through wider non green belt policies on amenity and environment. Would welcome exploring a policy framework to accelerate the delivery of affordable, sustainable homes in rural areas consistent with the intent and outcome of NPF policies 16, 17 and 18. Of note are the well documented housing challenges facing Dunkeld & Birnam and the necessity for new allocation(s) to meet local need. Formal Dispute: No Comments in relation to the green belt and housing in the countryside are considered under the Green Belt section. Remaining comments have helped inform the Summary of Implications for the Proposed Plan section of the Evidence Report.
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Meeting the requirements of the Act: The Act sets out a number of requirements relating to housing which local authorities have to set out in the preparation of their Evidence Report. The Housing Needs of the Population of the Area Part 2, Section 16B(3) and Section 15(5)(ca) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to set out their views on the housing needs of the population of the area (including, in particular, the needs of persons undertaking further and higher education, older people, and disabled people). With respect to the Perth and Kinross Area, the HNDA calculation combines the components of housing need to create a 20-year range of housing estimates for Perth and Kinross as follows: • There is an estimated need for around 5,400 – 6,500 houses over the 20-year period of the HNDA • Approximately 1,500 households may require housing for older people • Up to 3,200 households may require a more accessible form of housing, 640 households may require wheelchair accessible housing • There is a backlog demand of 50 students in education requiring accommodation The Availability of Land for Housing Part 2, Section 16B(3) and Section 15(5)(cb) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to set out their views on the availability of land in the district for housing, including for older people, and disabled people. With respect to the Perth and Kinross Area there is an agreed land supply for housing of nearly 17,000 units. This means that, in very simplistic terms, there is enough non-constrained housing land to last nearly 20 years at a build rate of 850 units per year (the annualised MATHLR). This is almost double the 10-year LDP period. It is acknowledged, however, that this is not a straightforward calculation and that ultimately it is the bringing forward for development of that non-constrained land supply which results in the end delivery of houses on the ground. Construction and Adaptation of Housing Part 2, Section 16B(3)(b)(i) and (ii) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to provide a summary of the action taken by them to support and promote the construction and adaptation of housing to meet the housing needs of older people and disabled people in their area, and an analysis of the extent to which the action has helped to meet those needs. With respect to the Perth and Kinross Area the LHS and SHIP are the primary vehicles for the delivery of housing for specific groups which require affordable housing. The LHS Annual Progress Report discussed in the summary of evidence section sets out the achievements so far in relation to meeting the needs for affordable housing generally, and of older people and disabled people in Perth and Kinross specifically. As identified in the SHIP, the Council is committed to increasing the supply of wheelchair accessible housing and is aiming for 10% of homes built to be suitable for people with particular needs where this can be met within affordable housing development sites. Existing LDP2 Policy 22: Particular Needs Housing Accommodation supports proposals for residential developments supporting housing for particular needs such as housing for frail or elderly people, people with additional support needs, and housing for varying needs. Houses in
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multiple occupation are also supported where a need for such accommodation can be demonstrated. In relation to the backlog demand of 50 students in education requiring accommodation, the Draft Perth City Centre Development and Design Framework identifies the ‘University Quarter’ as one of the proposed investment areas for the city. It refers to a new vision for the University Campus ‘Quarter’ which is to provide a new framework which will deliver a new educational facility for primary / secondary / further and higher education in one campus location. This will be developed alongside other ancillary uses, but no reference is made to providing more student accommodation on site. Planning permission was granted in 2019 to convert and extend an existing retail unit in the city centre to student accommodation comprising 47 bedrooms, 30 studios and associated communal facilities but the permission has not been implemented. Further discussion will therefore be needed with the College to understand any outstanding accommodation requirements. Policy 25: Housing Mix requires that the market element of all sites with a total capacity of 20 or more provide an appropriate mix of house types and sizes and meet the needs of smaller households including older people and lower income households by providing at least 10% of their units as one or two bedroom homes. This is in addition to any affordable housing requirements on the site. Furthermore, ‘where there are identified clusters of households with specific housing needs within the settlement, such as housing for wheelchair users, there may be a requirement for up to 10% of the development to be designed to meet these specific identified needs or for the developer to demonstrate that the house is capable of adaptation’. There were no specific site allocations for housing for older people or disabled people in LDP2. These policies have been used in assessing planning applications since the adoption of LDP2. Policy 22 in particular has helped facilitate the development of a residential assisted living scheme for over 55s, a change in house type to allow for a specialist need bungalow to be provided on a larger scheme, assisted living units, and a 10 unit HMO aimed at providing student accommodation. Accommodation Needs for Gypsies and Travellers Part 2, Section 16B(3)(b)(i) and (ii) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to provide a summary of the action taken by them to meet the accommodation needs of Gypsies and Travellers in their area, and an analysis of the extent to which the action has helped to meet those needs. With respect to the Perth and Kinross Area LDP Policy 21: Gypsy / Travellers’ Sites protects existing authorised sites with a presumption against their conversion to another use. The policy also supports proposals for new permanent sites and temporary short stay sites and sets out the criteria against which such proposals will be assessed. There were no specific site allocations for new Gypsy / Travellers’ sites in LDP2, although the settlement boundary of Greenacres private site was drawn to allow for expansion. Only a small number of planning applications have been submitted relating to Policy 21 during the lifetime of the Plan. Most notably permission was granted for replacement chalets on an existing Gypsy / Travellers site, and permission refused for an extension to another small existing Gypsy / Traveller site on health and safety grounds. The LHS Annual Progress Report discussed in the summary of evidence section sets out the achievements so far in relation to meeting the accommodation needs of Gypsies and Travellers in Perth and Kinross. Also, as abovementioned the HNDA data relating to Gypsy / Traveller needs dates from 2016. The 2016 report indicated a need to explore provision of transit sites. As a result, the Council has committed funding to and is currently progressing a 10 pitch transit site in Perth. Although there are no plans in the current SHIP for affordable homes for Gypsy / Travellers, work
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is progressing to establish the unmet needs of transient Gypsy / Travellers, and working with community members to have a better understanding of their accommodation needs and preferences is identified as an action in LHS. Further detail on this is set out in the Gaps or Uncertainties in Data section.