Appendix 2 - Participation Statement Consultation Responses
Perth and Kinross Council · 21 October 2024
Back to Economy and Infrastructure Committee — 21 October 2024 and its agenda
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APPENDIX 2 CONSULTATION RESPONSE Local Development Plan Scheme Participation Statement Consulted: 9 - 27 September 2023 Development Plans Team Officer: Brenda Murray Received From Comment Summary PKC Officer Response Change Made to DPS Private Individual Request for Perth Community Flood Aid to be included in the list of consultee organisations in the Participation Statement. Perth Community Flood Aid along with a wide variety of groups, fall into the category of “Communities of interest” referred to in the Participation Statement. The Group contact details have been added to our LDP mailing list which is used to inform interested parties about LDP updates, engagement events and consultations. To reach a wider audience, the Council website, digital channels and social media will be used to promote opportunities and encourage everyone to get involved. No change to Participation Statement. Private Individual Request for “Tenants” to be included in the list of consultee organisations in the Participation Statement. Tenants along with a wide variety of groups, fall into the category of “Communities of interest” referred to in the Participation Statement. The contact details for Tenants and Residents Associations have been added to our LDP mailing list which is used to inform interested parties about LDP updates, engagement events and consultations. In addition, to reach a wider audience, the Council website, digital channels and social media will be used to promote opportunities and encourage everyone to get involved. No change to Participation Statement.
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Received From Comment Summary PKC Officer Response Change Made to DPS Private Individual Request for no more developments in Auchterarder. Comment refers to matters out with the content of the Participation Statement which cannot be addressed through this consultation. No change to Participation Statement. Private Individual Consultation with the community regarding development plans is vital, but only if their views can instigate change. Community views expressed on planning application 23/01941/AMM, request for views to be taken into account when making planning decisions. The Participation Statement relates to the engagement which will be undertaken in the preparation of the next Local Development Plan i.e LDP3 and all comments gathered will be given due consideration when preparing that Plan. Community views are an important part of the evidence that will inform LDP3 alongside other considerations such as housing need, environmental, social and economic factors, and the policy framework set out at a national level. The example highlighted relates to the adopted LDP2 and a live planning application being progressed through the development management decision making process on which the Participation statement has no bearing. No change to Participation Statement. Network Rail Both the Development Plan Scheme and the Draft Participation Statement are very helpful. Network Rail welcomes the opportunity to engage with the council at all stages of LDP3 preparation and delivery, particularly during the Evidence Report preparation currently underway. Network Rail is keen to discuss and contribute to your evidence base in terms of rail infrastructure. Namely, this would relate to Comments and desire to be further engaged at all stages of LDP preparation noted. No change to Participation Statement.
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Received From Comment Summary PKC Officer Response Change Made to DPS network capacity and condition in relation to your Spatial Strategy. Opportunities for the introduction or improvement of Active Travel to/from stations and the emerging Infrastructure Levy, and how this would interface with emerging LDPs, are also important topics Network Rail is keen to discuss further. Scott Hobbs Planning Site suggestion for inclusion within LDP3 Comment refers to matters out with the content of the Participation Statement and are more applicable and relevant to the proposed plan stage of the LDP process. Advised respondent to submit suggestion at “Call for Ideas and Sites” stage of Plan preparation. No change to Participation Statement. Private Individual View’s given on future development in the village of Crook of Devon. Comment refers to matters out with the content of the Participation Statement and are more applicable and relevant to the proposed plan stage of the LDP process. Advised respondent to submit ideas at “Call for Ideas and Sites” stage of Plan preparation. No change to Participation Statement. Private Individual The Statement is very clear and comprehensive. Supportive comments. No change to the Participation Statement. Private Individual The Participation Statement looks good and the commitment to an inclusive approach and providing ‘everyone’ with an opportunity to have their say is encouraging. Supportive comments. No change to the Participation Statement.
