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Perth and Kinross Local Development Plan 3 Evidence Report

Perth and Kinross Council · 5 March 2025
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Our vision is a Perth and Kinross where everyone can live life well,
free from poverty and inequality
___________________________________________________________________
Committee or Board: Perth and Kinross Council
Date of Meeting: 5 March 2025
Report Title: Perth And Kinross Local Development Plan 3
Evidence Report
Report Number: 25/40
Report Author: Brenda Murray
Organisational Lead: Report by Strategic Lead – Economy, Development
and Planning
1. Purpose
1.1 This report asks Council to approve the Perth and Kinross Local Development
Plan 3 (LDP3) Evidence Report and delegate authority to the Strategic Lead
(Economy, Development and Planning) to submit to the Scottish Ministers for
the Gate Check process.
1.2 LDP3 will have an important role in delivering the spatial planning aspects of
the Corporate Plan 2022-2027, particularly contributing to the priorities of
‘tackling climate change and supporting sustainable places’ and ‘developing a
resilient, stronger and greener economy’.
1.3 Sections
1. Purpose
2. Recommendations
3. Background/Main Issues
4. Proposals
5. Conclusion
6. Impact Value Assessment
7. Appendices

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2. Recommendations
2.1 It is recommended that the Council: -
(i) Approves the LDP3 Evidence Report and delegates authority to the
Strategic Lead (Economy, Development and Planning) to submit it to
Scottish Ministers who will appoint a Reporter from the Department for
Planning and Environmental Appeals (DPEA) for review.
(ii) Delegates Authority to the Strategic Lead (Economy, Development and
Planning) to make any necessary minor changes or updates to the
Evidence Report thereafter, prior to its submission to Scottish Ministers.
3. Background/Main Issues
3.1 Historic Information/Context
3.1.1 Local Development Plans (LDPs) guide the use and development of land
within an area, and indicate where investment in housing, employment,
leisure and infrastructure will take place over the plan period. Together with
the National Planning Framework (NPF4), the LDP constitutes the statutory
Development Plan for an area against which all planning applications are
assessed. The Development Plan is also used by investors to inform
decisions.
3.1.2 The Council’s current Local Development Plan (LDP2) was adopted in
November 2019, and delivery of its many policies and proposals is ongoing,
however, the Council must ensure that the LDP is kept up-to-date and due to
changes in legislation, work on LDP3 has commenced. The process,
programme and consultation proposals for LDP3 are set out in the
Development Plan Scheme, which is reported annually to the Economy and
Infrastructure Committee, the most recent version of which was approved in
October 2024 (Report 24/284 refers).
3.1.3 LDP3 is being prepared under a revised statutory process as set out in the
Planning (Scotland) Act 2019 and accompanying Local Development
Planning Regulations 2023. A significant change in the process is the
requirement to prepare an Evidence Report as the first major stage in plan
preparation, prior to the drafting of the Proposed Plan. The purpose of the
Evidence Report is to provide a sound evidence base for preparing the LDP3,
and explaining what the implications of this information are for the
development of the plan. The Evidence Report does not contain any strategy
or policy, nor does it involve the assessment or allocation of specific sites.
Rather it provides the information on which these decisions will be founded at
the Proposed Plan stage.

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3.1.4 The legislation requires that the Evidence Report is approved by the Council
prior to being submitted to Scottish Ministers for a Gate Check review. The
Gate Check review is an independent assessment of whether the planning
authority has sufficient information to prepare an LDP. Scottish Ministers
appoint a Reporter from the Department of Planning and Environmental
Appeals (DPEA) to carry out the assessment. The reporter will then either
inform the Council that the report is sufficient, allowing it to proceed to the
preparation of the Proposed Plan, or will send the Council an Assessment
Report setting out the reasons why the report is not deemed sufficient with
recommendations for improvement before re-submission to Scottish Ministers.
4. Proposals
Process
4.1 The Evidence Report is attached as Appendix 1.
4.2 In preparing the Evidence Report, officers have had regard to the legislative
requirements, particularly relating to consultation and engagement. The broad
process has been as follows:
 Evidence Gathering and Early Engagement. Information was collated
from a wide range of internal and external sources. This included policy
documents, reports, assessments, statistical data, annual audits,
infrastructure capacity assessments, and survey work. A range of early
engagement activity was undertaken to collect evidence from the public
and key stakeholders, including the public Big Place Conversation
surveys, publicity, meetings and Place Standard workshops. More
information on this engagement is provided at paragraph 4.9.
 Topic Paper Preparation and Consultation. The Council produced and
consulted on a series of Topic Papers which covered the subject matters
of NPF4’s national planning policies suite.  These papers set out in detail
the evidence the Council has gathered to help produce our Evidence
Report, and our intention to use it to prepare our LDP3 Proposed Plan. 
The papers were published on the Council’s Consultation Hub for a 6-
week period during July and August 2024.
 Evidence Report Preparation. The Evidence Report was prepared
based on the content of the topic papers, considering the consultation
responses to both them and the Big Place Conversation. Focused
conversations were held with key stakeholders, to seek feedback on
particular issues.
Structure and Content
4.3 The scope and content of the Evidence Report has been guided by the
legislation and the Scottish Government’s Local Development Planning
Guidance. The Report takes a topic or issue-based approach and in the main
reflects the list of policy topics contained in NPF4, although some NPF4 policy
topics have been grouped together due to the inter-connected nature of the
subjects.

