Appendix 1 - Perth and Kinross Local Development Plan LDP3 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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Perth and Kinross LDP3 2027 Proposed Evidence Report (Draft) March 2025
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3 Table of Contents Glossary of Terms and Abbreviations 6 1 Introduction 8 FORM AND CONTENT REQUIREMENTS – EVIDENCE REPORTS 8 STYLE AND SCOPE OF EVIDENCE REPORT 8 2 Profile of the Perth and Kinross Area 14 PRINCIPAL CHARACTERISTICS OF THE AREA 14 Physical Characteristics 14 Cultural Characteristics 24 Economic Characteristics 28 Social Characteristics 33 Built Heritage Characteristics 34 Environmental Characteristics 35 PRINCIPAL PURPOSES FOR WHICH THE LAND IS USED 37 SIZE, COMPOSITION, HEALTH AND DISTRIBUTION OF POPULATION OF THE AREA 39 RURAL AREAS AND POPULATION DECLINE 46 HEALTH NEEDS OF THE POPULATION OF THE AREA 50 EDUCATION NEEDS OF THE POPULATION OF THE AREA AND SERVICE CAPACITY 50 3 Participation and Engagement 54 PARTICIPATION AND ENGAGEMENT STATEMENT 54 4 Perth and Kinross LDP2 Monitoring 64 DELIVERY OF PERTH AND KINROSS LOCAL DEVELOPMENT PLAN 2 64
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4 5 Evidence Gathering - Information on Issues 87 APPROACH TAKEN TO THE COLLATION OF EVIDENCE 87 GAPS, UNCERTAINTIES, KEY ISSUES AND FORMAL DISPUTES 89 TABLE OF GAPS, UNCERTAINTIES AND KEY ISSUES RAISED IN EVIDENCE 90 TABLE OF FORMAL DISPUTES TO THE EVIDENCE REPORT 101 SUSTAINABLE PLACES 105 SUSTAINABLE PLACES 106 LIVEABLE PLACES 138 LIVEABLE PLACES 139 HOMES 160 INFRASTRUCTURE AND TRANSPORTATION 167 PRODUCTIVE PLACES 186 PRODUCTIVE PLACES 187 6 Summary of Key Issues for the LDP3 Spatial Strategy 205 SUMMARY OF MAIN ISSUES BY THEME AND KEY POLICY CONNECTIONS 205 Sustainable Places 206 Liveable Places 215 Homes 221 Infrastructure and Transportation 222 Productive Places 227 7 Links to Strategic Environmental Assessment 233 REQUIREMENT FOR SEA: PERTH AND KINROSS LOCAL DEVELOPMENT PLAN 3 233 BENEFITS OF SEA 233
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5 NEXT STEPS 234 8 Local Place Plans 235 INVITATION TO PREPARE LOCAL PLACE PLANS 235 ASSISTANCE PROVIDED TO LOCAL COMMUNITIES 235 9 Approval of Evidence Report 237 APPROVAL PROCESS AND NEXT STEPS 237
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6 Glossary of Terms and Abbreviations Evidence Report A supporting document to the Local Development Plan. The Evidence Report provides a summary of the evidence base for a plan’s spatial strategy, policies, and proposals. It demonstrates that consideration has been given to the issues relevant to the plan area, and that appropriate consultation and engagement has been carried out and taken account of in preparing a plan. Gatecheck This is an assessment of the sufficiency of the evidence base on which the Proposed Local Development Plan will be developed. It is undertaken by an appointed person from the Scottish Government’s Planning and Environmental Appeals Division. Historic Assets As defined in Historic Environment Policy 2019, an asset, or historic or heritage asset ‘is a physical element of the historic environment – a building, monument, site, place, area or landscape identified as having cultural significance. Historic Environment As defined in Historic Environment Policy 2019, ‘the historic environment is our surroundings as they have been shaped, used and valued by people in the past, and continue to be today. It is central to our everyday life lives and our sense of place, identity and wellbeing. Local Development Plan (LDP) A plan which sets out, for the land in the part of the district it relates to, a spatial strategy; any other such matters as may be prescribed by the Scottish Ministers, and any other matters which the planning authority consider appropriate to include. National Planning Framework 4 (NPF4) NPF4 is the national spatial strategy for Scotland. It sets out the Scottish Government’s spatial principles, regional priorities, national developments, and includes a suite of national planning policy. NPF4 was adopted in February 2023. Proposed Plan The draft stage of the Local Development Plan, which must be approved by full Council before it can move on to its consultation stage. Spatial Strategy The detailed statement (usually represented through mapping as well accompanying text) of a planning authority’s policies and proposals regarding the development and use of land for the area for which the plan applies.
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7 Strategic Environmental Assessment (SEA) A systematic way of identifying, predicting, reporting, mitigating, and monitoring the environmental effects of plans, programmes, policies, and strategies. The Environmental Assessment (Scotland) Act 2005 provides information on the detailed stages and requirements for SEA in Scotland. Sustainable Development As defined in 1987 by the Brundtland Report: Our Common Future, it is development which meets the needs of the present without compromising the ability of future generations to meet their own needs. Sustainable Economic Growth Economic development that is conducted in a manner which does not lead to the depletion of natural resources.
