Consultation Responses

Read here our response to National Outcomes consultation

SPF responded to the consultation on Housing (Scotland) Bill Financial Memorandum which will inform the Scottish Parliament's Finance and Public Administration Committee on the financial implications of this bill. SPF has highlighted industry experts comments based on their proven investments south of the border that over ten years there is some £4.5bn of economic value for the Scottish economy that is at risk if we get this Bill wrong. Read the full response below. 

SPF submitted response to Investing in Planning consultation, it is aimed at performance fees and resourcing. We have highlighted member views on certainty for applicants, faster timescales and upskilling staff. You can read the full response here. 

SPF responds to the development plan amendment regulation consultation, we mainly relayed the concerns over timeline and clarity on what would 'trigger' these amendments. Read the full response below:

SPF responded to Masterplan Consent Areas regulation, we agree with the overarching principles of MCA but in the consultation response we have highlight the need for more clarity and guidance on how it will fit with wider development plans and amendments. Also touch upon major concerns such as fees, resources, and the 10 years timescale. Read the full consultation response below:

This is our response to Housing (Scotland) Bill Stage 1 Consultation to the Scottish Parliament's Local Government, Housing and Planning Committee. Our main concern is the detrimental impact of the rent control proposals on investment in the supply of new rental accommodation in Scotland.

We continue to have our reservations on any form of rent control policy because the evidence suggests that rent controls have not succeeded in attracting or sustaining new investment into the supply of new rental accommodation in other European countries. The impact of the emergency rent control legislation in Scotland also confirms this. However, in our response we have outlined that if rent controls are to be introduced, the system would require a number of elements to maintain some form of investment in Scotland.

We have suggested the need for a clearly defined rent control mechanism to include a provision for index-linked inflation and be subject to a sensible cap (suggested CPI +1, capped at 6%). We also advocate that rent controls should be linked to the tenancy not the property and requirement for accurate rental data to inform the need to enact controls and to ensure future policy is evidence based.

Read the full response to the consultation below

SPF Responded to the Edinburgh Heritage Plan highlighting the importance to collaboration in with developers, investors, stakeholders and the wider community to transmit the value of heritage and conserve it. We widely support the management and action plan to safeguard the city's Outstanding Universal Value. 

SPF responded to the Heat in Buildings bill consultation highlighting our membership views on the challenges in achieving the target of decarbonising Scotland's built environment by 2045. We relayed member concerns over the proposal of achieving MEES targets by PRS landlord by 2028 and owner occupiers by 2033 in the absence of sufficient technology, skills, manpower and most importantly the funding in carrying out these changes. You can read our full response here.

Read our response on the government's proposals to strengthen sanctions against non compliant building standards.  

SPF submitted a response to the Glasgow Co-Living Guidance. We highlighted membership views on extending Co-Living guidance beyond the city centre boundary. We felt the space requirement mentioned is overly prescriptive and we suggested flexibility will encourage the provision of better quality or cost effective options to occupiers. We also highlighted potential issues with imposing a 6-month tenancy period. Read our full response here.

The accessible homes consultation looks at reforming various aspects of Part 1 of the Housing for Varying Needs design guide as well as introducing a Scottish Accessible Homes Standard to be applicable for all new builds and those which are converted from non-residential to residential. Read our response here. 

This Bill seeks stakeholders views on how to deal with unsafe cladding on buildings. The Bill concerns buildings which are multi-residential, constructed or refurbished between 1 June 1992 and 1 June 2022, over 11 metres high and with external wall cladding system. The key proposals include the creation of a Cladding Assurance Register and to establish a responsible developers scheme where developers responsible for using unsafe cladding will be required to cover the costs of remediation work.