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The information for each issue follows the template suggested in the
Guidance and provides a systematic, consistent and transparent approach to
the analysis and interpretation of the evidence. Due to the volume of
information these templates are provided as Appendices to the Evidence
Report (Appendix A-E), with summaries of the information included within the
relevant chapters of the document.
4.4 The Evidence Report is structured as follows:
 Chapter 1 - a table detailing the key prescribed legislative requirements
for the Evidence Report and under which section of the report they have
been addressed;
 Chapter 2 - a profile of the Perth and Kinross Area;
 Chapter 3 - a participation and engagement statement to explain how
the Council has sought stakeholder views in line with legislative
requirements and how these have been taken into account;
 Chapter 4 - a summary of the appropriateness of the LDP2 spatial
strategy, policies and allocations;
 Chapter 5 - a summary of the gaps, uncertainties and key issues relating
to the evidence key information on the issues, and a summary of areas
of agreement and dispute with the evidence;
 Chapter 6 - a summary of the implications and key issues arising from
the evidence for LDP3;
 Chapter 7 - requirements for and benefits of Strategic Environmental
Assessment (SEA). Proposed Site Appraisal template (incorporating
SEA considerations) is in Appendix H;
 Chapter 8 - the invitation to local communities to prepare Local Place
Plans (LPPs) and the assistance provided to them; and,
 Chapter 9 - the Evidence Report approval process.
Areas of Agreement/Dispute
4.5 At the Gate Check, the DPEA’s assessment of the Evidence Report will be
guided by the extent to which there has been agreement or disagreement with
the evidence, particularly amongst the key stakeholders. Chapter 5 of the
report contains a summary of the main areas where the evidence is disputed
or uncertain, and where the Reporter’s attention is likely to be focused.
4.6 The consultation on the Topic Papers referred to in paragraph 4.2 above is
the main vehicle through which such areas of dispute have been established.
Overall, the consultation demonstrated a good level of agreement with the
evidence from the parties who responded, particularly the Key Agencies.
These included NatureScot, SEPA, Scottish Water, Scottish Enterprise,
Tactran, NHS Tayside and Historic Environment Scotland. Information was
added or amended in response to comments where appropriate, and this is
recorded in Appendices A to E to the Evidence Report.

