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Item 6 - Accelerating Home Building in Scotland

West Dunbartonshire Council · 22 April 2026
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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