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8 1 Introduction 1.1 Under Section 16(B)(1) of the 2019 Planning Act 1, planning authorities are required to prepare an Evidence Report before preparing a Local Development Plan. An Evidence Report should contain sufficient information to enable the planning authority to move on to the next stage and prepare their Local Development Plan (LDP). 1.2 The purpose of an Evidence Report is to provide the planning authority’s interpretation of the evidence it has gathered and the likely implications of that evidence for the preparation of their LDP. The Report will provide a summary of what the evidence means for the plan, rather than contain all the detail of evidence collected. FORM AND CONTENT REQUIREMENTS – EVIDENCE REPORTS 1.3 The 2019 Act sets out the detailed requirements with regards to the preparation of Evidence Reports, including their form, content, consultation and engagement expectations, and approval processes. The Scottish Government’s May 2023 Local Development Plan Guidance also provides useful step by step advice and guidance regarding the preparation of Evidence Reports to assist planning authorities in meeting their legislative requirements under both the Act and Development Planning Regulations2. 1.4 Table 1 to follow lays out the key prescribed requirements for our Perth and Kinross LDP3 Proposed Evidence Report and identifies under which section of this report those requirements have been addressed. Sections 2 to 8 constitute our LDP3 Proposed Evidence Report. STYLE AND SCOPE OF EVIDENCE REPORT 1.5 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. 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 in Appendices A-G, with summaries of the information included within the relevant chapters of the document. 1 The Town and Country Planning (Scotland) Act 1997, as amended by the Planning (Scotland) Act 2019 2 The Town and Country Planning (Development Planning) (Scotland) Regulations 2023
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9 Table 1: Legislative Requirements for Local Development Plan Evidence Reports Required Under Detailed Requirements for the Evidence Report Relevant Section of Report The Town and Country Planning (Scotland) Act 1997, as amended by the Planning (Scotland) Act 2019 [the Act] - Part 2, Section 16B(2) In preparing the evidence report, the planning authority are to seek the views of and have regard to any views expressed by the key agencies, children and young people (in particular school pupils, youth councillors and young parliament representatives), such persons as may be prescribed, and the public at large. Section 3, Participation and Engagement, pages 54-63 The Act – Part 2, Section 16B(3) and Section 15(5)(a) The planning authority’s views on the principal physical, cultural, economic, social, built heritage and environmental characteristics of the land in the district. Section 2, Profile of the Perth and Kinross Area, pages 14-37 The Act – Part 2, Section 16B(3) and Section 15(5)(b) The planning authority’s views on the principal purposes for which the land is used. Section 2, Profile of the Perth and Kinross Area, pages 37-38 The Act – Part 2, Section 16B(3) and Section 15(5)(c) The planning authority’s views on the size, composition, health, and distribution of the population of the district. Section 2, Profile of the Perth and Kinross Area, pages 39-46 The Act – Part 2, Section 16B(3) and Section 15(5)(ca) The planning authority’s views on the housing needs of the population of the area (including, in particular, the needs of persons undertaking further and higher education, older people and disabled people). Section 5, Evidence Gathering - Information on Issues Issue: Homes, page 163 The Act – Part 2, Section 16B(3) and Section 15(5)(cb) The planning authority’s views on the availability of land in the district for housing, including for older people and disabled people. Section 5, Evidence Gathering - Information on Issues Issue: Homes, pages 163-164 The Act – Part 2, Section 16B(3) and Section 15(5)(cc) The planning authority’s views on the desirability of allocating land for the purposes of resettlement. Section 5, Evidence Gathering - Information on Issues Issue: Homes, pages 197 The Act – Part 2, Section 16B(3) and Section 15(5)(cd) The planning authority’s views on the health needs of the population of the district and the likely effects of development and use of land on those health needs. Section 2, Profile of the Perth and Kinross Area, page 50 The Act – Part 2, Section 16B(3) and Section 15(5)(ce) The planning authority’s views on the education needs of the population of the district and the likely effects of development and use of land on those education needs. Section 2, Profile of the Perth and Kinross Area, pages 50-53
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10 3 References to systems for the supply of energy include in particular land available for the development and use of facilities for renewable sources of energy. (Section 15 subsection (5A) 4 “Accommodation needs” includes, but is not limited to, needs with respect to the provision of sites on which mobile homes may be stationed. Required Under Detailed Requirements for the Evidence Report Relevant Section of Report The Act – Part 2, Section 16B(3) and Section 15(5)(cf) The planning authority’s views on the extent to which there are rural areas within the district which have experienced a substantial decline in population. Section 2, Profile of the Perth and Kinross Area, pages 46-49 The Act – Part 2, Section 16B(3) and Section 15(5)(cg) The planning authority’s views on the capacity of education services in the district. Section 5, Evidence Gathering – Information on Issues Issue: Infrastructure - Education Facilities, page 173 The Act – Part 2, Section 16B(3) and Section 15(5)(ch) The planning authority’s views on the desirability of maintaining an appropriate number and range of cultural venues and facilities (including in particular, but not limited to, live music venues) in the district. Section 5, Evidence Gathering – Information on Issues Issue: Culture and Creativity, page 202 The Act – Part 2, Section 16B(3) and Section 15(5)(d) The planning authority’s views on the infrastructure of the district (including communications, transport and drainage systems, systems for the supply of water and energy3, and health care and education facilities). Section 5, Evidence Gathering – Information on Issues Issue: Infrastructure and Transportation pages 170, 173, 176- 177, 180-182, 184-185 The Act – Part 2, Section 16B(3) and Section 15(5)(e) The planning authority’s views on how that infrastructure is used. Section 5, Evidence Gathering – Information on Issues Issue: Infrastructure and Transportation pages 170, 173, 176- 177, 180-182, 184-185 The Act – Part 2, Section 16B(3)(b)(i) and (ii) A summary of the action taken by the planning authority to support and promote the construction and adaptation of housing to meet the housing needs of older people and disabled people in the authority’s area, and an analysis of the extent to which the action has helped to meet those needs. Section 5, Evidence Gathering - Information on Issues Issue: Homes, pages 164-165 The Act – Part 2, Section 16B(3)(c)(i) and (ii) A summary of the action taken by the planning authority to meet the accommodation needs 4of Gypsies/Travellers in the authority’s area, and an analysis of the extent to which the action has helped meet those needs. Section 5, Evidence Gathering - Information on Issues Issue: Homes, page 165
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11 Required Under Detailed Requirements for the Evidence Report Relevant Section of Report The Act – Part 2, Section 16B(3)(d)(i) Set out how the planning authority have invited local communities in their district to prepare Local Place Plans in accordance with Schedule 19. Section 9, Local Place Plans, pages 235 The Act – Part 2, Section 16B(3)(d)(ii) Set out the assistance provided to local communities to assist them to prepare Local Place Plans. Section 9, Local Place Plans, pages 235-236 The Act – Part 2, Section 16B(3)(e) Include any such matters as prescribed. The Act – Part 2, Section 16D(1) Include an assessment of the sufficiency of play opportunities in its area for children in preparing an Evidence Report. Section 5, Evidence Gathering - Information on Issues Issue: Play, Recreation and Sport, page 153 The Act – Part 2, Section 16B(4)(a)(i) to (iii) and 16B(4)(c) Include a statement on how the planning authority, in preparing the report, sought the views of the public at large, including, in particular, the views of disabled persons, Gypsies/Travellers, and children and young people, and the extent to which the views expressed have been taken into account in the report. Section 3, Participation and Engagement, pages 54-55, 60-63 The Act – Part 2, Section 16B(4)(b) and 16B(4)(c) Include a statement on the steps taken by the planning authority in preparing the report to seek the views of community councils, and the extent to which the views expressed have been considered in the report. Section 3, Participation and Engagement, page 63 The Act – Part 2, Section 16B(5) Before submitting a Proposed Evidence Report, the planning authority must approve it. Section 9, Approval of Proposed Evidence Report, page 237 LDP Guidance – Evidence Gathering, Paragraphs 89-91 The Regulations do not include minimum evidence requirements. The Evidence Report should consider the local, regional and national strategies and policy priorities that could impact on the direction and subsequent implementation of the LDP, and which will shape the requirements of the evidence base. In gathering the evidence for their plan, planning authorities should be thinking ahead to the ‘Information and Considerations’ and content requirements that must be included in the Proposed Plan. Where required, reasonable steps should be taken to address any gaps in evidence gathered. Section 5, Evidence Gathering – Information on Issues, pages 87-187, Appendices A-E