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4.7 There were a few notable areas of dispute which are detailed in each of the
relevant issues templates and outlined in brief below.
 Housing – Homes for Scotland (HfS) dispute the evidence in relation to
the methodology for calculating housing need. The Council’s evidence is
based on the Housing Needs and Demand Assessment (HNDA). The
HNDA was carried out using the Scottish Government’s HNDA tool and
confirmed as robust and credible by the Centre for Housing Market
Analysis. The evidence submitted by HfS was commissioned by them
and was not written in partnership with the Council or with other
stakeholders. It is noted, however, that this research was undertaken at
a national level as well as for individual local authority areas and is to be
discussed within Scottish Government. If the conclusion of those
discussions is that this research is to be preferred nationally over those
derived through the HNDA process, then it can be used to inform the
setting of the LHLR at Proposed Plan stage.
 Flooding - A few individuals dispute the conclusions of the Craigie Burn
Flood Study and call for it to be redone. This is not considered to be
necessary as the study was carried out for PKC by suitably qualified
consulting engineers, in-line with national guidance and industry-
standard methodology. The study was updated and finalised and the
conclusions and recommendations of the study were approved at the
Climate Change and Sustainability Committee on 27 November 2023.
 Green Belt - Disputes raised relate to: the need for a review of the Perth
Green Belt boundary in light of the new policy context and priorities set
out in NPF4; whether the green belt is still the most appropriate way to
effectively manage development in this area; and that the review should
have been undertaken as part of the evidence report. In response, the
evidence report acknowledges that it will be necessary to undertake a
review in light of the new policy context and priorities set out in NPF4,
including meeting the finalised housing and employment land
requirements, and the spatial strategy which is identified for the new
LDP3. The timing of the review will be important as it will need to be
informed by other pieces of work, such as the settlement audit, work on
20-minute neighbourhoods, and the spatial strategy itself. For this
reason, it was not considered appropriate to carry out the Green Belt
review at Evidence Report stage. It will, however, need to be undertaken
prior to the site selection process.
 Retail -a supermarket operator disagrees with the methodology and
findings of the Perth and Kinross City and Town Centre Retail Study
2023.  Officers consider that the 2023 study is consistent with good retail
planning practice undertaken by specialist consultants and is based on
the latest available information, including a new household telephone
survey of shopping patterns, up-to-date population and expenditure
projections, and robust estimates for Special Forms of Trading (i.e.
online retail sales). The retail market has changed significantly since the
previous 2016 study, due in part to changes in shopping habits and
expenditure growth rates, and therefore different findings and
conclusions are to be expected.

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Key Issues arising from the evidence
4.8 The key issues identified through the Evidence Report are set out in detail in
Chapter 6 of the Evidence Report. Overall LDP3 will need to address:
 Demographics of an ageing population and increase in the number of
smaller households;
 Risks associated with climate change such as more extreme weather
events, through nature-based solutions and the location and adaptation
of buildings and infrastructure;
 Delivery of biodiversity enhancements and improvements such as the
establishment of Nature Networks and building on natural capital assets
such as peatland restoration, woodland creation and natural flood
management;
 The need to realise the area’s full potential for electricity and heat from
renewable, low carbon and zero emission sources whilst taking account
of energy infrastructure, ability to connect to the grid, utility network
plans, the Local Heat and Energy Efficiency Strategy, areas of heat
network potential and balancing this with environmental concerns such
as impact on the landscape;
 The low proportion of brownfield land in the area and the limited
contribution of such sites towards meeting the overall land requirements
resulting in the need for more greenfield land release;
 An available supply of housing sites to ensure there is a deliverable
housing land pipeline for the Local Housing Land Requirement which
addresses the need for increased provision of affordable homes, self-
provided homes, the enhanced emphasis in NPF4 on the delivery of new
housing in rural areas, and homes to meet particular needs;
 A tailored approach for rural areas which considers how to distribute the
land supply requirements for housing, employment uses etc, against the
requirement to reduce the need to travel and avoid suburbanisation of
rural communities, particularly in rural areas which are currently
declining and those rural populations which are most at risk of transport
poverty;
 The majority of current allocated employment land supply is constrained
and unlikely to be developed in the short-medium term without any
public sector intervention;
 Working in partnership with relevant agencies to support and coordinate
an infrastructure first approach between infrastructure providers to
facilitate development;
 Focusing on ill health prevention through promoting places that
contribute to good health and wellbeing, and giving careful consideration
to funding options for new healthcare infrastructure;
 Supporting the regeneration and changing role of town centres including
the delivery of town centre living and redevelopment and refurbishment
of vacant buildings and brownfield land;
 Provision of rural and neighbourhood scale retail;

