Consultation response by Scotland’s Towns Partnership (STP)
STP Members Feedback Summary/Collation (January 2025)
Background
The Scottish Government’s Planning and the housing emergency: delivery plan, sets out key actions the government will take so that planning plays its part in addressing the housing emergency. The delivery plan indicated that government would consider and engage widely on the potential scope for further permitted development rights, which could support housing delivery in specific circumstances.
This consultation is the first step in taking forward that commitment. In its dedicated article, the Scottish Government explains what permitted development rights (‘PDR’) are, before setting out how they’re exploring the potential expansion of PDR to streamline the delivery of homes.
STP have canvassed views from our members on the Scottish Government’s current consultation on Permitted Development Rights and its use to help address the housing emergency. As the leading voice for our country’s towns, STP is submitting this response to the consultation after reasonable input from our wider membership and internal teams.
Response Summary
Following the January deadline for input a set of themes, key points and quotes are outlined below to support the consultation feedback.
- Key questions decision makers need to be asking before they develop a site:
Need to assess risks and whether these are manageable; whether the housing planned matches local need and whether relaxation of PDR is likely to be detrimental to the ability of local authorities to plan development and shape their local communities in the long term
Quote:
‘We need to learn the lessons from experiences globally, where there are PDRs or PDR equivalents that allow the conversion of many different types of buildings, including shops and offices, to dwellings.’
- Significant related issues raised in addition to Permitted Development Rights:
PDR alone will not tackle all the related issues including those of unsafe homes, lack of clarity on other safety regulations such as responsibility for decontamination, motivation of developers to provide more needed but less profitable solutions. Will there be a focus on infrastructure issues such as flooding or reasons that slow the reuse of empty homes.
Quote:
‘Many thanks to STP for wishing to put pen to paper on this. What a complicated subject for the ‘lay citizen’, even to understand the function of a Local Place Plan (or Community Action Plan). ……. PDR stance may be insufficient…’. (in addressing issues summarised).
- Availability of sites:
Owner responsibility re derelict sites and not enough sites where housing can be built – affordable and otherwise. The number of derelict and abandoned brown-field sites in our towns and cities.
Quote:
‘Aberdeen is blighted by several prominent city centre sites where owners have done nothing for years. Quite frankly this shouldn’t be allowed, and ownership should carry greater responsibilities and obligations.’
- Risks and opportunities involved in repurposing office/commercial real estate:
Although plans should be approached with caution so as not to overheat the market development of converted properties should include a mix of rental and owned property.
No more development of green sites.
We need to ensure that we avoid hollowing out town centres by permitted development rights and focus attention on secondary, above ground and NOT at the heart of the town centre. Removing the commercial ground floor units to develop housing is not the answer in town centres and does not serve the purpose of encouraging mixed use and vibrant places.
Quote:
‘I would like to see some new framework created to allow for the conversion of former shops and spaces above them into low-cost residential premises, with the minimum of planning restrictions, to bring life back into struggling town centres.’
- Affordability of Town Centre Living and development:
Considerations of VAT and Council Tax exemptions, priority given to town centre living, PDR changes to run in tandem with taxation.
Quote:
‘High accessibility locations should therefore become a trigger point for relaxation of permitted development rules. Accordingly, those sites which have lower accessibility require more detailed scrutiny for impacts on roads, infrastructure, schools and health facilities. Low accessibility homes should be charged VAT to enable government to support the extra infrastructure required whereas town centre housing should be VAT exempt as much of the essential infrastructure is already in place.
Rather than VAT perhaps a ‘carbon tax’ would be a more apt way of describing the tax regime SG should consider. ‘
Conclusion
STP welcome a coordinated approach to permitted development rights particularly in relation to smaller scale developments. STP is working as part of a collective in de-risking town centre living and providing a series of recommendations and workstreams that will expedite the living agenda in our towns. STP (Scotland’s Town Partnership), SFT (Scottish Futures Trust), A&DS (Architect and Design Scotland), SLC (Scottish Land Commission) are exploring a Pan- Local Authority model in aggregating a selection of small sites to provide more attractive development opportunities for SME developers. This work is also under-pinned with reviewing investment and funding models and re-working new delivery mechanisms against a criteria of five conditions of success. These conditions include, leadership and collaboration, holistic approach to planning and placemaking, partnership working, risk mitigation and funding and investment models.
A key part of STP’s role is in the delivery and support of the town centre action plan, detailed on the report “The New Future for Scotland’s Towns”. We would like to continue to support and collaborate on this area as is a key part of our delivery of sustainable towns and places that are fit for the future.