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12 Required Under Detailed Requirements for the Evidence Report Relevant Section of Report LDP Guidance – Evidence Gathering, Paragraphs 92 The Evidence Report can support an Infrastructure First approach by including an assessment of the capacity of existing infrastructure and services. Section 5, Evidence Gathering – Information on Issues Issue: Infrastructure and Transportation, pages 167-185, Appendix D LDP Guidance – Evidence Gathering, Paragraphs 93 As part of the preparation of the Evidence Report, the planning authority should evaluate whether the previous plan has delivered on its outcomes, and allocations, identify any lessons learnt for the preparation of the new plan and consider the appropriateness of the previous spatial strategy. N.B. new proposals or site-specific detail should not be included at this stage. Section 4, Perth and Kinross LDP2 Monitoring, pages 64-86 LDP Guidance – Drafting the Evidence Report, Paragraph 108 The Evidence Report should not include detailed policies and site proposals. Detailed site appraisal will not be appropriate at the Evidence Report stage, but the planning authority could develop a site appraisal methodology for appraising sites and informing allocations for the Proposed Plan which could be linked or integrated with the approach to SEA assessment. Section 8, Links to Strategic Environmental Assessment (SEA), pages 233-234 LDP Guidance – Drafting the Evidence Report, Paragraph 109 The Evidence Report may be collated around issues – either policy topics or places. A suggested template is provided in the LDP Guidance at Figure 7, page 33. Section 5, Evidence Gathering – Information on Issues, pages 87-88 LDP Guidance – Drafting the Evidence Report, Paragraph 111 To help the Gate Check process, planning authorities should identify where there are any potential gaps in the evidence gathered or uncertainty in data and evidence within the Evidence Report, along with an explanation of the authority’s reason for accepting this evidence and including it in the Report. This should be set out clearly under the ‘Summary of Evidence’ heading in the template at Figure 7, page 33. Section 5, Evidence Gathering – Information on Issues, pages 87-204, Appendices A-E, Summary Table pages 90-100 LDP Guidance – Drafting the Evidence Report, Paragraph 113 The Evidence Report should highlight areas where the planning authority is aware, through discussions etc. that stakeholders agree or disagree with the evidence, and the reasons for this. Section 5, Evidence Gathering – Information on Issues, pages 87-204, Appendices A-E, Summary Table pages 101-103
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13 Required Under Detailed Requirements for the Evidence Report Relevant Section of Report LDP Guidance – Drafting the Evidence Report, Paragraph 114 The Evidence Report should bring together the ‘Summary of Implications for the Proposed Plan’ and ‘Statements of Agreement/ Dispute’ for all the topics to help allow for connections to be made across issues, and flag key issues. Section 6, Summary of Implications for the Proposed Plan and Summary of Key Issues, pages 205-232 LDP Guidance – SEA, Paragraphs Preparation of the Evidence Report should be aligned with the scoping of SEA. The Evidence Report must set out the planning authority’s views on ‘environmental characteristics’ of the plan area, as per Section 15(5) of the Act. The material that informs the SEA Scoping Report and the Evidence Report are likely to be similar. Section 7, Links to Strategic Environmental Assessment (SEA), pages 233-234
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14 2 Profile of the Perth and Kinross Area PRINCIPAL CHARACTERISTICS OF THE AREA 2.1 The paragraphs to follow provide an overview of the principal physical, cultural, economic, social, built heritage and environmental characteristics of the Perth and Kinross Area, as required under Section 16B(3) and Section 15(5)(a) of the Planning Act. More detailed information and evidence relating to these characteristics is summarised under the range of issues covered by this Evidence Report and within our LDP3 background Topic Paper 001: The Plan Area and Strategic Environmental Assessment (SEA) Scoping Report. Physical Characteristics 2.2.1 The Perth and Kinross Council Area is situated in the heart of Scotland, just north of the Central Belt bordering Aberdeenshire, Angus, City of Dundee, Fife, Clackmannanshire, Stirling, Argyll and Bute, and Highland Council areas. The Cairngorms National Park is located to the north, and the Loch Lomond and the Trossachs National Park to the west. 2.2.2 The Area covers 5,286km2 (4,707km2 excluding the part of Perth and Kinross within the Cairngorms National Park) and is the 5th largest unitary authority in terms of area in Scotland, and the 12th largest in respect of population size. It is an area of outstanding natural beauty, containing both highland and lowland landscapes. 2.2.3 Figure 1 to follow shows the overall Perth and Council Area, within the context of Scotland, and the part of PKC within the National Park Area (see green boundary line in top left inset map). 2.2.4 The area is characterised by a diverse mix of urban and rural communities, from the main population centre of Perth, and towns such as Blairgowrie, Crieff, Kinross, Auchterarder and Pitlochry, to extremely remote communities such as Kinloch Rannoch in the Highland area. Figure 1: The Perth and Kinross Council Area 2.2.5 The Highland Boundary Fault (Figure 2) runs across the area from the northeast to the southwest, roughly dividing the landscape of Perth and Kinross between the distinct geological areas of Highland Perthshire, and Lowland Perthshire and Kinross. The division is very much reflected in the topography, vegetation, and
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15 land use of those areas. Both are characterised by a diverse mix of rural and urban land use, which varies considerably from rich lowland arable farming to extensive upland forestry, and from the main population centre of Perth to small, remote communities, such as Kinloch Rannoch. Figure 2: The Highland Boundary Fault Line with Perth and Kinross 2.2.6 There are 10 main Landscape Character Types present within the Perth and Kinross Council Area, as categorised by the map-based national Landscape Character Assessment. These are: • Summits and Plateaux – Tayside (22.5%) • Summits and Plateaux – Cairngorms (10.7%) • Traditional Moorland and Forest (8.9%) • Lowland Hills – Tayside (8.8%) • Lowland Hill Ranges (8.6%) • Mid Upland Glens (7.1%) • Lower Upland Glens (6.3%) • Mid Upland Glens with Lochs (4.7%) • Lowland Basins (3.3%) • Upland Glen – Cairngorms (3.0%) 2.2.7 Figure 3 to follow shows the distribution of all landscape character types (not just the main ones listed above) across the Council Area and can be viewed in more detail in our LDP3 SEA Scoping Report.
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16 Figure 3: Landscape Character Types within Perth and Kinross
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17 2.2.8 Historic Environment Scotland’s Historic Land Use Assessment (HLA) shows the extent of changes that have occurred to the environment. It plots those land-uses which are still in existence at a scale of 1:25,000, describing them by function and period. It maps both current, and where surviving, previous land uses. An HLA has been undertaken for a large percentage of the Council Area. Figures 4 and 5 to follow show the HLA coverage available for Perth and Kinross and main classification categories, and Table 2 below a breakdown of key historic land uses across the area. Please note, this information can be viewed in more detail within our LDP3 SEA Scoping Report. Table 2: Key Historic Land Use within Perth and Kinross Historic Land Use Category Area (km2) Woodland and Forestry 806.6 Agriculture and Settlement 760.9 Moorland and Rough Land Grazing 503.7 Waterbody 87.0 Designed Landscapes 59.4 Built Up Area 45.5 Leisure and Recreation 33.9 Defence 19.1 Energy Extraction and waste 12.8 Rural Settlement 4.3 Transport 3.2 Spiritual and Ritual 0.4 2.2.9 A clear distinction can be seen in Figure 4 between the moorland and rough grazing, and woodland and forestry in the upland area, and agriculture in the lowland areas.