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 The need to strike a balance between supporting the recovery and future
growth of the tourism sector against the existing and potential for
adverse impacts on local communities and the environment of
accommodating that recovery and growth;
 Developing green networks that, where possible, link to nature networks,
connecting natural spaces in rural and urban areas. Green networks
include an active travel element that will contribute to Local Living and
20-minute neighbourhoods, mitigating transport related emissions.
Engagement
4.9 As noted at paragraph 4.2 above, extensive engagement has taken place in
the preparation of the evidence report in line with the statutory requirements.
A full summary is included in Chapter 3 of the Evidence Report, but the main
elements have been as follows:
 The Big Place Conversation (BPC): Place Standard Engagement -
This extensive engagement process took place from January to
September 2023.  Community Councils were engaged with to help
shape the engagement in their area. An online survey was open during
this time hosted on a dedicated BPC webpage, as well as providing
opportunities for communities to feedback through a range of in-person
and online events. These included public events, drop-in sessions, and
roundtable in person and online facilitated discussions using the Place
Standard Tool (a simple framework to structure conversations about
place). The drop-in sessions were more informal events to allow for
quicker feedback on the Place Standard topics to complement the
roundtable discussions. The engagement process gathered feedback
from communities on how they viewed different elements of their place
and where they felt improvements could be made. A total of 272 survey
responses were received, and nearly 1300 people attended the 114
events which were held during the engagement programme. In addition,
as part of the BPC officers undertook an extensive programme of
engagement with children and young people. This involved Place
Standard sessions with primary and secondary schools, as well as
dedicated workshops with established youth groups.  A total of 28
dedicated sessions were held and attended by nearly 400 children and
young people.
 Topic Paper Consultation - The Council produced and consulted on a
series of Topic Papers which covered each subject matter contained in
NPF4’s national planning policies suite.  The papers were published on
the Council’s Consultation Hub for a 6-week period during July and
August 2024. These papers incorporated a provisional view of the
evidence gathered and asked parties to identify gaps, suggest additional
evidence, and identify areas of agreement/disagreement. This attracted
responses from 51 parties, making a total of 287 comments across the
topic papers.
 Key Stakeholders - As part of the development of the topic papers and
the Evidence Report officers engaged with the key agencies as
prescribed through the Planning Act.

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These included NatureScot, SEPA, Scottish Water, Scottish Enterprise,
Tactran, NHS Tayside and Historic Environment Scotland. All key
agencies were welcome to respond in relation to any of the topic papers
during the 6-week consultation period. Where feedback was specifically
sought on a particular issue, officers sent targeted engagement
invitations to key agencies and other relevant parties/stakeholders
flagging the most relevant papers which could benefit from their input.
Officers also worked closely with a number of internal teams including
Climate Change and Sustainable Development, Conservation, Economic
Development, Structures and Flooding, Property Services – Education,
Transport Planning, and the Health and Social Care Partnership.
Next Steps
4.10 Subject to approval of the Evidence Report by the Council, some additional
technical work will be needed to prepare it for the Gate Check, notably
confirming embedded hyperlinks to web information. Since information is
constantly changing, it may be that minor factual updates will also be needed
post approval. Consequently, the recommendation asks members to delegate
authority to the Strategic Lead (Economy, Development and Planning) to
make any necessary minor changes or updates to the Evidence Report prior
to its submission to Scottish Ministers.
4.11 On submission of the Evidence Report to Scottish Ministers for the Gate
Check, the Scottish Ministers will appoint a Reporter from the Scottish
Government Division of Planning and Environmental Appeals (DPEA) to
independently assess the evidence to prepare the LDP3 Proposed Plan.
4.12 Following the assessment of the Evidence Report, the Reporter will either
prepare a letter setting out that the Evidence Report contains sufficient
evidence to prepare LDP3, and the reasoning for this, or prepare an
‘Assessment Report’ setting out the reasons that they are not satisfied that the
Evidence Report contains sufficient evidence and the recommendations for
improving the evidence. A copy of the letter of Assessment Report will be sent
to the Planning Authority and the Scottish Ministers. Where an Assessment
Report is issued the Planning Authority will be required to address the areas
of improvement and resubmit the Evidence Report to the Gate Check.
5. Conclusion
5.1 The Council has commenced preparation of LDP3, the first major stage of
which is the preparation of the Evidence Report. This will provide a robust
compendium of evidence on which the Proposed Plan can be based.
5.2 Whilst there are a small number of disputes on the evidence, the majority of
key stakeholders are in agreement with the sufficiency of evidence. It is
considered that there is sufficient evidence to move forward with the
preparation of LDP3 to the Gate Check. Following approval of the Evidence
Report it will be submitted to the Scottish Ministers for the Gate Check at the
end of March.

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There is an expectation based on information from the Scottish Government
that the Gate Check process should take approximately 3 months, however,
this will depend on the complexity of issues in the Evidence Report.
6. Impact Value Assessment
Impact Value Assessment - Perth and Kinross Local Development Plan LDP3
Evidence Report
7. Appendices
7.1 Appendix 1 – Perth and Kinross Local Development Plan 3 – Evidence Report