Item 6 - Accelerating Home Building in Scotland
West Dunbartonshire Council · 22 April 2026
Back to Planning Committee — 22 April 2026 and its agenda
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WEST DUNBARTONSHIRE COUNCIL Report by the Planning, Building Standards and Environmental Health Manager Planning Committee: 22nd April 2026 ___________________________________________________________________ Subject: Scottish Government Consultation on Accelerating Home Building in Scotland 1. Purpose 1.1 The purpose of this report is to seek committee approval of the proposed response to the consultation. 2. Recommendation 2.1 It is recommended that Planning Committee agrees the response noted at Appendix 1 to be submitted as West Dunbartonshire Council’s response to the consultation. 3. Background 3.1 The Scottish Government is consulting on proposed penalties and incentives to accelerate house building in Scotland. The full consultation documents can be found at https://www.gov.scot/publications/accelerating-home-building- scotland-consultation-penalties-incentives-speed-up-housing-delivery/ 3.2 The consultation is part of a wider response to the nationally declared housing emergency. A major driver for intervention is the significant number of homes that already have planning permission but have not been built. Recent Government estimates indicate approximately 164,000 consented units remain unbuilt, demonstrating that the key barrier to housing delivery is not securing planning permission, but progressing sites post-consent. Evidence shows delivery can stall due to market absorption rates, viability challenges, infrastructure deficits, land assembly issues, and developer commercial decisions. 3.3 Within a West Dunbartonshire context, the most up to date figures from the 2025 Housing Land Audit demonstrate that there were 1,993 units with planning consent that are under construction or not yet started, with 1,788 of them expected to be delivered before 2032. Taking this as an annualised figure over that 7 year period, an average of 255 units per year have been programmed from consents. This aligns with past trends, with an average of 263 units being completed annually over the last 5 years. Comparing this to the Minimum All Tenure Housing Land Requirement (MATHLR) for West Dunbartonshire in National Planning Framework 4 (NPF4), the total MATHLR is 2,100 over a 10 year period annualised to 210. As the consented sites should deliver on average 255 units per year, it can be seen that consents ITEM 6
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from the Planning Authority are not a barrier to delivery and adds weight to the national picture that the key barrier is not consent through the planning system, but delivery. 3.4 The Government considers accelerated delivery essential to support economic growth, meet housing need, and maintain confidence in the planning system. Ministers have emphasised that Scotland “urgently needs more homes” and that many sites with planning permission are not moving to construction despite the planning system having already done its part. The consultation therefore examines whether incentives, clearer expectations and if, where required, stronger interventions could unlock stalled sites and ensure faster delivery. 3.5 The consultation seeks views on four broad categories of reform aimed at improving build-out rates: Fiscal incentives or penalties to reduce delays on allocated or consented sites. Stronger monitoring and potential intervention powers where delivery is unreasonably slow. Streamlined planning processes for smaller sites to support SME housebuilders. Greater diversity of housing types and tenures on larger sites to increase market absorption. 4. Main Issues Summary of the proposed response 4.1 The Planning Authority is not convinced that fiscal penalties or reliefs would materially accelerate build-out and would be concerned by their introduction. Whilst we broadly agree that there may be a case for penalties or incentives in some circumstances, delivery is more commonly constrained by viability, infrastructure, market conditions, and developer programming rather than tax burdens. There is a concern that penalties may distort Local Development Plan delivery by making it less attractive to bring forward sites for development, or by inadvertently delaying the submission of applications. 4.2 The Planning Authority is not supportive of a tax on allocated sites. Similar to the reasons above, there is concern that this would be seen as a punitive measure and may result in reduced development interest, particularly in lower market areas, such as West Dunbartonshire. If introduced, it should only apply to sites with planning permission to prevent developers withdrawing from land promotion and apply to the developer, not a landowner. Uncertainty exists as to how “permission” would be defined, for example, should this apply to Planning Permission in Principle applications as well as Full Planning Permissions, and to what other consents outside of the planning system would it include, for example Building Standards? The tax should, if
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implemented, be localised with any income reinvested into infrastructure or planning and related services to support delivery. 4.3 The Planning Authority is broadly supportive of enhanced reporting mechanisms. It is considered that this is best achieved by tying the requirement to housing land audits, provided requirements are proportionate, given that this process already captures a significant amount of information relating to build out rates. The Planning Authority however would raise a concern that that revocation powers without compensation would improve delivery, noting such action could actually delay sites restarting under a new developer. Limited, highly specific circumstances could justify revocation where a stalled site prevents infrastructure capacity being utilised elsewhere. 4.4 The Planning Authority, whilst supportive of Small and Medium Enterprise (SME) builders, raises concern that introducing new streamlined processes solely for SME’s would be best to apply to all sites of a certain scale. It is our view that development impact is determined by context rather than developer size, and whilst we support, and already apply, a proportionate approach, this is applied on a case-by-case basis depending on the specifics of the case. Again, whilst we broadly support proportionality, the Planning Authority would raise concerns that such changes have to be handled carefully to avoid weakening placemaking or design quality. However, wider review of hierarchy thresholds could be considered, potentially introducing a “medium” category. 4.5 The Planning Authority supports the principle of diversified housing outputs but rather than a blanket national approach, it should be tailored to meet local Housing Need and Demand Assessments. Any legislative requirement for diversity should apply only to large strategic sites (e.g. 500–1,000 homes). Practical limitations in lower market areas must be considered to avoid undermining viability. 4.6 In terms of other measures, the consultation response highlights the need and opportunity to consider other matters that may assist with accelerating build out: Clearer and legally aligned validation requirements to reduce disputes and delays. Continued recognition of the role of infrastructure in enabling development and funding gaps. Consideration of enhanced status for LDP allocations to provide greater certainty. Increased Scottish Government resourcing for planning authorities to support the delivery focus of NPF4. Key summary of the response 4.7 Overall, West Dunbartonshire Council is supportive of measures that improve clarity, certainty and delivery focused planning. However, the Council raises concern over fiscal penalties or tax-based approaches and emphasises the
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need to avoid unintended consequences that could suppress development or market confidence. 5. People Implications 5.1 There are no people implications associated with this report. 6. Financial and Procurement Implications 6.1 No direct financial implications arise from responding to the consultation. Should new measures be introduced, particularly localised taxes, future resource implications may require assessment. 7. Risk Analysis 7.1 There is no financial, reputational or legal risk associated with this report. The Council is not statutorily required to respond to this Scottish Government consultation but will be bound by the outcome of the consultation and any resulting measures introduced by the Scottish Government. 8. Equalities Impact Assessment (EIA) 8.1 Not required. 9. Consultation 9.1 This is a Scottish Government consultation seeking the views of all stakeholders. Officers from both Planning and Housing have reviewed the consultation documents and inputted into the response at Appendix 1. 10. Strategic Assessment 10.1 The consultation is considered to be relevant to, and will help deliver, all of the Council’s strategic priorities: Our Communities – Resilient and Thriving Our Environment – A Greener Future Our Economy – Strong and Flourishing Our Council – Inclusive and Adaptable Michael Mulgrew Planning, Building Standards and Environmental Health Manager Date: 22nd April 2026 ___________________________________________________________________ Person to Contact: Michael Mulgrew, Planning, Building Standards and Environmental Health Manager, Michael.mulgrew@west-dunbarton.gov.uk
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Appendices: Appendix 1 – Respondent Information Form Background Papers: https://www.gov.scot/publications/accelerating-home- building-scotland-consultation-penalties-incentives- speed-up-housing-delivery/ Wards Affected: All