The planning systems of Scotland, Wales, and Northern Ireland are all similar to England
Although the planning systems of the devolved nations and Republic of Ireland have a separate legal basis to the planning system in England, their technical designs are still very close to the existing system in England. They are still highly discretionary, as decisions to grant planning permission are frequently made case-by-case.
This technical similarity to planning in England remains despite various small reforms to these systems, such as those in Scotland. Ultimately they still have “English-style” planning systems, especially when compared internationally.
Housing outcomes within the devolved nations resemble those within England
Housing conditions across the Celtic nations vary between and within them. Scotland has relatively affordable housing outside of Edinburgh – in Glasgow, the average house costs 5.8 times average local incomes, while they cost 8.2 times local incomes in Edinburgh. Wales is similar – housing is less affordable in Cardiff than it is in Edinburgh, but Swansea and Newport are much less expensive. In Northern Ireland, housing is relatively more affordable in general.
These outcomes reflect the varying performance of local economies within the devolved nations. It is the same pattern as can be seen in England – housing is much more affordable in Blackburn than it is in in Brighton, where the average home cost 13.5 times average incomes.
This is because the housing crisis in cities across the UK is caused by how the discretionary planning system rations development and causes mismatches between the local supply of housing and local demand. This causes housing shortages in the most expensive and high-demand cities, such as Bournemouth, Cardiff, and Edinburgh.
Conversely, Blackpool, Dundee, and Swansea are all in the same boat – their housing is relatively affordable due to their weak labour markets and relatively low demand for housing.