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18 Figure 4: HLA for the Perth and Kinross Area (Land Uses/ Function)
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19 Figure 5: HLA for the Perth and Kinross Area (Time Periods)
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20 2.2.10 The National Land Capability for Agriculture in Scotland Map, which was produced by the Macaulay Institute for Soil Research during the 1980’s, provides a land classification system, ranking land on the basis of its potential productivity and cropping flexibility. 2.2.11 Land Classes 1 to 3.1 are typically referred to as ‘Prime Agricultural Land’ and are capable of being used to produce a wide range of crops. Classes 3.2 to 4.2 are regarded as land capable of supporting mixed agriculture, which can be used to grow a moderate range of crops, including potatoes and cereals, forage crops and grass. Historically the Development Plan has sought to protect the loss, through development, of land within Classes 1, 2, and 3.1. There is no Class 1 land within the Perth and Kinross Council Area. Table 3 and Figure 6 show the scale and distribution of Classes 2, and 3.1 across the area, and Class 3.2 has also been included due to its potential to produce some crops. More detailed maps can be viewed under the Soils issue of this Evidence Report, and the SEA Scoping Report Environmental Baseline. Table 3: Breakdown of Prime Agricultural Land within PKC Map Key Class Area (Ha) % of Perth and Kinross Class 2: Land capable of producing a wide range of crops. 25,946.4 4.9% Class 3.1: Land capable of producing consistently high yields of a narrow range of crops and/or moderate yields of a wider range. Short grass leys are common. 36,485.7 6.9% Class 3.2: Land capable of average production though high yields of barley, oats and grass can be obtained. Grass leys are common. 57,877.54 11%
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21 Figure 6: Overview of Prime Agricultural Land within PKC
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22 2.2.12 The National scale Land Capability for Forestry Map provides information on the potential for land across Scotland to grow trees based on a number of factors, including soil, climate, and topography. The map was produced by the Macauley Land Use Research Institute and also uses a classification system of Classes F1 through to F7 in terms of capability. Classes F8 and F9, represent, respectively, built-up areas and areas of inland water. 2.2.13 Figure 7 and Table 4 to follow show the location of those classes within Perth and Kinross and provide a breakdown of that coverage. The total amount of the PKC area which is covered by Classes F1 – F4, i.e. land which is excellent through to that with moderate flexibility for the growth and management of tree crops, is 2,044 Km2, which equates to 38.66% of the total Council Area. A more in depth look at across the area has been carried out for the Forestry, Woodland and Trees issue of this Evidence Report. Table 4: Breakdown of Land Capability for Forestry within PKC Map Key Class Area (Km2) % of Perth and Kinross F1 – Land with excellent flexibility for the growth and management of tree crops 23.27 0.44% F2 – Land with very good flexibility for the growth and management of tree crops 247.04 4.67% F3 – Land with good flexibility for the growth and management of tree crops 342.28 6.48% F4 – Land with moderate flexibility for the growth and management of tree crops 374.68 7.09% F5 – Land with limited flexibility for the growth and management of tree crops 451.34 8.54% F6 – Land with very limited flexibility for the growth and management of tree crops 338.14 6.40% F7 – Land unsuitable for producing tree crops 266.94 5.05%
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23 Figure 7: Overview of Land Capability for Forestry in PKC
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24 Cultural Characteristics 2.3.1 Culture is at the heart of every community in Perth and Kinross. Historically and culturally Perth and Kinross have played an important role at the heart of Scotland. It is home to some of most beautiful countryside in the world linked by the Rivers Tay, Earn, Almond, Garry, and Isla. Ancient drove roads and the Wade Roads built following the Jacobite Risings of the early 18th Century criss-cross the land, which is also rich in designated and undesignated heritage assets. The area around Forteviot, to the east of Perth, was known as the ‘Cradle of Scotland’, and is the place where Picts, Gaels and Scots came together to create the Kingdom of Alba in the time after the Romans left. 2.3.2 Perth and Kinross Council has been a local authority since local government reorganisation in 1996. Perth regained its City Status in 2012 and became Scotland’s 7th city. Perth College is part of the University of the Highlands and Islands (UHI) and boasts 650 culture and creative industry students. 2.3.3 The area has a mix of nationally recognised creative organisations who produce innovative and exciting new work for and about the people of Perth and Kinross and bring global artists and creative work to the area. This nationally and internationally important work connects with homegrown talent in the form of artists, makers, writers, musicians, poets, and actors who live and work here. 2.3.4 Local museum collections represent past generations who lived on and worked the land, and events at local pubs and community halls keep alive traditional music, stories, and song. 2.3.5 There are several festivals held to celebrate some of the area’s greatest cultural figures, including the Neil Gow Festival (Birnam), the Soutar Scots Language and Literature Festival, Perth Festival of the Arts, and Blairgowrie’s Bookmark Festival. 2.3.6 The area’s communities have always been rich and diverse, and this has been further strengthened in recent years with people from all over the world making Perth and Kinross their home, bringing with them a range of cultural traditions and creativity. Our Gypsy Traveller communities have roots here, dating back centuries. 2.3.7 There are two major producing theatres in the area, several museums of UK and national significance, including the new Perth Museum which houses the Stone of Destiny, the Scottish Crannog Centre, and the Black Watch Museum. The area’s cultural venues are mostly run by charities and community-led organisations, many of which are revenue or grant-funded by the Council. 2.3.8 The Council works closely with neighbouring local authorities, including through the Tay Cities Deal – a £150 million agreement between the UK and Scottish Governments to make the region smarter and fairer through investment in innovation, international links, and cultural tourism.
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25 2.3.9 The Council’s Culture Strategy 2023-2028 reports on the Council Area across seven distinct localities each with their own cultural qualities and significance. Figure 8 on the following page shows the spatial distribution of these localities, and the text to follow, the key cultural characteristics.
