Chamber and committees

Priorities for Session 6- Homes for Scotland - 29 July 2021

Dear Ariane,

STAKEHOLDER PRIORITIES

Thank you for your letter of 1 July, providing Homes for Scotland (HFS) with the opportunity to submit our views on priorities within the remit of the Local Government, Housing and Planning Committee (LGHPC).

With HFS focused on the delivery of new homes of all tenures (representing c200 organisations together providing the vast majority of new homes built in Scotland), our interests span not only the entire breadth of LGHPC responsibility but also that of other Committees such as Economy & Fair Work and Net Zero, Energy & Transport, highlighting the wide-ranging impact of housing across portfolios.

I note from the Committee page on the Parliament website that a number of organisations have been approached for feedback into the Committee’s work. I would like to recommend that you extend your reach to others within the private sector – users of the services provided by local government, housing and planning functions. I am sure that organisations such as Scottish Property Federation, Federation of Master Builders, NHBC and indeed the CBI would all be interested in contributing, having all given evidence at the previous Local Government and Communities Committee. This would hopefully provide additional voices on behalf of private sector interests, giving you a balanced view on potential priorities.

Our membership extends from UK PLCs and indigenous SMEs to Registered Social Landlords and those in the sector’s extensive supply chain, ensuring depth and breadth of knowledge and representation. This expertise is crucial in developing our policy positions, most recently reflected in our own recent Scottish Parliament election manifesto and the Role of Home Building in Scotland’s Covid Recovery plan developed during the height of lockdown last year. We draw the Committee’s attention to the following in particular for consideration in relation to its work programme:

1. Planning
(a) It is essential that the Committee scrutinises the development of National Planning Framework 4, particularly in relation to the number of new homes identified following “initial default estimates” which represented a very significant reduction from current delivery levels.

(b) Latest planning performance standards highlighted a near 55-week average decision time for major housing applications – 39 weeks more than the 16-week statutory timescale. This is unacceptable if we truly wish to tackle Scotland’s housing shortage, as the current performance only exacerbates existing problems.

It is fundamental that planning departments and those involved in the wider consenting process (eg Building Warrants and Verification, and Road

Construction Consents and Roads Bonds) be adequately resourced and incentivised in order to support the delivery of more new homes of all tenures. There should be an inquiry into how Scotland can overcome the disconnect between national housing policy and its implementation at local level.

(c) The Committee should consider how we bring about culture change at a local level so that development is considered a positive rather than opposed and that elected officials hear from all residents as opposed to vocal minorities. This would sit perfectly with the Scottish Government’s economic transformation strategy and its national challenge competition.

2. Housing and housing strategy
(a) Housing to 2040 states that “… overall we need to have many more homes than ever before” yet there is a disappointing lack of acknowledgement of the role the new build private sector will have to play in delivering this, despite it accounting for three quarters of the 22,596 homes completed in 2019.

HFS promotes a tenure-neutral approach and is clear that the housing sector must be considered as a whole system in light of the many inter-dependencies which exist. For example, not only do those HFS members operating in the private sector build their own homes to sell into the open market, they also supply the land, and often the buildings, required to satisfy affordable housing planning conditions. In addition, a large number of our members have contracting arms that build affordable housing stock directly for RSLs and councils throughout Scotland. These interdependencies mean that delivery of social housing is heavily reliant on the expertise and resource of the private development industry.

As we seek to rebuild our way out of the pandemic, it is vital that Committee members fully understand these nuances as further consideration of Housing to 2040 is undertaken.

(b) Growing the number and capacity of indigenous SME home builders is vital to increasing housing supply (particularly in rural areas) and diversity. The findings of a major HFS research project into this has 20 recommendations on how this can be achieved. How can these be taken forward?

(c) Scottish Government evidence shows that 82% of households in Scotland want to own their own home. However, following the closure of the main Help to Buy (Scotland) scheme and the subsequent closure of the First Home Fund after only five days, there is now no mechanism in place to support Scottish First Time Buyers. This places Scottish residents at significant disadvantage to their counterparts south of the border and is reflected in the growing “squeezed middle” of households who neither qualify for social housing nor can save for a large deposit for an otherwise sustainable mortgage.

3. Building Standards / Net Zero
We recognise that delivering more of the highly energy-efficient and sustainable new homes Scotland requires to meet housing need and aspiration is part of the solution to achieving a successful transition to net zero. Indeed, great improvements have already been made, with a 75% reduction in carbon emissions since 1990 baselines. For information, we ourselves are also currently undertaking significant project work to develop a routemap for industry. Going forward, we would ask Committee members to note:

(a) the need for a cross-government approach to transition as co-ordination and collaboration are essential to enabling such a major shift and allowing our industry to play its full part, in conjunction with others.

(b) member concerns regarding the speed, scale and feasibility of further programmed changes, including supply chain capacity and the resourcing and skills of local authority consenting regimes to determine new zero carbon standards especially in light of the already reported delays mentioned above.

(c) the vast bulk of housing-related emission issues pertain to existing stock and this is where primary focus should lie.

I hope the above is useful and would be pleased to discuss the points outlined in greater detail at the Committee’s convenience.