Perth and Kinross Local Development Plan 3 Evidence Report
Perth and Kinross Council · 5 March 2025
Back to Perth and Kinross Council — 5 March 2025 and its agenda
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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