Item 6 - Appendix 1
West Dunbartonshire Council · 22 April 2026
Back to Planning Committee — 22 April 2026 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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1 Official 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 If you ask for your response not to be published, we will still take account of your views in our analysis but we will not publish your response, quote anything that you have said or list your name.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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2 Official 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 Please indicate your publishing preference: Publish response with name ☐ Publish response only (without name) ☐ Do not publish response ☐ Information for organisations only: The option 'Publish response only (without name)' refers only to your name, not your organisation’s name.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 If you choose the option 'Do not publish response', your organisation name may still be listed as having responded to the consultation in, for example, the analysis report. 6.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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3 Official 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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4 Official 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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5 Official 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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6 Official 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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7 Official 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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8 Official 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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9 Official 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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10 Official 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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11 Official 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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12 Official 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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13 Official 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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14 Official 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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15 Official 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.