Over the past two weeks of my internship, I have been involved in various projects that have allowed me to deepen my understanding of the planning sector. One of the main projects I have been working on involved analysing the Local Development Plans (LDPs) and Housing Land Audits (HLAs) of the local authorities that cover Edinburgh and the Lothians to establish how each authority is meeting or failing to meet their Housing Land Requirement (HLR) set in their current LDPs.
The basis for my investigation was the recent Hens Nest Road judgement
[1] that essentially crystalised the point that a LDP sets out how many homes should be built in their area over the plan period and that number of new homes should be delivered over the plan period. I then looked at the National Planning Framework 4’s (NPF4’s) Minimum All-Tenure Housing Land Requirement (MATHLR) to assess how these same local authorities were going to perform against the new NPF4 requirement.
So, what did I find?
In terms of the HLR vs delivery/supply set out in the LDPs / HLAs for Edinburgh, East Lothian, Midlothian, and West Lothian, Edinburgh is the only one of the 4 local authorities that has a chance of delivering their housing land requirement by end March 2024. East Lothian might come close, but Midlothian and West Lothian will fall far short.
The Minimum All-Tenure Housing Land Requirement (MATHLR) is a component of the new NPF4, and each local authority is expected to exceed these new minimum HLRs through setting a Local Housing Land Requirement (LHLR) with a 10-year delivery pipeline. To see how the local authorities of Edinburgh and Lothians were likely to perform against the MATHLR I looked at the future development programming set out in each of the 2022 Housing Land Audits.
East Lothian, Midlothian, and West Lothian will all exceed the MATHLR as these authorities all have supply/expected completion figures that are higher than the total MATHLR in the short and medium term (years 1-3 and 4-6). However, this is not the case with Edinburgh, which will fall well short of delivery against the MATHLR in the short and medium term. Edinburgh is the only local authority looked at that has a MATHLR that is significantly higher than the HLR previously set by their LDP.
For East Lothian and West Lothian, the per annum HLR is hugely reduced by the MATHLR from that set by the LDPs. Midlothian’s has largely remained the same.
Of the four local authorities, Edinburgh is the only one that has an overall shortfall in the supply of housing set out in its LDP when held against the MATHLR from 2023-2033. This housing supply shortfall is equivalent to 3 years’ worth of the MATHLR. In contrast, if the MATHLR is applied to the other three local authorities, then all three would successfully meet the MATHLR based on their current scheduled supply. This is not to say that these authorities necessarily have sufficient land to meet their next Local Development Plan’s land requirements.
Once a LHLR is set for each authority in their next LDP, this position may change.
In Summary
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Edinburgh will likely delivery its Housing Land Requirement set in the LDP. East Lothian might just but Midlothian and West Lothian will not.
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There is a significant per annum uplift in deliverable housing land required for Edinburgh to meet the MATHLR, East Lothian and West Lothian have seen their per annum requirement reduce significantly and for Mid Lothian it has largely stayed the same.
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If the MATHLR is to be applied from the period 2023/24 onwards, then Edinburgh is the only local authority that would fail to meet the MATHLR’s requirements.
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Final Thought
If we compare the delivery of new homes in each of these local authorities in 2021/22 with the per annum rates suggested by the MATHLR then there will be an overall net reduction per annum of 830 new homes across Edinburgh and the Lothians:
My internship is at an end now, but I hope what I have found out has been interesting to you. If you wish to discuss any of the above please contact
Nicola Woodward or
Gordon Thomson in our Edinburgh office.
[1] 2023csih3.pdf (scotcourts.gov.uk)
