Consultation Report

Local Housing Strategy

IMAGE: Orkney Islands Council crest and logo, identifying the organisation responsible for the Local Housing Strategy.

Table of Contents

• Introduction and background
• Approach to the LHS consultation
• Responses received
• Summary of findings
  • Vision
  • Strategic Priorities
  • Outcomes
  • Action plan
• Islands Communities Impact Assessment and Equality Impact Assessment
• Other comments from respondents
• Peer review and Scottish Government response
• Conclusions and implications for the final Local Housing Strategy
• Changes from the draft to final Local Housing Strategy

Introduction and background

The Housing (Scotland) Act 2001 places a statutory duty on local authorities to assess the housing needs of all persons in the area, across all housing tenures, and to develop strategies to meet those needs. This requires the production of the Housing Need and Demand Assessment, and Local Housing Strategy (LHS).

The Local Housing Strategy sets out the priorities and actions required for housing supply, housing quality, and access to housing. The Strategy covers the period 2024-2029. The Act requires that local authorities consult on their LHS, and the statutory Equality Duty on public bodies requires the involvement, consultation and engagement of as wide a range of stakeholders as possible.

The Orkney Islands Local Housing Strategy was developed over 2023, with the consultative draft published in January 2024. The draft was developed with input and oversight from the Orkney Housing Market Partnership which encompasses the Council’s Member Officer Working Group. It has responsibility for developing the LHS, and monitoring its implementation on behalf of Orkney Islands Council.

The Housing Market Partnership comprises the following partners:

• Orkney Islands Council Elected Members
• Orkney Islands Council - Education, Leisure & Housing; Neighbourhood Services & Infrastructure; Enterprise & Sustainable Regeneration; Strategy, Performance & Business Solutions; Orkney Health & Care.
• Orkney Housing Association (OHAL)
• Orkney College UHI
• The Development Trusts’ housing consultant
• Highland & Islands Enterprise (HIE)
• Housebuilders
• NHS Orkney
• Scottish Government More Homes Division
• Scottish Water

The Partnership held 8 meetings between January and December 2023 to oversee production of the Housing Needs and Demand Assessment, and then to develop the Local Housing Strategy. This process involved:

• Consideration of Housing Strategy topic papers and presentations
• Workshops on each topic with a total of 20 break out groups over the development period including a total of 45 stakeholders. Most Partnership members attended multiple workshops.

Approach to the LHS consultation

In addition to the work of the Housing Market Partnership during 2023, wider consultation undertaken. It should be noted that the Housing Market Partnership’s work built on previous, and wider community consultation led by the Council in late 2021 and early 2022 – ‘Orkney Matters’, with findings from this also feeding into the Housing Need and Demand Assessment, and the Local Housing Strategy development. The focus of Orkney Matters was on community and place with questions asked on what’s working, what’s not working so well, and what the community would like to improve. The engagement was through survey, online consultation, and art workshops for harder to reach groups. This project involved all Council teams including the Housing Service and partner agencies from Orkney’s Community Planning Partnership.

The Local Housing Strategy consultative draft was issued for public consultation in January 2024 with a questionnaire to ask for feedback on the housing vision, priorities, outcomes and actions. The consultative draft was disseminated through proactive media engagement with the established network of organisations and community groups including Community Councils and the Development Trusts. Separate consultation took place with the 10 Development Trusts (2 meetings) to ensure the needs of the outer islands’ communities were understood and built into both the Housing Needs Assessment and the Housing Strategy. Community Councils were also contacted directly to ask them to respond to the Strategy consultation.

Responses received

A total of 62 responses were received to the consultative draft. These comprised:

• 55 responses made to the online survey.
• 7 additional responses – 5 made in writing directly to Orkney Islands Council, and 2 additional survey responses which missed the original deadline but were included in this consultation analysis.
• Of these, 14 responses came from organisations, and the remaining 48 came from individual households. 45 responses came from Orkney Mainland and Linked South Isles, 15 from Orkney ferry-linked isles and 2 respondents skipped this question.

