Technical Notes 2026, Issue 75 - Local Development Plan 3 (LDP3) Evidence Report – Housing Land Requirement Scenarios

• The purpose of this Technical Note is to provide an update to Members on the work being undertaken as part of the resubmission of the Evidence Report for Local Development Plan 3 (LDP3), following approval of the revised Evidence Report at Council on 02 April 2026.  In line with the recommendations set out in Council report EDC/009/26/SM, officers have been undertaking targeted engagement with the Planning and Environmental Appeals Division of the Scottish Government (DPEA) and key stakeholders ahead of resubmitting the Evidence Report for Gate Check Assessment
  
  Background
  
  
• As a result of the Reporter’s determination in November 2025 that the first submission of the LDP3 Evidence Report (see Technical Note 2025, Issue 191) was insufficient, officers have worked on a revised Evidence Report that can be submitted to the Planning and Environmental Appeals Division (DPEA) to undergo a further Gate Check assessment.  To ensure that the revised Evidence Report was turned around as quickly as possible, officers focussed on addressing the key issues identified by the Reporter, primarily relating to education and healthcare infrastructure and the indicative Local Housing Land Requirement 
• Updated household projections with a base date of 2022 were published by NRS in December 2025.  The projections provide a trend-based projection of the total number of households in each authority area annually up until 2047.  The projections directly inform the ‘newly forming households’ element of calculations used to determine the Minimum All-Tenure Housing Land Requirement (MATHLR) in National Planning Framework 4 and subsequently the I-LHLR
• The Council received a letter from the DPEA on 18 March 2026 drawing attention to the ‘Evidence Reports and Gate Checks: Action Plan and Advice’ published by the Scottish Government in February 2026.  The letter states that the advice references the new household projections as a relevant source of updated evidence and that addressing this new information, including undertaking engagement with stakeholders, in advance of resubmitting the Evidence Report will aid progress through the Gate Check to avoid potential delays.  This letter was received in the period where officers were preparing to the take the revised Evidence Report to Council for approval on 02 April 2026 (report ref. EDC/009/26/SM)
• Whilst the revised Evidence Report prepared by officers sought to address the new NRS projections, this had been done before the DPEA advice and letter had been published/received by the Council and therefore did not fully satisfy the requirements of the new Advice.  As such the Council report recommended that drafts of key parts of the Evidence Report should be submitted to the DPEA, to provide an opportunity for provision of advice by a Reporter on whether the amendments made to the revised report have addressed the Reporter’s recommendations set out in their November 2025 Assessment Report and any newer pertinent information, or if there are any further matters that they recommend the Council should address before the Evidence Report is re-submitted.  The report also recommended that specific targeted engagement with stakeholders be undertaken before resubmission, in line with the comments in the DPEA letter regarding engagement with stakeholders.

Informal Submission to the DPEA

• Following approval of the Evidence Report at Council, officers sent the following information to the DPEA for comment in accordance with recommendation 2.3 of the Council report:
  • Document 01 Introduction
  • Topic 16A Housing Land Supply
  • Local Housing Land Requirement Position Statement
  • Topic 18 Infrastructure First
• On 06 May 2026 officers received informal comments from the DPEA (given to the Council without prejudice to the final outcome of the Gate Check reassessment)
• With regard to the I-LHLR, the Reporter responded with a number of technical questions relating to the minor methodological change made to the I-LHLR (see paragraphs 3.22 to 3.35 of report EDC/009/26/SM) and the new NRS household projections.  The Reporter also questioned the status of the Local Housing Land Requirement Position Statement
• With regard to education and healthcare infrastructure (Topic 18 Infrastructure First), the Reporter only had one minor comment in relation to considering the relationship between the new household projections and the provision of infrastructure
• Officers are continuing to work through the comments from the DPEA and will make technical revisions to the Evidence Report where appropriate.

Local Housing Land Requirement Consultation

• In accordance with recommendation 2.3 of Council report ref. EDC/009/26/SM, officers undertook a targeted consultation relating to the use of the updated household projections by NRS, to seek views on the Council’s preferred approach to explore and consider the new household projections as part of preparing the LDP3 Proposed Plan
• To maintain proportionality, only those participants that had made a representation to the previous consultation on housing land supply between 26 January 2026 and 18 February 2026 were contacted.  The consultation was open between 10 April 2026 and 1 May 2026.  Five submissions were received, of which one was from the Mining Remediation Authority to confirm that they had no comments to make.  The remaining four submissions were made by housebuilders or their representatives
• Homes for Scotland responded to reiterate their view that submission of the Evidence Report for Gate Check should be paused to address the 2022-based household projections and that not doing so would risk the resubmitted Evidence Report being found insufficient or recommended by the DPEA for withdrawal.  Barratt Redrow made a similar submission in support of Homes for Scotland’s position
• Mac Mic Group made a broadly similar submission to ask that the Evidence Report should clearly explain how the most up-to-date projections have been considered, taken into account or reflected in establishing the I-LHLR.  They also expressed concern regarding their understanding that the Council would defer consideration of the 2022-based household projections until a new regional Housing Need and Demand Assessment (HNDA) was prepared.  Cala Homes made a similar suggestion with respect to reflecting the 2022-based household projections, with the specific request that the Council should consider modelling the new projections against the existing LHLR framework.  Cala Homes also requested presentation of other information on why 2,700 dwellings would remain an appropriate uplift from the original MATHLR of 2,500 dwellings, alongside explanation of the intended pathway to updating the HNDA and I-LHLR during the LDP preparation period, and a demonstration of how the 2022-based projections have been actively considered in the Evidence Report rather than deferred to the proposed plan stage
•  Officers have sought to address the comments made as part of the consultation in the redrafted Evidence Report Topic 16A paper on housing land supply. With regard to the responses from Homes for Scotland, Barratt Redrow and the Mac Mic Group and Cala Homes, officers maintain the view that it is not possible to arrive at a credible LHLR figure for the LDP3 Proposed Plan until a new HNDA or similar assessment for the Glasgow City Region or East Dunbartonshire is prepared.  Officers consider that presenting a quickly derived alternative ILHLR in the Evidence Report, without undertaking comprehensive work, would not result in a robust or credible basis upon which the Proposed Plan for LDP3 could be prepared
• Officers consider that the suggestion by Cala that the 2022-based projections could be modelled against the MATHLR or I-LHLR frameworks to attempt to estimate a future figure or figures has some value in terms of offering potential indicative future scenarios against which to measure housing land supply and infrastructure provision.  As such, and for indicative purposes only, using the 2022-based projections it is estimated that land for between 3,200 and 5,050 dwellings may have to be found, depending on the methodology, projection used (principal or high), base date chosen and other factors.  A summary of the potential scenarios is presented for Members’ information as follows

