Consultation Responses

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. 

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