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26 Figure 8: Localities within Perth and Kinross
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27 2.3.10 These localities are: 1. Perth City, which is the main urban centre in Perth and Kinross. It is compact, walkable and contains several beautiful parks, and the River Tay running through it. It has an important heritage as Scotland’s first capital, and a growing contemporary art scene. Some of its assets include the Concert Hall, Perth Theatre, Perth Art Gallery, Perth Museum, and the AK Bell Library, which is Scotland’s 4th busiest library. Other important assets are - a range of light and art installations across the city, including in historic medieval vennels; the Creative WASPS Hub (home to makers and creatives), and the University of the Highlands and Islands/ Perth College, which has a curriculum specialising in music technology and other creative subjects. In addition, there is also a range of independent charities who operate the theatre, concert hall, museums and libraries and who offer programmes across all art forms and creative learning opportunities for all ages. Perth City also has independent organisations, such as Ad-lib Arts and Julie Young Dance School, who provide training for local children and young people in performing arts. 2. Eastern Perthshire is a rural area with the 3 towns of Blairgowrie (which has the largest population after Perth), Coupar Angus, and Alyth. It covers Strathmore, the Carse of Gowrie, and Blairgowrie and the Glens. The area is regarded as a place of traditional storytelling, poetry, and song, walks and outdoor living. Blairgowrie was the birthplace of Hamish Henderson, a Scottish poet, songwriter, soldier, and known as the founding father of Scotland’s 20th Century folk renaissance. It is also an area that is rich in farming, which provides an inspiration and resource for the social history museum collection in Alyth. The Nest in Blairgowrie is a hub of creativity activity, focussed on the surrounding community, and the town also hosts the annual Bookmark Festival during October. 3. Highland Perthshire, which boasts more than 200,000 acres of woodlands, is known as ‘Big Tree Country’. The area also contains spectacular mountains, glens, large lochs, and historic towns and villages, and is home to musicians, makers, and creatives. The two biggest towns are Pitlochry and Aberfeldy. Highland Perthshire has witnessed some of the most turbulent and important events in Scottish history with the stunning views of Schiehallion, the Queen’s View at Loch Tummel, the hydro-electric dams built in the early 20th Century, and traces of the 19th Century Highland Clearances are all part of the area’s landscapes and stories. Perthshire Gaelic was the majority language in the Highlands, and in Perth, until the late medieval period, and native Gaelic speakers continued to live in the Highlands until very recently. Some of the area’s cultural assets include: the Pitlochry Festival Theatres; the Birk’s Cinema, which is a community owned facility hosting music, spoken word, and film festivals, and the Scottish Crannog Centre at Kenmore, which is expanding its site via a Community Asset Transfer and Scottish Government grant, to tell the story of the Iron Age people who lived on the waters of Loch Tay. 4. Strathtay is a rural area in the centre of Perth and Kinross. It is home to the two busy towns of Birnam and Dunkeld. The area is surrounded by stunning scenery, and the River Tay runs through the centre of it. Traditional music is still an important part of community life in this area. The Birnam Arts Centre, which is also a community-owned and managed asset, has a café, shop, gallery, and auditorium, and hosts a range of events across the year. The area hosts a few unique home-grown events and festivals, including the Neil Gow Festival, which celebrates the famous fiddler who set many of Robert Burns’ songs and poems to music.
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28 5. In the Almond and Earn area, much of the population primarily live in villages – there are no major towns. However, parts of the area are close to Perth. Abernethy is the largest village in the area and has an independently run museum where you can climb to the top of Abernethy Round Tower. The tower dates to 1100 and is one of only two Irish-style round towers in Scotland. Culture in the area thrives in local clubs, village halls and groups which have been created and run by local people, including the cinema club. 6. Strathearn and Strathallan are located to the south-west of Perth. The area’s biggest towns are Crieff and Auchterarder, and are surrounded by mountains, lochs, and rivers. The Gleneagles Hotel, which opened in 1924, Crieff Hydro, and Drummond Castle, are some of the major attractions which help the area contribute 23% of tourism revenue to Perth and Kinross. Innerpeffray Library, close to Crieff, is the oldest public lending library in the UK, and it is still possible to study and view its important special collection there. There are several active arts organisations, including Strathearn Arts, which is a major provider of culture in the area; Radio Earn radio station; regular concerts across the year, and a range of local culture and heritage groups and classes. The area is also home to a few small creative businesses. 7. Kinross-shire lies between Fife and Perthshire, and boasts plenty of beautiful scenery and walks, including Loch Leven, which is an RSPB National Nature Reserve, where you can spot rare birds and the castle where Mary Queen of Scots was held captive. Kinross is the main town in the area and houses one third of Kinross-shire’s overall population. Kinross-shire has a proud music scene, with music being played in local pubs and hotels, and by young people, the orchestras, and choirs who meet. 2.3.11 Gaelic Culture and Heritage is also an important aspect of the cultural characteristics of Perth and Kinross. The area’s Gaelic heritage includes a wealth of stories and songs, traditional Gaelic melodies, and a landscape full of Gaelic place names. Further information on the Gaelic heritage of the area, including books and records, and signposts to ways of accessing Gaelic education within Perth and Kinross are covered under the Culture and Creativity issue of this Evidence Report. Economic Characteristics 2.4.1 In the years immediately preceding the COVID-19 pandemic, the Perth and Kinross economy had experienced growth, with higher- than-average rates of employment (particularly through self- employment), very low unemployment, and higher than the national level increases for VAT business registrations. Tourism revenue had also grown, with tourism related employment accounting for 13% of the total workforce of the area. 2.4.2 The paragraphs and tables to follow provide an overview of the economic performance within Perth and Kinross across several key economic performance indicators. These indicators mirror those reported in the Tay Cities Regional Economic Strategy (2019 – 2039). 2.4.3 Productivity and Earnings – the Gross Value Added (GVA) in Perth and Kinross Area is better than the Scottish average; the average workplace weekly wage is lower than the Scottish average, but the average resident weekly wage for the area is slightly higher.
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29 Table 5: Overview of Economic Performance within Perth and Kinross Indicator Perth and Kinross Scotland GVA per head of population (2021) £27,755.02 £27,361.45 GVA per job (2021) £55,441.56 £52,869.53 GVA per hour worked (£) £39.50 £36.90 Growth in total GVA (2017 - 2021) +1.4% +6.9% Employment rate (16 to 64 years) (12 months to September 2023) 76.9% 75.2% Employment rate growth (2018 – 2023, percentage points) -0.1 +0.9 Average (median) workplace weekly wage (2023) £671.90 £702.80 Average (median) resident weekly wage (2023) £727.70 £702.40 2.4.4 Business Base – The business base for the area tends to mirror that of Scotland as a whole, with the exception of the number of businesses per 10,000 of the working age population - which is significantly higher than the national average, and the growth in number of businesses between 2018 and 2023, which has experienced less of a decline during that period than Scotland as a whole. Table 6: Business Base within Perth and Kinross (2023) Indicator Perth and Kinross Scotland No. of businesses per 10,000 working age population (2023) 646 481 Growth in no. of businesses (2018 – 2023) -0.7% -1.9% Business births per 10,000 working age population (2022) 53.9 53 5-year business survival rate (2017 - 2022) 49.5% 40.5% % micro-businesses (0-9 employees) 2023 87.7% 87.4% % SME businesses (10-249 employees) 2023 12.1% 12.2% % large businesses (+249 employees) 2023 0.2% 0.3% 2.4.5 Employment and Growth Sectors – Table 7 to follow shows that the largest share of jobs across the area are in the Tourism, Health and Social Work, Retail, and Food and Drink sectors, which is to an extent similar to the national picture, which sees the majority of jobs located within the Health and Social Work, Financial and Business Services, Education, Retail, and Tourism sectors.