A methodology for each scenario is provided in Appendix 1 to this Technical Note.

• As a consequence of expectations of higher household growth during the 2022-based projection period than the 2018-based household projections used to underpin the MATHLR and I-LHLR, all scenarios above produce a higher figure than the I-LHLR set out in the revised Evidence Report.  However, each figure is subject to its own limitations, particularly in terms of agreeing with partners in the Glasgow City Region to undertake mobile demand redistribution or addressing potential spatial imbalances in supply between authorities should such an approach be taken
• It is important to reiterate that the above scenarios are presented for Members’ information only and that no scenario is currently considered sufficiently robust to be identified or agreed as the potential LHLR for LDP3.  The intention is to provide an overview of the level of housing land release that might be required during the LDP3 period should different approaches be taken.  It should also be noted that further/ updated household projections may be published in due course.  Any updated projections will be taken into account during the preparation of the LDP3 Proposed Plan.

Next Steps

• In accordance with the Council report, the Evidence Report will be revised to reflect the comments received from the DPEA and the latest round of comments from stakeholders on the I-LHLR. It is intended that the scenarios set out above will be summarised in the amended Topic 16A paper of the revised LDP3 Evidence Report and set out in more detail in the Draft Housing Technical Paper to be linked to the report.  The Reporter will have the potential scenarios before them when they undertake their appraisal of the sufficiency of the Evidence Report and will be emphasised to the Reporter that any scenario as set out is indicative only and has not yet been fully tested, discussed or scrutinised
• It is anticipated that the revised Evidence Report will be resubmitted to the DPEA for Gate Check before the end of May 2026.

22.    Should Members have any questions please contact Niall.Urquhart@eastdunbarton.gov.uk or Stewart.McNally@eastdunbarton.gov.uk .

Appendix 1 - Potential Housing Land Requirement Scenarios

Potential Scenarios

An explanation of the inputs from the potential LHLR scenarios summarised under TN Number 075-26 is provided as follows:

Scenario A 

To achieve a figure of 3,200 units, this scenario uses the following inputs:

• The NRS 2022-based principal household projection
• 2022 as the projection period as was used for the MATHLR
• The same proportions and approach with regard to mobile demand  redistribution as was carried out for the MATHLR
• A flexibility allowance of 25% as was set for the MATHLR.

Scenario B 

To achieve a figure of 3,300 units, this scenario uses the following inputs:

• The NRS 2022-based principal household projection
• 2028 as the projection period base date according to the year by which it is expected new-style LDPs should be adopted
• The same proportions and approach with regard to mobile demand1 redistribution as was carried out for the MATHLR
• A flexibility allowance of 25% as was set for the MATHLR.

Scenario C 

To achieve a figure of 3,550 units, this scenario uses the following inputs:

• The NRS 2022-based high migration household projection
• 2022 as the projection period as was used for the MATHLR
• The same proportions and approach with regard to mobile demand1 redistribution as was carried out for the MATHLR
• A flexibility allowance of 25% as was set for the MATHLR.

Scenario D

To achieve a figure of 3,950 units, this scenario uses the following inputs:

• The NRS 2022-based high migration household projection
• 2028 as the projection period base date according to the year by which it is expected new-style LDPs should be adopted
• The same proportions and approach with regard to mobile demand1 redistribution as was carried out for the MATHLR
• A flexibility allowance of 25% as was set for the MATHLR.

Scenario E

To achieve a figure of 4,000 units, this scenario uses the following inputs:

• The NRS 2022-based principal household projection
• 2022 as the projection period as was used for the MATHLR
• No mobile demand redistribution
• A flexibility allowance of 25% as was set for the MATHLR.

Scenario F

To achieve a figure of 4,250 units, this scenario uses the following inputs:

• The NRS 2022-based principal household projection
• 2028 as the projection period base date according to the year by which it is expected new-style LDPs should be adopted
• No mobile demand redistribution
• A flexibility allowance of 25% as was set for the MATHLR.

Scenario G 

To achieve a figure of 4,500 units, this scenario uses the following inputs:

• The NRS 2022-based high migration household projection
• 2022 as the projection period as was used for the MATHLR
• No mobile demand redistribution
• A flexibility allowance of 25% as was set for the MATHLR.

Scenario H

To achieve a figure of 5,050 units, this scenario uses the following inputs:

• The NRS 2022-based high migration household projection
• 2028 as the projection period base date according to the year by which it is expected new-style LDPs should be adopted
• No mobile demand redistribution
• A flexibility allowance of 25% as was set for the MATHLR