Democracy Spraffa

Item 6 - Appendix 1

West Dunbartonshire Council · 22 April 2026
Back to Planning Committee — 22 April 2026 and its agenda

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Respondent Information Form
Accelerating home-building in Scotland
A consultation on incentives and penalties to speed up housing delivery
Please Note: this form must be completed and returned with your response.
Please indicate how you wish your response to be handled and, in particular,
whether you are content for your response to published. If you ask for your response
not to be published, we will still take account of your views in our analysis but we will
not publish your response, quote anything that you have said or list your name. We
will regard your response as confidential, and we will treat it accordingly.
To find out how we handle your personal data, please see our privacy policy at the
bottom of the page. By submitting your response to Scottish Government you agree
to our privacy policy.
1. What is your name?
2. What is your email address?
Your email address will never be published. Your email address will be used if you
give permission below to be contacted again in future about this consultation.
3. Are you responding as an individual or an organisation? 
Individual ☐
Organisation ☐ 
4. What is your organisation?
If responding on behalf of an organisation, please enter the organisation's name
here.
ITEM 6 - APPENDIX 1

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5. The Scottish Government would like your permission to publish your
consultation response. Please indicate your publishing preference:
Publish response with name ☐
Publish response only (without name) ☐
Do not publish response ☐
Information for organisations only:
The option 'Publish response only (without name)' refers only to your name, not your
organisation’s name. If this option is selected, the organisation name will still be
published.
If you choose the option 'Do not publish response', your organisation name may still
be listed as having responded to the consultation in, for example, the analysis report.
6. Do you consent to Scottish Government contacting you again in relation to
this consultation exercise?
Yes ☐
No ☐
7. I confirm that I have read the privacy policy and consent to the data I provide
being used as set out in the policy.
You can view the privacy policy here: Privacy - gov.scot (www.gov.scot)
I consent ☐

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Questionnaire
Question 1
Could fiscal incentives offering relief to other charges help to accelerate build-out
rates? 
☐ Yes
☐ No
☒ Unsure
Please explain your answer.
Question 1a
Which charges / taxes / levies could the incentives be applied to?
Please explain your answer.
Question 1b
Should relief be in the form of full exemptions or variable rates?
☐ Full exemptions
☐ Variable rates
The Council is unsure that such an approach would be beneficial to the development
industry to the extent that development would be accelerated. Development viability
and programming is often complex and arises from various factors such as
infrastructure availability, financial cash flow issues and general industry
workforce/material capacity. Additionally, market issues arise as it is a commercial
decision as to where, and how fast, sites are built out taking account of competitors
activity.
The Council would also express concern that such an approach would lead to land not
coming forward within Local Development Plans or a stall in sites gaining planning
permission. This would seem to go against an outcome of delivering more homes
faster.
Please see response to Q1.

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Please explain your answer
Question 1c
Could a tax impact differently on different types of land owners?
Please explain your answer.
Question 1d
Please provide any evidence of how fiscal measures linked to other charges would
impact development finance to influence built out rates.
Question 2
Please see response to Q1.
Please see response to Q1.
Please see response to Q1.

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Should we introduce a tax on sites which have been allocated for residential
development and/or have permission for homes, but are not being built out as
expected, as set out in option 1? 
☐ Yes
☐ No
☒ Unsure
Please explain your answer.
Question 2a
Should this apply to allocated sites, sites with permission, or both?
☐ Allocated sites
☒ Sites with permission
☐ Both
Please explain your answer.
Question 2b
How should the tax be calculated?
Whilst the Council is generally supportive of measures to increase build out rates to
assist with the housing emergency, the Council is not convinced that a tax on sites that
have been allocated, or have planning permission, would be beneficial overall. It is not
clear in which circumstances a punitive tax would be appropriate as there are multiple
reasons that a site may not progress, some which are in the control of the developer
and some which are not. A concern arises that such sites would not come forward for
the Local Development Plan or to gain consent. However, if such a tax is taken forward,
the Council would strongly suggest that this should only apply to sites with planning
permission. 
We would also caution that NPF4 requirements are frequently cited by developers as
affecting feasibility, any new taxes may stall development rather than accelerate it.
As Q2 above, whilst the Council is unconvinced that such an approach would ultimately
be beneficial, should it be introduced we would suggest that this should only apply to
sites with planning permission to ensure that the supply of land through Local
Development Plans is not impacted. Care would need to be taken as to how permission
would be defined, for example would this relate to Planning Permission in Principles
as well as Full Planning Permission or only be applicable to Planning Permission in
Principles at the Matters Specified in condition stage. Additionally, would other
consents such as Building Warrants and technical consents from utility providers be
included in this definition?