Summary of findings

Vision

The draft Local Housing Strategy sets out the following vision for housing in Orkney:

“Orkney has a wide range of good quality, sustainable homes that are affordable and meet the current and future needs of individuals, across all Orkney Islands communities.”

Consultees were asked if they thought this was the right vision for Orkney. From the survey responses, there was a split response to this question with 45% agreed, 49% disagreed and 6% didn’t know:

This excludes additional written responses received by the Council. These 7 additional responses mostly did not explicitly mention the Vision and were positive about the general direction of the Strategy.

Additional open comments received from survey are summarised below. Many of these comments did not comment on the actual vision, but respondents took the opportunity to set out what they felt were key priorities for the Strategy. The summarised themes are set out below, followed by the number of respondents making these types of comments (note not all respondents made open comments):

• Lack of supply, empty homes, holiday homes and second homes – minimise empty homes, holiday homes and second homes for the benefit of local people, keeping our young people and reduce the number of people moving away due to housing affordability reasons, and lack of access to housing. Several people mentioned Stromness specifically and the impact of holiday homes in the centre of the town, and this was also mention by many from the isles communities. Only one consultee mentioned the positive impacts of holiday homes. (9)
• Increasing housing supply and different types/size of housing needed – more focus is needed on the volume of new supply (increased supply and lower prices) and type of housing including the need for more starter homes and smaller properties for young families, young workers, older people, workers and students coming to live in Orkney. (8)
• Location – a range of comments included ensuring a distribution of new housing across all Orkney communities including the outer isles to support sustainability of communities and to prevent depopulation, and also suggested ‘well located’ housing – proximity to community support, transport, schools, amenities, and reducing the need for cars. (7)
• Poor condition –poor condition of existing homes and empty homes (including heating problems and lack of insultation) - comments included private, council and housing association homes. (4)
• Planning and regulators – more housing supply needs to be supported by Planning approvals, and the challenges associated with SEPA in Planning processes. (3)
• Increasing elderly population - more focus is required on the housing needs of increasing elderly population. (2)

Strategic Priorities

The draft Housing Strategy set out the housing priorities to be driven by the Council in partnership with the Orkney Housing Market Partnership over the next five years. These priorities are: - More Homes - Quality Warm Homes - Access and Choice of Housing for All.

Consultees were asked if they thought these were the right priorities. Responses showed the majority agree with the strategic priorities: 69% agreed, 28% disagreed, and 4% didn’t know.

Additional open comments received from survey and separate written responses in relation to the priorities are summarised below. Many of these comments repeated the themes made in the comments for the first question:

• Empty homes, second and holiday homes – the amount of second and holiday homes are excluding homes for local people, and the need for refurbishment of empty homes. (7)
• Key workers / local households – comments supporting both the need for more housing for key / incoming workers but also comments suggesting that the need for local households must also be met. (6)
• Location – ensuring a spread of development around the islands in suitable location, and the need for development where there are good transport links. (5)
• Housing quality and energy efficiency/fuel poverty – bringing existing council housing up to decent standards including insultation and affordable heating methods, and refurbishment of empty homes. (4)
• Type of homes required – ensuring homes meet the needs of different household types including smaller sized homes and to meet the needs of the increasing number of older people. (4)

Outcomes

The draft Housing Strategy includes a list of outcomes to be worked on over the next 5 years.

Consultees were asked if they thought these were the right outcomes. Responses showed the vast majority agree with the outcomes to be worked on with: 74% agreed with More Homes, 98% Quality Warm Homes, 85% Access and Choice of Housing for All, 85% Monitoring and Review.

Additional open comments received from survey and separate written responses in relation to the outcomes are summarised below. Again, many of these comments repeated the themes made in the comments for the previous questions:

• Improving and maintaining quality of existing homes - including insultation, energy efficiency and fuel poverty, with reference to the difficulty of finding trades for people to make repairs in their own homes. (7)
• Empty homes, second and holiday homes – reducing the number of empty homes and bringing them back into use and reducing Airbnb/holiday homes. (6)
• Location and enabling community led housing initiatives – making sure there is a spread of housing across areas, again with some mentioning the need to support housing to prevent depopulation / support viability on the isles, and the need for community led initiatives to be supported (4)
• Type of homes required and lack of choice – noting the need for smaller homes and lack of choice in the existing housing system (3).