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30 Table 7: Top Employment Sectors and Scottish Government Growth Sectors within Perth and Kinross (2022) Indicator Perth and Kinross Scotland Health and Social Work 8,000 394,000 Retail (excluding Motor Trades) 7,000 227,000 Financial and Business Services 6,000 322,000 Tourism 9,000 216,000 Education 5,000 220,000 Manufacturing 4,500 173,000 Public Admin. and Defence 4,000 163,000 Construction 4,500 148,000 Food and Drink 7,000 125,000 Creative Industries (including Digital) 1,325 88,000 Energy (Including Renewables) 4,000 68,000 Life Sciences 400 23,000 2.4.6 In terms of the Scottish Government’s identified ‘Growth Sectors’ i.e. those sectors where Scotland is considered to have a distinct comparative advantage, Table 8 to follow highlights that the Perth and Kinross Area is performing well above the Scottish average in respect of its percentage share of jobs within the Food and Drink, Energy (including Renewables), and Sustainable Tourism sectors. However, it is below the Scottish average for percentage share of jobs in the Financial and Business Services, Creative Industries, and Life Sciences. It is perhaps worth noting that the Tay Cities Region Economic Strategy identifies the Key Business Sectors for the Region as being - Tourism and Culture; Food and Drink; Engineering and Manufacturing; Energy; Digital and Creative Industries; Biomedical, Life Sciences and MedTech, and Construction. Table 8: Scottish Government Growth Sectors – Percentage Share of All Jobs within Perth and Kinross Indicator Perth and Kinross Scotland Food and Drink 10.1% 4.8% Financial and Business Services 5.8% 9% Life Sciences 0.6% 0.9% Energy (Including Renewables) 5.8% 2.6% Sustainable Tourism 13% 8.7% Creative Industries (including Digital) 1.9% 3.4% 2.4.7 In respect of ‘Inclusive Growth’, the most recent data available (see Table 9) related to employment shows that, whilst the employment statistics across the three occupation levels (higher, mid, and lower) look similar to the national picture for two out of three of the levels, Perth and Kinross was performing at a lower rate in terms of employment in the lower-level occupations during the 12 month period to December 2022. 2.4.8 The relationship between broadband investment and economic growth is widely regarded as a significant one. Digital connectivity policy in Scotland contributes to several key cross-cutting Scottish Government policy statements and ambitions. The most recent data (see Table 9) relating to percentage of premises with access to superfast, ultrafast, and full fibre broadband within Perth and Kinross highlights that the area is lagging the national average.
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31 The percentage area coverage with mobile data service is on a par with the national average. Table 9: Inclusive Growth within Perth and Kinross Indicator Perth and Kinross Scotland Employment in higher level occupations (12 months to Dec 2022) 35,500 (48.4%) 1,299,200 (48.3%) Employment in mid-level occupations (12 months to Dec 2022) 21,200 (28.9%) 700,400 (26%) Employment in lower-level occupations (12 months to Dec 2022) 13,200 (18%) 632,200 (23.5%) % employee jobs paid below Living Wage (2023, provisional data) 10.4% 10.1% Participation rate for 16-19 year olds (2023) 94.7% 94.3% % premises able to access superfast broadband (>=30Mbit/s) (2023) 87% 95% % premises able to access ultrafast broadband (>=100Mbit/s) (2023) 42% 71% % premises able to access full fibre broadband (2023) 14% 52% % area coverage with mobile data service (2023) 90% 94% 2.4.9 Unemployment – The figures in Table 10 show that the unemployment rate for the area is estimated to be below the Scottish average. However, it is important to note that the Office of National Statistics Annual Population Survey data collection process has been severely affected since the Covid-19 pandemic. 5 Estimate unreliable. For this reason, many of the measures have been either unreliable as estimates or unavailable entirely due to sample size and sample availability. This is pronounced at the local authority level. Table 10: Labour Market within Perth and Kinross (12 months to September 2023) Indicator Perth and Kinross Scotland Unemployment rate 16+ (modelled) 2.8% 3.4% Unemployment rate (16 to 64 years) 2.5%5 3.4% Male unemployment N/A 3.9% Female unemployment N/A 2.9% % working age population with no qualifications N/A N/A 2.4.10 Claimant Count – The total number of claimants in Perth and Kinross during March 2024 was a significantly small proportion (1.9%) of the overall number across Scotland at this time. The highest number of claimants was in the 25-49 age group, and the lowest in the age 16-24 group. The national claimant rate for age 16+ was 3.1%, compared to a 2.3% rate for Perth and Kinross. Finally, there was a higher percentage rate of males claiming compared to females in the 16+ age group during the same month.
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32 Table 11: Claimant Count and Rate by Sex and Age Group (March 2024) Indicator Perth and Kinross Scotland Claimant Count, age 16+ 2,140 109,890 Claimant Count, aged 16-24 355 19,910 Claimant Count, aged 25-49 1,320 63,680 Claimant Count, aged 50+ 465 24,300 Claimant Count, age 16+, male 1,290 65,640 Claimant Count, age 16+, female 850 44,250 Claimant Count rate, age 16+ 2.3% 3.1% Claimant Count rate, age 16+, male 2.8% 3.8% Claimant Count rate, age 16+, female 1.8% 2.5% 2.4.11 Housing Market – Table 12 shows that the average house price for all types of property in Perth and Kinross (February 2024) was £57,253 above Scottish average prices for the same period. The average house price across all the individual house types (detached, semi-detached, and terraced), apart from flats or maisonettes, was also higher in Perth and Kinross for the same period. The average house price (all types of property) has steadily increased month on month (apart from during January 2024) during the 12-month period March 2023 to February 2024, which an overall percentage increase of 5% on the March 2023 figure. Table 12: Housing Market (February 2024) Indicator Perth and Kinross Scotland Average house price (all types of property) £245,253 £188,000 Detached house price average £375,855 £338,000 Semi-detached house price average £236,304 £201,000 Terraced house price average £180,246 £157,000 Flats or Maisonettes £126,897 £130,000 2.4.12 Employment Land - Perth and Kinross has above average levels of employment in accommodation and food services, agriculture, forestry and fishing and mining, quarrying and utilities reflecting its attractiveness from a tourism perspective and its traditional employment base. These are not generally sectors which have a large employment land/property requirement (in terms of planning use classes). The Area has below average levels of employment in health, business administration and support services, professional, scientific, and technical and information and communication. As such Perth and Kinross potentially has a lower overall employment land requirement than an ‘average’ Scottish local authority. 2.4.13 The principal employment property locations in the Area are Inveralmond Industrial Estate and North Muirton Industrial Estate, within Perth City itself. There is also notable stock around Crieff, Blairgowrie, Kinross, Errol, and Aberfeldy, with most of the smaller towns throughout the Council Area having some industrial units.