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Please explain your answer. 
Question 2c
Who should be required to pay the tax?
Please explain your answer. 
Question 2d
Should the tax operate as a local or a national tax?
☒ Local tax
☐ National tax
Please explain your answer.
Question 2e
How should any income be used?
Please explain your answer.
The Council considers that the tax should be payable by the developer of the site rather
than the landowner, otherwise such an approach may disincentivise the release of
land. Additionally, as legally any developer can apply for planning permission on land
they do not own, subject to the statutory notification requirements, it would not be
reasonable to enforce a tax on the landowner.
The Council would support this tax being retained at the local level. Whilst further
discussion would be required, there is potential that any monies raised by the tax is
reinvested in Council workstreams to enable housing development, for example by
being reinvested into housing supply workstreams such as empty homes programmes,
the forward funding of infrastructure to unlock wider local capacity or by investment in
planning and building standards services to bring development forward quicker.
The Council does not have a set view on how the tax should be calculated but some
suggestions in the consultation that would appear to be reasonable to explore such as
a % tax of market value and having defined areas in which the tax should be applied.

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Question 2f
Please provide any evidence of how a tax connected to sites allocated or permitted
not being built out would influence build-out rates.
Question 3
Should we bring forward powers for reporting on development progress and powers
to intervene where it is considered to be unreasonably slow, as set out in option 2?  
☒ Yes
☐ No
☐ Unsure
Please explain your answer.
Question 3a
Should this include creating a legal framework for reporting on development progress?
☒ Yes
☐ No
☐ Unsure
Please explain your answer.
Please see answer to 2d.
The Council does not have any such data available but the consultation response
refers to work in England and Wales and would suggest that data from those legislative
frameworks are reviewed for impact before any such process is introduced in Scotland.
The Council would broadly support the inclusion of formal reporting of development
progress.

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Question 3b
Should there be a power for planning permission to be revoked, without compensation
being payable, where reporting demonstrates that progress is unreasonably slow?
☐ Yes
☐ No
☒ Unsure
Please explain your answer.
Question 3c
Yes, the Scottish Government should however look to tie this in with annual housing
land audits as development progress is already assessed through this mechanism with
many authorities issuing Developer Intention Surveys. It would be more practical for
authorities to collect this in one go annually rather than annually from the issuing of any
individual consent. The onus to respond to this request should be on the relevant
landowner/developer/agent.
Pace of development is difficult to gauge as what is a fast build out rate in one market
area would not be fast in another. The planning service when carrying out forecasting
through the Housing Land Audit process makes use, amongst other data, of Homes
for Scotland guidance which sets out reasonable build out rates split by urban/rural and
by flat/houses. Whilst this guidance is useful it is not prescriptive and delivery rates can
be affected by many different factors such as commercial decisions, availability of
infrastructure and wider economic/supply issues.
The Council suggests that it may be more reasonable to introduce shorter time periods
for implementation of planning consents in specific circumstances, such as where a
site has been approved on a non-allocated site.
The Council is unsure that this mechanism would be effective. Planning legislation
already allows for planning permission to be revoked but the Council would caution the
use of such an approach except in very rare exceptional circumstances. Revoking
planning permission for one developer may seem attractive, however, it is unclear how
this would enable faster consent as it would mean that any other developer who wanted
to purchase the site would then have to start completely from scratch through the
planning process. Whereas currently a stalled site would have the benefit of an extant
consent that, in theory, could be picked up by any future developer to continue build
out. The Council do consider though that this approach could work in a very specific
circumstance where a stalled consent could be revoked to allow an alternative site to
progress. This would be beneficial in terms of forecasting infrastructure capacity as an
extant consent could in theory come back online at any point so the capacity has to be
“reserved”. We would recommend that the Scottish Government would need to
carefully consider the circumstances where this could apply.

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How would the pace of development be set and agreed – for example how would
reasonable-ness be measured?
Please explain your answer. 
Question 3d
Please provide any evidence of how reporting on development progress would
influence build-out rates.
Question 4
Should we bring forward legislation to amend the development hierarchy, to enable us
to introduce more streamlined planning processes on planning applications for smaller
sites, as outlined in option 3?
☐ Yes
☒ No
☐ Unsure
It is unclear how mandatory reporting would directly lead to faster build out rates but it
would be beneficial to have clear and consistent mandatory reporting in order for
completion rates and future forecasting to more accurate in the future. Whilst many
developers and Homes for Scotland engage with Planning Authorities through the
Housing Land Audit, not all provide responses to Developer Intention Surveys and not
all Planning Authorities ask for them.

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Please explain your answer.
Question 4a
How many categories should be defined by the development hierarchy, and what size
of development should these cover? For example, four categories, that define major,
medium, small and very small developments. 
Question 4b
What are your views on, and do you have any evidence relevant to whether creating
more categories in the development hierarchy might have an overall effect of speeding
up or slowing down build-out of housing?
Whilst the Council is supportive of SME developers and the contribution to not only the
economy but also the response to the housing emergency, in planning terms, a
developments impact is the developments impact, irrespective of the size of the
developer. NPF4 is clear that development should be well designed and mitigate its
negative impacts and whilst a proportionate approach should always be taken, and the
Council is supportive of such an approach, we consider it more reasonable and
practical to apply this on a site by site basis taking account of the particular
challenges/opportunities of that site, rather than a blanket legislative approach.
However, the Council would in general be supportive to streamlining requirements and
processes where it still results in appropriate development. This could be perhaps
better explored as a wider review of the development hierarchy as a whole and
introduce a new “medium” thereshold that sites between a local and a major.
The Council would also wish to resit any impact arising from any reduced requirements
that would negatively impact on placemaking and quality of development. This may
lead to longer term issues arising from poor placemaking.
The Council has no relevant evidence to support either view. Removing requirements
for SME’s on the face of it would appear to favour the view of speeding up delivery,
however the Council would caution the Scottish Government that housing supply
should not be reduced to a ‘numbers game’ and there is still a requirement to ensure
that quality placemaking is achieved and that developments appropriately mitigate their
negative impacts, be that on the environment or infrastructure.
See response to Q4.

