From: Sent: 04 August 2017 15:07 To: Subject: LDP-390-2 Further Information Request 16 Attachments: 2017 08 04 - HfS Response to FIR 16.pdf See attached response from Homes for Scotland regarding FIR 16. Kind regards Principal Planning Advisor Homes for Scotland 5 New Mart Place, Edinburgh, EH14 1RW Tel: Mob: E-mail: Web: www.homesforscotland.com Homes for Scotland’s 6th Annual Conference will take a hard-hitting look at where the housing industry is now, where it goes next and how it gets there 10 years on from the Scottish Government's Firm Foundations "discussion document". Join us at this leading housing event on 1 November – click on the logo below to find out more and book your place. Early bird HFS member discount ends 18 August! ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________ *********************************** ******************************** This email has been received from an external party and has been swept for the presence of computer viruses. ******************************************************************** 1 Planning and Environmental Appeals Division The Scottish Government 4 The Courtyard Callendar Business Park Falkirk FK1 1XR By Email to: M 04 August 2017 Dear PROPOSED STIRLING LOCAL DEVELOPMENT PLAN THE TOWN AND COUNTRY PLANNING (DEVELOPMENT PLANNING) (SCOTLAND) REGULATIONS 2008 FURTHER INFORMATION REQUEST 16: ISSUES 3 SETTING THE LAND REQUIREMENT FOR HOUSING & 4 HOUSING LAND POLICIES In response to the Reporter’s query set out within FIR 16, Homes for Scotland is aware that the Scottish Government has stated an aim to deliver 50,000 new affordable homes during the current Scottish Parliament’s term. The Scottish Government expects to achieve this through provision of funds to local authorities in response to each local authority setting out its aspirations in their Strategic Housing Investment Plans. Whilst not all of the funds may necessarily result in new homes being built, i.e. buy backs of previous right-to-buy properties (a point that had been clarified recently by the Minister), it is anticipated that most of the funds will be directed towards new build projects. FIR 16 refers to a fund that has been made available by the Scottish Government, and Homes for Scotland understands that this relates to the Scottish Government seeking to ensure the 50,000 target is met by confirming what monies will be available to local authorities between 2018 and 2021 to assist with the delivery of affordable homes. Homes for Scotland understands that the resource allocations to each local authority area have been determined by the needs-based Strategic Housing Investment Framework (SHIF) model agreed with COSLA in 2012; that model allocates the budget in accordance with the size of each authority (measured by the total number of households of all tenures), adjusted by four agreed indicators of housing need. Therefore, in addition to the £6.012m made available to Stirling Council for affordable housing during 2017/18, the recently announced agreed funding for affordable housing in Stirling Council to 2021 is as follows: 2017/18 2018/19 2019/20 2020/21 Total Stirling £6.102m £7.965m £9.011m £9.614m £32.692m Source: https://beta.gov.scot/publications/resource-planning-assumptions-to-councils-2017-2018/ and https://beta.gov.scot/publications/long-term-resource-planning-assumptions-to-councils-2018-2019-to-2020-2021/ The current Strategic Housing Investment Plan (SHIP) for Stirling has the following figures for requested funding from the Scottish Government: 2017/18 2018/19 2019/20 2020/21 Total Stirling £7.048m £4.420m £4.042m £4.602m £20.112m Source: http://www.stirling.gov.uk/__documents/housing/managing-tenancies/lhs-information/ship-templates-2017-2022.pdf These figures therefore demonstrate that 62.5% more funds are now available to Stirling Council than the Council has currently expected or planned for. The Council’s current SHIP has predicted that some 374 completions would be achieved during these 4 years which therefore equates to an average assumed cost of c£54,000 per unit. Notwithstanding this is a very simplified calculation, the additional funding could then potentially generate a further 230 new affordable homes between 2017 and 2021 (on average 58 per annum). Whilst it is presently unclear how Stirling Council will respond to this opportunity (a 62.5% increased in available funding), it would be expected that the funds will be used by Stirling Council to deliver more affordable housing than presently planned. Any additional affordable homes may come forward from