Action plan

The draft Housing Strategy includes a detailed Delivery Action Plan to guide implementation of the Strategy. Consultees were asked if they considered that any actions or targets should be amended, or new actions added to the Plan. These comments tended to repeat the themes as list above, rather than suggest any change to the action plan. However, where comments suggested amendment or greater emphasis on certain aspects of the action plan, these are identified below (note - where comments reiterated existing actions these are not repeated here):

• Prioritising action for short-term lets and stating the need for control of short-term lets (but one person saying no control needed).
• Affordable student accommodation during term-time and when students are on placement.
• Greater emphasis on sustaining viability of the isles’ communities through housing supply.
• Ensuring the plan is sufficiently resourced and making it sure it is not a ‘wish list’ and can actually be delivered.
• Sustainable funding required for Care and Repair.

Islands Communities Impact Assessment and Equality Impact Assessment

As noted above, 45 responses came from Orkney Mainland and Linked South Isles, and 15 from Orkney ferry-linked isles (2 respondents skipped this question). When asked if the Housing Strategy could have any unfair and unintended consequences for where you live, 55.7% of respondents stated Yes, and 44.2% stated No. Less than half of respondents then responded through open comments on why they felt this way.

Respondents were asked if the Housing Strategy could affect people of protected characteristics listed in the Equality Act 2010 (race, sex, sexual orientation, gender reassignment, pregnancy and maternity, age, religion or beliefs, caring responsibilities, care experience, marriage and civil partnerships, and disability). From the survey respondents, 24.5% stated Yes, 58.5% stated No and 16.9% stated Don’t know. Only 16 people then responded through open comments on why they felt this way.

The key themes from both the impact assessment questions are listed below:

• Too much focus on Kirkwall at the expense of Stromness, smaller settlements on the mainland, the linked South Isles, and the ferry-linked isles.
• Prioritise the housing needs of local people versus those of incoming workers.
• The need for affordable warmth, particularly on the Isles, and for older people.
• Lack of supply means young people may have to leave the islands.
• Needs of older people in more rural areas and the isles, with the need for small developments suitable for older people including co-housing (in addition to the core and cluster approach as proposed for the mainland in the Strategy).
• Older and disabled people require more support to stay in their own homes and communities, and support to make use of technology for independent living.
• Specific mention was made of the importance of the Care and Repair service for older and disabled people.
• Problems of prioritising tourists and short-term lets over the needs of residents.

Other comments from respondents

The survey respondents were asked whether there were any other final comments they wished to make to add on the Housing Strategy. 34 survey respondents made additional comments, however, all of these comments repeated themes already covered above.

In addition to the survey respondents, 5 separate responses were made. One consultee supported the draft Strategy and made no further comment; one other response was from an internal Council department with comments made and which have been addressed in the revised draft. Three others respondents made more detailed responses on matters relating to:

• Specific housing needs in Stromness including the negative impact of tourism/short-term lets, the need for effective land supply, housing for workforce and students;
• One outer isle with a buoyant housing market, and argument for an integrated economic and housing strategy with support from Planning for housing development, and balancing tourism with the housing needs of locals;
• A response from the renewable energy sector which noted general support for the strategic priorities and outcomes. Arguments were made for control of short-term lets, improved site efficiency for new housing development (including increased site density), supporting the monitoring and reporting on fuel poverty and supporting the mainstreaming of the Net Zero to 2030 in housing ambition.
• There was one comment that queried attraction of more housing contractors to the islands. However, the Strategy does not promote more building contractors, but rather at least one more affordable housing developers that can augment the financial and organisational capacity of existing providers to supply more affordable housing.

Peer review and Scottish Government response

As part of the Local Housing Strategy development process, there is a requirement for peer review from another Scottish local authority, and formal comment to come from Scottish Government. Scottish Government More Homes representatives are also members of the Orkney Housing Market Partnership.