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33 Take-up of employment land within the Perth and Kinross Area over the last 8 years can be averaged at 2.1 ha per annum. Social Characteristics 2.5.1 The social characteristics of the Perth and Kinross Council Area are explored in more detail across several of the issues in this Evidence Report, but particularly those relating to Design, Quality and Place, Flood Risk and Water Management, Homes (including Rural Development), Infrastructure, Local Living and 20 Minute Neighbourhoods, and Tackling the Climate and Nature Crises. However, the following paragraphs provide an overview of those characteristics to help set out the profile of the Council Area across the range of prescribed characteristics in the Planning Act. The 2020 Scottish Index of Multiple Deprivation (SIMD) data tells us that 39 out of 186 (21%) of all data zones in the Perth and Kinross Area are ranked in the 40% most deprived areas in Scotland; 7 out of 136 (4%) are within the 15% most deprived; 3 out of 186 (2%) are within the 10% most deprived areas, and 44 out of 186 (24%) are within the 20% least deprived areas in Scotland. The 10% most deprived areas in Perth and Kinross can be found in Perth (Muirton, and Hillyland, Tulloch and Inveralmond), and Blairgowrie East (Rattray). 2.5.2 The Scottish Household Survey (SHS) is a useful data source which provides us with a picture of how residents of Perth and Kinross feel or perceive different aspects of their neighbourhoods and communities. The 2022 results tell us that typically most residents are happy with their neighbourhoods as a good place to live. However, some perceived there to be, or they have experienced problems within their neighbourhoods, mostly linked to issues that are not within the influence of the land use planning system, e.g., littering and animal related noise, neighbour disputes, rowdy behaviour etc., with the results all being quite like the Scotland average for these answers. 2.5.3 Overall, a large percentage of participants indicated that they felt like they belong to a community, which is a good representation of the feeling of community experienced across the area. Most of both males and females, disabled and non-disabled persons, met socially with others at least once per week or more, with the figures mirroring the Scotland averages also. The reported feeling of loneliness across the participants group was quite low, which is very positive considering the rural nature of large parts of the Council Area. 2.5.4 In terms of perception of safety when walking alone after dark, a higher percentage of males over females felt very or fairly safe, and a higher percentage of females than males felt very or a bit unsafe. Overall, most participants felt reasonably safe. 2.5.5 The Office of National Statistics personal wellbeing indicators relate to overall estimates of life satisfaction; the feeling that the things done in life are worthwhile; happiness, and anxiety. Please note for the figures in Table 13, for the Anxiety indicator, a lower
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34 score is better, and for the Happiness, Life Satisfaction, and Worthwhile indicators, a higher score is better. 2.5.6 Encouragingly, in 2022/23, the Perth and Kinross Area scored lower than the Scottish average for the Anxiety wellbeing estimate, and higher for the Life Satisfaction and Worthwhile scores. However, in terms of the Area’s Happiness score, it was estimated to be slightly lower than the national average. Table 13: Wellbeing Measures 2022/23) Indicator Perth and Kinross Scotland Anxiety score 3.02 3.21 Happiness score 7.33 7.39 Life satisfaction score 7.56 7.49 Worthwhile score 7.91 7.74 Built Heritage Characteristics 2.6.1 The Perth and Kinross Area has a rich, strong, and varied human past which is demonstrated through the number and quality of sites of historic, architectural, archaeological, and cultural importance. These sites include a diverse range of archaeological sites, conservation areas, designed landscapes, historic battlefields, listed buildings, palaces, and stately homes. 2.6.2 Table 14 outlines some of the key information for the Perth and Kinross Area’s built heritage assets. Further details about these assets and maps showing their spatial distribution are provided under the Historic Assets and Places issue of this Evidence Report. Table 14: Built Heritage within the Perth and Kinross Area Built Heritage Asset Type Total Number Designated Conservation Areas: Aberfeldy, Abernethy, Baledgarno, Birnam, Blair Atholl, Blairgowrie, Cleish, Comrie, Coupar Angus, Crieff, Dunkeld, Dunning, Errol, Forgandenny, Fortingall, Fowlis Wester, Grandtully & Strathtay, Inchture, Kenmore, Kinnesswood, Kinross, Kinrossie, Knapp, Longforgan, Meikleour, Muthill, Moulin, Perth Central, Perth Kinnoull, Pitcairngreen, Pitlochry, Rait, Scotlandwell, Spittalfield, St. Fillan’s, Wester Balgedie 36 Listed Buildings: Category A: 160; Category B: 1402; Category C: 1492 3054 Listed Buildings on the Buildings at Risk Register 115 Designated Scheduled Monuments 683 Gardens and Designed Landscapes: Abercairny, Aberuchill Castle, Balmanno, Battleby, Blair Adam, Blair Castle, Bolfracks, Braco, Branklyn, Castle Menzies, Cleish Castle, Cluny House, Craighall Rattray, Drumkilbo, Drummond Castle, Dunira, Dunkeld House, Dupplin Castle, Errol Park, Falls of Bruar, Fingask Castle, Glendoick, Gleneagles Hotel and Golf Courses, Grantully Castle, Inchyra, Invermay, Keillour Castle, Kinfauns Castle, Kinross House, Meggernie Castle, Megginch Castle, Meikleour, Methven Castle, Monzie Castle, Murthly Castle, Ochtertyre, Rossie Priory, 41
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35 Built Heritage Asset Type Total Number Scone Palace, Stobhall, Taymouth Castle, The Hermitage Inventory of Historic Battlefields Sites: Battle of Dunkeld, Battle of Dupplin Moor, Battle of Killiecrankie, Battle of Tippermuir 4 Undesignated Archaeological Sites/Remains on Council’s Historic Environment Record 15,472 Environmental Characteristics 2.7.1 The environment of Perth and Kinross is rich and varied, which is evidenced through its many designated sites. Approximately 36% of the area is designated under national or international legislation to protect landscape, habitats, and species, and around 27% is designated under a local designation for landscape alone. 