existing allocations within the Local Development Plan or they may be realised on brownfield sites within urban areas. These additional funds may also support the delivery of constrained sites where viability has been an issue but they could also necessitate new sites being found to ensure the funds can be used. Whatever the response to the additional funding on the ground, it must be taken as a signal that the Scottish Government recognises that there are significant unmet housing needs within the Stirling area (derived from their SHIF modelling) and are responding through their resource allocation. It can also be interpreted as a signal for Stirling Council to do more to meet housing need and demand in general. However, the Examination Hearing heard from Mr Holder that the figures for affordable housing need and demand as set out within the HNDA were significantly higher than what has been brought forward as part of the Local Development Plan’s Housing Supply Target. Part of the justification for the much reduced target was the inability for Stirling Council to deliver sufficient new homes to meet those needs and demands. The predicted affordable housing output as set out within the Agreed 2016 Housing Land Audit is generally in line with or a little above the annualised affordable housing element of the Local Development Plan’s Housing Supply Target. Therefore, given that more funds than previously expected have been confirmed to 2021, the Council’s argument to discount the Housing Supply Target has been diminished in a small way. Accordingly, Homes for Scotland would suggest that a modest increase in the Housing Supply Target, that equates to c60 units per annum or around 600 new homes between the date the Plan is adopted and the end of the Plan period, can be justified. I trust the above is of assistance to the Reporters in formulating their conclusions in the Local Development Plan but if there are any queries, do not hesitate to contact me. Yours sincerely Principal Planning Advisor 2 From: Sent: 04 August 2017 15:07 To: Subject: LDP-390-2 Further Information Request 17 Attachments: 2017 08 04 - HfS Response to FIR 17.pdf See attached response from Homes for Scotland regarding FIR 17. Kind regards Principal Planning Advisor Homes for Scotland 5 New Mart Place, Edinburgh, EH14 1RW Tel: Mob: E-mail: Web: www.homesforscotland.com Homes for Scotland’s 6th Annual Conference will take a hard-hitting look at where the housing industry is now, where it goes next and how it gets there 10 years on from the Scottish Government's Firm Foundations "discussion document". Join us at this leading housing event on 1 November – click on the logo below to find out more and book your place. Early bird HFS member discount ends 18 August! ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________ *********************************** ******************************** This email has been received from an external party and has been swept for the presence of computer viruses. ******************************************************************** 1 Planning and Environmental Appeals Division The Scottish Government 4 The Courtyard Callendar Business Park Falkirk FK1 1XR By Email to: 04 August 2017 Dear PROPOSED STIRLING LOCAL DEVELOPMENT PLAN THE TOWN AND COUNTRY PLANNING (DEVELOPMENT PLANNING) (SCOTLAND) REGULATIONS 2008 FURTHER INFORMATION REQUEST 17: ISSUES 3 SETTING THE LAND REQUIREMENT FOR HOUSING & 4 HOUSING LAND POLICIES Further to the Reporter’s query as set out within FIR 17, Homes for Scotland was aware of the Notice of Intention issued by the DPEA regarding Appeal reference PPA-360-2046. This Notice was referred to in the Homes for Scotland closing statement (paragraphs 12 and 57). This Notice was also referred to in the Homes for Scotland response to the Council’s reply to FIR 03 (paragraph 7.2). The Council was asked about this Notice during the Examination Hearing and in response it was accepted that the site would add to the predicted housing completions coming forward within the area. Homes for Scotland agree with this perspective. However, what the Notice demonstrates very clearly is the inconsistency of the Council’s approach to calculating land supply. Within their submissions to the Appeal, the Council accepted that there was a shortfall in the effective land supply for Stirling (paragraph 6 of the Notice); that calculation being based on the 2015 Housing Land Audit and a compounded approach being used. Homes for Scotland also note that the position of Stirling Council in respect of planning applications