Consultation Responses

This consultation is seeking views on a Scottish Building Safety Levy which will be used to fund the Scottish Government’s domestic property Cladding Remediation Programme. The levy will apply to all new (private) residential development and is anticipated to generate up to £30m annually to address some 1,000 high rise and 5,000 medium rise buildings within the current scope of the programme. 

The government is proposing to introduce a 28-day notice to quit period to allow students to terminate their leases early before the end of the academic year. As this survey is targeted at providers, we are unable to answer most questions. Instead, we provide a summary of the unintended consequences should a 28-day notice to quit period be introduced. We highlight the special nature of PBSA, illustrating how a blanket policy that allows students to terminate their leases early is likely to substantially increase financial risk for investors, developers, funders and University partners. In our response we also illustrate the unintended consequences for the broader private rented sector (PRS). 

We submitted our response to Scottish Government's consultation on determining the principles of Scottish equivalent of Passivhaus. We have highlighted our member concerns regarding the current supply chain capacity, skills and rising costs of construction which are likely to be a barrier to enforcing the new standard. Read more here.

We responded to Glasgow's Tall Building design guide consultation, which looks to guide developers and planning officers on developments above 11m in areas set in Glasgow's city centre Strategic Development Framework. Members are broadly supportive of this guidance and embrace high density development including tall buildings to provide choice, encourage brownfield developments.

Read our full response here, we highlighted the unintended consequence that the ILS could discourage investment in Scotland. The introduction of this levy will add to current and proposed developer taxes. We relayed our further concerns over clarity on how the levy is to be calculated and the definition of 'infrastructure' that it will be contributing towards. This is a major piece of legislation which is bound by a sunset clause ending in Summer 2026. We have argued that the current health of the markets and development industry has to be considered but that this was not reflected in the discussion paper.

This consultative draft Supplementary Guidance provides an overview of the proposed approach to how the Council will seek developer contributions for the infrastructure set out in City Plan 2030. City Plan 2030 will be the Council’s next local development plan and they are currently at the stage where they have notified Scottish Ministers of the Council’s intention to adopt the plan. Whilst we do understand the need and importance of developer contributions towards infrastructure, our response highlights some concerns we have with the Council's approach. 

The New Build Heat Standards came into force on 1 April, 2024, which affects the type of heating system that new-build homes and properties are allowed to use. Homes and buildings are not allowed to use polluting oil and gas boilers. Instead, they must use climate-friendly alternatives like heat pumps and heat networks. Following the backlash on secondary heating systems for Rural and Island communities, the previous Minister for Climate Action asked for review. SPF responded to their discussion paper on this review.

Meanwhile, Scottish Ministers have issued a temporary direction to allow wood burning stoves and other bioenergy (and peat) heating systems to be installed in new homes. The direction does not apply to non-domestic buildings. 

As requested by the Scottish government, the SLC is investigating how compulsory owners' associations could work for tenements blocks. While we welcome measures to ensure there is coordination and responsibility for work to be carried out in common parts, we have highlighted logistical and financial issues particularly for commercial unit owners within tenements. 

This consultation is seeking views on potential options to reform the Tenancy of Shops (Scotland) Act 1949. The Act enables some retailers to extend their leases for up to an additional year but there is an ongoing debate as to whether the Act still performs as intended. Read our response below. 

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.