Borders housing policies savaged by national agency

by EWAN LAMB

Homes for Scotland, the body which represents housebuilders and social landlords, has attacked Scottish Borders Council's housing policies, claiming the region is missing out on positive development opportunities, while the construction industry can have "zero faith" in the local authority's latest land audit.

The allocation of land for future housebuilding is proving to be a highly contentious issue during the current examination of SBC's latest draft Local Development Plan (LDP) by Scottish Government planning reporters.

A recently approved National Planning Framework set the Scottish Borders minimum all-tenure housing land requirement over the next ten years at 4,800 units. But there have already been suggestions that this figure should be radically increased with a land requirement for 8,000 new homes being advanced by some professionals. 

SBC's 2020 Housing Land Audit [HLA] showed that the total number of completions in the past five years had peaked at 373 completions. Within the 2020 audit, there had been a decrease of 21 completions since the previous audit. 

"The completion rates overall within the Scottish Borders have been much lower than the pre-recession rates, with many of the sites under construction within the Borders at a slow rate or stalled, due to lack of developer/mortgage finance. This demonstrates the current generally weak market within the Scottish Borders, despite the large number of established sites available for development. 

The audit stated: "It should be noted that in recent years there are very few local housebuilders developing sites within the Scottish Borders. The above demonstrates the direct impact upon rural areas including the Scottish Borders as a result of the current economic climate and Covid pandemic recovery."

Those sentiments have not gone down well with Homes for Scotland (HFS) given that the trends outlined in the Borders HLA form the basis for future land allocations in the new LDP.

In a hard-hitting newly published written submission as part of the LDP examination, HFS which represents 200 member organisations, calls for an overhaul of current SBC housing development policies.

HFS warns: "Affordable housing delivery currently exceeds market housing delivery in the Scottish Borders Council area. Care must be taken in setting housing targets across various tenures, so as not to drive away private housing investment."

The scathing attack on SBC's land audit for 2020 claims it was very important to note that HFS considered the document was prepared in a wholly unacceptable manner. 

"HFS engage with 27 HLAs across Scotland each year. Scottish Borders Council was unique last year in that there was no provision for a back-and-forth between the Council and HFS following the initial submission of our comments. 

"Local authorities are encouraged to consult widely with the house building industry and infrastructure providers in the collation of the annual audit to enhance the accuracy of the data and thus its usefulness. For the 2020 HLA, the Council did not provide for a back-and-forth between the parties following the initial submission of our comments, rather seeking to publish a "finalised" audit post-haste without any further engagement. 

"Such an approach inevitably leads to less accurate programming, and an audit that the development industry can put zero faith in, in terms of its projections and transparency. As such, the development industry can ascribe no weight to the outcomes of the 2020 HLA."

The submission adds that HFS has, for some time, strongly disagreed with the Council on its approach to housing land supply. 

"Fundamentally, our concern goes beyond any analysis of numbers, to the way the Council perceives and deals with its history of seeing limited take up of site allocations. 

"As we have previously alluded to, if the Council is to see a better match between household need and demand for homes, and the supply of new homes in the future, it will need to review the cumulative impact of its policies on build costs, initiate a shift in its approach to land release to realign its suite of allocations with the market interest that does exist and introduce a more flexible land release policy that can respond not just to a technical shortfall in the land supply but to any issues arising in association with the delivery of allocated sites and other sites already in the established supply. 

"To this point, the Council has not provided a detailed analysis of the effectiveness of the remaining sites which are to be carried forward. The Council is thus missing out on positive development opportunities by not exploring in more detail the reasons behind the low take up of existing sites. Limiting the release of new sites is only an appropriate strategy if the Council has sufficient confidence those sites already allocated will be delivered in this plan period."

HFS also attacks what it describes as "the incredible position the Council has taken with regards to their strongly disputed 2020 HLA, which seeks to claim a programmed delivery of over 1,000 units for a single year within the next five years. Such a claim further undermines the validity of the Council’s HLA process. The supposed estimated level of completions represents an inconceivable figure in practical terms."

Overestimation of the potential of the effective supply will reduce the amount of additional land allocated and therefore reduce the flexibility available in the supply to address market fluctuations and other constraints to the delivery of housing, according to HFS. It adds: "There can be no confidence in the accuracy of the HLA."