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Received From Comment Summary PKC Officer Response Change Made to DPS Homes for Scotland Given the importance of home building across all tenures to the social and economic success of Perth & Kinross, it is vital that a home builder representative is defined as such. We would also like to see a reference in the Participation Statement to what other local authorities have termed “expert groups”. These will be stakeholders with key expert knowledge in an industry. HFS can act as this stakeholder for the home building industry. It is positive that the Evidence Report Preparation stage of the Development Plan Scheme (DPS) sets out that the Council will seek views on the gathered data from key agencies. HFS request to be engaged in both contributing information to the Evidence Report, and the review of this evidence base. During the Evidence Report stage, we would like to see more information on how the engagement of key stakeholders will take place, and who the Council considers would have a key role in the meeting of the legislative requirements of the Evidence Report. HFS should be identified as a key agency. It is recognised that HFS represents a large part of the Home Building industry and that it is an important contributor to the preparation of LDP3, along with numerous other representative organisations. The Participation Statement states that “Throughout the preparation of LDP3, our approach to engagement and consultation will be based on a collaborative approach, including (but not exclusively) representatives of … Landowners and Developers”. HFS falls within this category and have been invited to engage in the Topic Paper consultation both in terms of suggesting additional evidence and in reviewing the proposed evidence base. HFS has submitted comments and these are being given due consideration in preparing the Evidence Report. The Participation Statement sets out information on how the engagement of all stakeholders will take place on pages 9 to 13 of the DPS and is considered to contain sufficient information in this regard. There is no statutory requirement for the Participation Statement to set out who the Council considers would have a role to play in meeting the legislative requirements of the Evidence Report. The Council would refer the respondent to Regulation 25 of The Town and Country Planning (Development Planning) No change to Participation Statement. No change to Participation Statement
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Received From Comment Summary PKC Officer Response Change Made to DPS HFS is keen to build on the engagement we’ve had with Perth & Kinross Council. This should continue to take the form of, ideally, in-person meetings between HFS and its members and the ability for two-way communication between us and the council in the form of phone calls and emails, as appropriate. It is positive that during the Proposed Plan Preparation period a ‘Call for Sites and Ideas’ survey will be issued. The Local development planning guidance (2023) states that the DPS must include proposed timings for various stages of LDP plan preparation, by specifying the proposed year and quarter. However, we note that the DPS draft document does not appear to contain this information. Establishing a coherent Site Assessment Methodology will require significant continued engagement with HFS and our members. (Scotland) Regulations 2023, which sets out the bodies specified as key agencies. Agreed Support for Call for sites stage noted Consultation was on the Participation section of the DPS only. This information is included within the full document. The views of the respondent are noted. However, the site assessment methodology is not for the Development Plan Scheme and Participation Statement to address and is part of the Evidence Report and the Gatecheck processes. No change to Participation Statement No change to Participation Statement No change to Participation Statement
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Received From Comment Summary PKC Officer Response Change Made to DPS To adapt the Housing Need and Demand Assessment (HNDA) figure into a Local Housing Land Requirement (LHLR) figure will also require significant ongoing engagement with HFS and our membership. There must be open and transparent dialogue on setting the LHLR including which other factors should be considered in order that the LHLR exceeds the MATHLR as required by NPF4. The current HNDA process and toolkit are fundamentally flawed and significantly underestimate the true need and demand for housing. The comments of the respondent are noted; however, the purpose of the Development Plan Scheme and Participation Statement is to set out the timeframe for production of the next Local Development Plan, the stages involved in that, and how people can be involved in the LDP preparation. The Council has been engaging with the development industry (including house builders and infrastructure providers) during preparation of the Evidence Report to ensure the evidence base we have is as robust as possible. However, there is no requirement to detail every process involved in gathering information for housing in the Development Plan Scheme and Participation Statement document, these will be discussed when and if necessary, with relevant parties. No change to Participation Statement Cardross Asset Management Ltd There needs to be recognition that pivotal Gate Check Reports for LDP3 require an integrated approach from stakeholders. For example, Strategic Flood Risk Assessments are required for the PKC area. These will involve PKC, SEPA, Scottish Water and affected landowners so there must be a prescriptive and inclusive approach. This is of critical importance for Inveralmond Industrial Estate (including LDP development site E38), where PKC is required to advance flood protection measures. The Strategic Flood Risk Assessments (SFRA) purpose is to inform the development planning process, and gather evidence, primarily to avoid increasing overall flood risk, and avoid development within NPF4 ‘at risk’ areas. The draft SFRA was consulted on as part of the Flood Risk and Water Environment Topic Paper which ran 8 Jul till 18 Aug 2024. This draft was prepared by the planning authority in consultation with Scottish Environment Protection Agency (SEPA). The SFRA guidance prepared by SEPA suggests, ’input from colleagues with expertise in flooding, planning, mapping, building standards and from other organisations such No change to Participation Statement
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Received From Comment Summary PKC Officer Response Change Made to DPS Utility capacity constraints require an integrated approach from SSE, SGN, Scottish Water, and Scot Gov, as consented BESS developments are removing kVA capacity for allocated LDP infrastructure sites. It is noted with concern that PKC appears to be using the 2022 Ryden Report re demand & supply analysis for Classes 4, 5 & 6. This report is nearly 2 years out of date and must be updated. There must be up to date and robust assessment of "effectiveness" of existing LDP sites. For example, Perth West requires delivery of a substantial road junction, and there is no certainty that this junction can be provided via City Deal. There appears to be an inference that for Classes 4, 5 & 6 development that LDP3 site allocation should broadly reflect the as Scottish Water and Scottish Canals may be needed prior to finalising it.’ There is no particular benefit or need to involve landowners when preparing the SFRA, however, it will be important to engage with landowners and developers, at Call for Sites and Ideas stage. The remaining comments of the respondent are noted, however, they refer to matters out with the Participation Scheme. They relate to the content of the topic papers and will be considered in the preparation of the Evidence Report. The purpose of the Development Plan Scheme and Participation Statement is to set out the timeframe for production of the next Local Development Plan, the stages involved in that, and how people can be involved in the LDP preparation. No change to Participation Statement
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Received From Comment Summary PKC Officer Response Change Made to DPS settlement hierarchy within PKC, and further that "mixed use" development should be encouraged. This is in our view completely flawed, as particularly major Class 6 developments are likely to have 24/7 operations so require some separation from existing residential conurbations. So substantial Class 6 development at strategic transport junctions but in smaller settlements should also be supported within LDP 3. Fossoway Community Council Request that local primary and high schools in the Fossoway area are included in the LDP preparation process. Request for Fossoway Community Development Trust to be included in future emails. The Participation Statement states that we will seek the views of children and young people. Initial engagement has been undertaken across the 5 to 25 year age group through involvement of schools and various youth organisations. Place Standard events were held in both Fossoway Primary School and Kinross High School to gather pupils views about what they like in their area and what could be improved. We will continue to keep the schools informed and engaged during the various stages of plan preparation. Fossoway Community Development Trust have been added to the LDP mailing list.