Housing Land Requirement – Conclusion

As demonstrated through case studies, there are a significant number of local authorities performing over and above the five year requirement based on the average method. However, this is not taking into account any under delivery from previous years in the plan period and therefore, is not showing a realistic picture of whether Local Planning Authorities are set to meet their overall housing need by the end of the plan period. This method ignores under performance and also over-performance in previous years. In the case of the latter, in certain circumstances it might be disadvantageous for a LPA to facilitate the delivery of homes in advance of the programming in the HLA as this might create a shortfall in future years.

 

The residual method takes into account past performance in previous years and sets a five year requirement based on meeting the overall housing need by the end of the plan period.

 

Although the recent judicial review and petition against the recent changes to Scottish Planning Policy has been upheld and thereby reversing the 2020 changes to SPP and removing PAN 1/2020, the decision was based on the unfairness of the consultation rather than the method itself being unsound.  It is reasonable to assume that the average method might be reintroduced as part of NPF4. If the average method is to be the future method of calculating the requirement for assessing whether a Council has a 5 year housing land supply, it will ultimately lead to an incomplete picture in performances and a number of authorities not meeting their overall housing land requirement.

 

Lichfields’ view is that the average method does not provide a robust approach to calculating the five year housing land requirement and should not be taken forward in any future policy. Any standardised method ultimately adopted needs to look at the bigger picture and calculate the 5 year supply of effective housing land required which will ultimately lead to the overall housing need for the whole plan period being met.