Comments received demonstrate that Scottish Government consider the Orkney Local Housing Strategy to be robust, with only minor comments received on areas for improvement:

• Equalities – Scottish Government encourages the Council to highlight any specific aspects from the impact assessments that have helped inform the priorities and outcomes set out in the LHS and to ensure that a Child Rights and Wellbeing and Health Inequalities Impact Assessment are carried out in support of the development of the LHS. This is not currently a type of impact assessment undertaken by the council and is being investigated.
• Homelessness - Although the production of a separate strategy for homelessness is no longer required and the LHS links in with the councils Homelessness Strategy and subsequently its Rapid Rehousing Transition Plan (RRTP), it was suggested that the LHS be expanded to include key points from the homelessness strategy – this has been done and the latest RRTP has been updated on the Council’s website.
• House Condition - While the LHS provides some useful data from the Scottish Housing Quality Standard this section of the strategy would benefit from more detail on future plans to ensure SHQS is maintained and EESSH/EESSH2. The Council is awaiting the finalised revised EESSH2 or successor definition following the Scottish Government’s consultation process.
• Housing Delivery – Self Build/Custom Build - The statement in the LHS that there will be opportunities created for serviced sites within some of the volume housing developments is welcome. It would be helpful to have more information on how the local authority intends to respond for demands for land outwith these developments. It would also be helpful to have more information about the register, which the local authority is required to establish under the Planning (Scotland) Act 2019, including the information it will contain and how it will be published. The LHS draft has been updated to reflect these points.

Conclusions and implications for the final Local Housing Strategy

The consultation findings have been considered against the draft Local Housing Strategy. There are some very clear, common themes that were consistently raised by Orkney residents and organisation responses. To summarise, these were:

• Reducing empty homes, second and holiday homes – this was the most common theme expressed across open survey comments, and in some of the additional written responses received.
• Increasing housing supply – including the need for different types and sizes of housing to meet a range of housing needs for individuals, families and starter homes.
• Quality of existing homes – highlighting the need for maintenance, and the need for focus on energy efficiency/fuel poverty especially in Council housing, and the lack of access to tradespeople for people that wish to make repairs to their own home.
• Location –consultees argued that housing was needed across different locations/communities with some also noting that new development should be sustainable – in the right place for amenities, travel, and within communities.
• Key workers and local households – many noting the need for housing for key workers (including incoming workers), but with a similar strength of opinion around ensuring local people’s housing needs are met.

Changes from the draft to final Local Housing Strategy

Vision

Given the comments relating to increase volume of meeting the needs of different types of households especially young and family households, and comments relating to different locations, it is proposed the vision is changed in emphasis to explicitly include meeting needs of families and local communities, as follows:

“Orkney has a wide range of good quality, sustainable homes that are affordable and meet the current and future needs of individuals, families and local communities across the Orkney Islands.”

Priorities

No changes are planned to the priorities set out in the draft – More Homes, Quality Warm Homes and Access and Choice of Housing for All.

Outcomes

No changes are proposed for the outcomes, although in relation to the More Homes, the consultation suggests equal priority from consultees on new supply, and addressing the issue of empty homes, second homes and holiday homes.

Action plan

It is concluded that generally the key themes raised by consultees are already covered in the action plan. A few additions and changes in emphasis have been made to the action plan to reflect the priorities from consultees:

• Empty homes, second and holiday homes – these actions are changed to be more assertive and propose that action on control may be needed in key locations.
• Housing needs in the isles, including the needs of older people living on the isles – these actions have been made more explicit.
• Care and Repair – two actions included to seek funding from NHSO/OHAC with the aim of making the service more sustainable for independent living of older and disabled people.

In addition, Council departments have examined the action plan in detail in relation to allocation of resources and timescales for delivery. Much of the work will be undertaken through ‘business as usual’ approach and within existing resources, but the action plan provides focus on activity and work programmes. Inevitably, given the current challenge in relation to financial resources, this may mean that some of the implementation may take longer than ideally would be the case.