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Question 4c
What are your views on whether we should review and rationalise policy requirements
for smaller housing sites, or introduce a new rules based policy for smaller housing
sites? 
Question 4d
Do you think that further advice on planning application information requirements
would support faster delivery of housing on smaller sites?
☒ Yes
☐ No
☐ Unsure
Please explain your answer.
Question 4e
Do you think there are any further options that creating more categories in the
development hierarchy might open up, further to those outlined in option 3?
☐ Yes
☒ No
☐ Unsure
Please explain your answer.
Please see response to Q4.
The Council is of the view that revisions to legislation to amend validation standards is
required rather than just advice. Whilst advice could be helpful, Heads of Planning
Scotland validation guidance is used by authorities and many authorities have
prepared their own guidance, however there is a significant gap between what is legally
required to validate an application and the actual requirements in order to assess
against local and national Development Plan policies. This gap should be closed to
provide clarity all stakeholders (developers, communities and Planning Authorities) as
to what is required to make a competent planning decision. The Council considers that
such an approach would reduce conflict during the processing of applications and
would very likely lead to faster decision making as all parties would be clear up front
about what information is required.

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Question 4f
Do you think that this measure would have any particular benefits for SME
housebuilders?
☐ Yes
☐ No
☒ Unsure
Please explain your answer.
Question 5
Do you think that encouraging more diverse housing outputs across the pipeline of
deliverable housing land would increase the pace of build-out?
☐ Yes
☐ No
☒ Unsure
Please explain your answer.
Please see response to Q4.
In general, SME housebuilders, and others, could benefit from streamlining and clarity
on requirements.

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Question 5a
Should we use legislation to require a diversity of housing types and tenures on sites
above a certain threshold?
☒ Yes
☐ No
☐ Unsure
Please explain your answer.
Question 5b
Do you think that this measure would have any particular benefits for SME
housebuilders?
☐ Yes
☐ No
☒ Unsure
Please explain your answer.
Further to the response to Q5, should such an approach be taken forward it should
only apply to larger strategic sites. An appropriate threshold may vary by Planning
Authority area but 500 or 1,000 may be appropriate.
The Council is supportive of the principle of this approach but we are concerned that
there are practical limitations that may end up discouraging market investment, which
would reduce development output. We also consider that whilst in one way a blanket
approach would be clear and consistent, Scotland does have very diverse local
housing markets. Should such an approach be introduced we would ask the Scottish
Government to explore how this could be linked to existing local Housing Need and
Demand Assessments, Local Housing Strategies and the Evidence Report
underpinning Local Development Plans. The Council would raise a general point that
as with all such studies and evidence that may change outwith Development Plan
timescales, it would need to be made clear how planning policy or legislative
requirements would adapt to this change and when.

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Question 5c
Please provide any evidence of how increasing diversity would influence build-out
rates.
Please explain your answer.
Question 6
The Council does not have any such evidence, but we would support diversity of
housing to ensure that needs and demands as set out in Housing Need and Demand
Assessments and Local Housing Strategies are met. On the face of it, providing for this
need would suggest that sales rates, and therefore build rates, would be faster.
One option the Council would suggest, is exploring how allocations in the Local
Development Plan could be granted an alternative status, perhaps similar to Planning
Permission in Principles, with applications then being focused on details of design,
similar to Matters Specified in Condition applications. With Development Plans
becoming more delivery focused, increased scrutiny of sites at the site assessment
stage and Development Plans setting out more in the way of site requirements for
development, it would seem appropriate that allocations are granted some enhanced
status to provide more certainty to developers as to the acceptability of sites and the
design and layout parameters. This could work alongside existing provisions for
Masterplan Consent Areas.
A frequent comment to the Council that affects viability is that parts of the area are
deemed ‘not marketable’ by the industry, thus affecting speed of delivery of Local
Development Plan allocations. It would be beneficial if Scottish Governement could
work with developers to understand these low market areas and what further could be
done to unlock development, particularly on brownfield sites.
Planning Authorities are already under considerable pressure in both Development
Management and Development Planning. Scottish Government should consider the
impact of future changes to accelerate housebuilding and plannings role and recognise
that further funding to planning authorities is required.

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Do you have any other suggestions for measures which could use levers available, or
which could be put in place through the planning system, to deliver more homes at
pace?
Question 6a
Please provide any evidence of how these potential measures would influence build-
out rates.
The Council does not have any evidence currently on this matter but consider that it
could have a positive impact on build out rates by reducing procedural uncertainty
without prejudging detailed consideration of the design and impact of the development.