2.7.2 Tables 15 and 16 outline the range of designations and key environmental assets covering the area. These are considered in more detail in the Biodiversity and Natural Places issue of this Evidence Report and the SEA Scoping Report. Table 15: Designations within the Perth and Kinross Relevant Designation Total Number and/or Area National Scenic Areas (NSA): Loch Rannoch and Glen Lyon, Loch Tummel, River Tay, and River Earn 4 Relevant Designation Total Number and/or Area The Ben Nevis and Glen Coe NSA is also partially within the Perth and Kinross Council Area. Wildland Areas Breadalbane/Schiehallion, Lyon/Lochtay, Ben Lawers, Rannoch/ Nevis/ Mamores/ Alder, and Cairngorms 5 Local Landscape Areas (LLAs): Rannoch Forest, Loch Lyon and Loch an Daimh, Loch Tay, Strath Tay, Ben Vrackie, Glen Quaich, Sma’Glen and Glen Almond, Upper Strathearn, Sidlaw Hills, Ochil Hills, and Loch Leven and Lomond Hills 11 sites covering 1,444 Km2 National Nature Reserve Areas: Ben Lawers, Loch Leven, and Mar Lodge Sites are wholly or partially within PKC Area. 3 Ramsar Sites: Firth of Tay and Eden Estuary, Loch Leven, Rannoch Moor, and South Tayside Goose Roosts 4 Special Areas of Conservation (SACs): Beinn a’ Ghlo, Ben Heasgarnich, Ben Lawers, Black Wood of Rannoch, Craighall Gorge, Drumochter Hills, Dun Moss and Forest of Alyth Mires, Dunkeld-Blairgowrie Lochs, Firth of Tay and Eden Estuary, Glenartney Juniper Wood, Keltneyburn, Methven Moss, Pitkeathly Mires, Rannoch Moor, River Tay, Shelforkie Moss, Shingle Islands, Tulach Hill and Glen Fender Meadows, Turflundie Wood, and Upper Strathearn Oakwoods 22 sites covering 756.91 Km2
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36 Relevant Designation Total Number and/or Area Sites are wholly or partially within PKC Area. Special Protection Areas (SPAs): Caenlochan, Cairngorms Massif, Drumochter Hills, Firth of Tay and Eden Estuary, Forest of Clunie, Loch Leven, Rannoch Lochs, and South Tayside Goose Roosts 8 sites covering 2323.18 Km2 Special Sites of Scientific Interest (SSSIs) 92 out of the 112 sites are designated for biological reasons, 13 for geological reasons, and 7 are mixed. 112 sites covering 710.08 Km2 RSPB Important Bird Areas 7 sites covering approx. 440 Km2 Ancient Woodland Inventory (AWI) Sites (Ancient and Semi-Natural Woodland) 570 Km2 Table 16: Key Facts – Other Important Environmental Assets Other Environmental Assets Key Facts Existing Woodland Cover 18% of total land area of Perth and Kinross (968.8 Km2) is covered by woodland. Of that, approximately: • 48.1% is Conifers • 18.1% is Broadleaved • 51.6% is Native Woodland • 1.2% is Nearly Native Woodland Other Environmental Assets Key Facts Nationally Important Soils • 589.9 Km2 of Scotland’s Class 1 Nationally Important Soils are within Perth and Kinross. • 294.4 Km2 of Class 2 • 226.9 Km2 of Class 5 Wetlands • Approximately 293.1 Km2 of wetlands within Perth and Kinross. Protected Sites and Species • 75.3% of protected biological and mixed SSSI features within Perth and Kinross are in favourable condition (June 2022). • 75.5% of protected nature sites within the area are in favourable condition (June 2022). • 51.4% of all 1 Km grid squares covering the area had recordings for protected species (protected by European and UK Legislation). Surface Water Quality Status In 2023, approximately: • 9% (20 waterbodies) of surface waters in Perth and Kinross were classified as having overall high-quality water status • 46% (97 waterbodies) were classified as having overall good status • 28% (60 waterbodies) as having overall moderate status. • 13% (27 waterbodies) as having overall poor status, and • 4% (8 waterbodies) as having an overall bad water quality status.
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37 Other Environmental Assets Key Facts Areas in the North, Northwest and West contained areas of bad surface water quality status, and areas primarily to the North, East and South contained areas of poor surface water quality status. PRINCIPAL PURPOSES FOR WHICH THE LAND IS USED 2.8.1 There are 112 defined settlement boundaries identified in the Adopted Perth and Kinross Local Development Plan 2. These range in scale from the largest, Perth City, through to the smallest settlement, Cosieville in Highland Perthshire. They cover a total land area of 8,266 Hectares. It is important to note that a range of land uses exist within a settlement, and not all land within a defined boundary has been developed. 2.8.2 Nature Scot’s Habitat Map of Scotland (HabMoS) is the publication of all available habitat data and uses The European Nature Information System, or EUNIS to standardise that data in order to map habitats and land use across Scotland. The most recently updated version of this map was in March 2022. 2.8.3 Whilst HabMoS is a key dataset in providing us with information regarding the breakdown and distribution of habitat types across Perth and Kinross from an ecological perspective, it is also helpful in setting out the percentage coverage of the Council Area, which is used for agricultural and horticultural purposes, and those areas which are developed. Table 17 and Figure 9 identify the main land cover categories covering Perth and Kinross. Table 17: HabMoS Key Land Cover Types within the PKC Area Land Cover Type and EUNIS Codes Area (Ha) % of Perth and Kinross A - Marine Habitats 384 0.07% B – Coastal Habitats 0 0 C – Inland Surface Waters 11,384 2.15% D – Mires, Bogs, and Fens 37,155 7.03% E – Grasslands and Lands Dominated by Forbs, Mosses, or Lichens 48,131 9.11% F - Heathland, Scrub and Tundra 44,357 8.39% G - Woodland, Forest, and Other Woodland Land 119,0596 22.52% H – Inland Unvegetated, or Sparsely Vegetated Habitats 3,062 0.58% I – Regularly, or Recently Cultivated Agricultural, Horticultural, and Domestic Habitats 116,233 21.99% J – Constructed, Industrial, and Other Artificial Habitats 267 0.05% X – HES: Historic Land Use Assessment 1614 0.31%
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38 Figure 9: Habitat Map of Scotland (HabMoS) – The Perth and Kinross Council Area
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39 SIZE, COMPOSITION, HEALTH AND DISTRIBUTION OF POPULATION OF THE AREA Population – Estimates, Projections and Profile 2.9.1 In the most recently published National Records of Scotland 2021 mid-year population estimates, the population of Perth and Kinross was calculated as being 153,810 residents, which is an increase of 1.3% from 151,910 in 2020. Over the same period, the population of Scotland increased by 0.3%. Perth and Kinross had the 12th highest population in 2021, out of all 32 council areas in Scotland. 2.9.2 Between the period 2018 to 2028, the population of Perth and Kinross has been projected to increase by 1.0% from 151,290 to 152,779 (which is less that the most recent mid-year population estimate figure for the area), which compares to a projected increase of 1.8% for Scotland as a whole. 2.9.3 Some of the key figures from the mid-year estimates for Perth and Kinross tell us that in 2021: • There were more females (50.8%) than males (49.2%) living in the area. • The largest age group was the 45 to 64 group, with a population of 43,806. • The smallest age group was the 16 to 24 group, with a population of 13,838. 7 Note: totals have been rounded to the nearest 10 at council level. • In 3 out of the 6 age group ranges i.e. 0 to 15, 16 to 24, 25 to 44, 45 to 64, and 75 and over, more females lived in Perth and Kinross than males. • Between 2001 and 2021 the 0 to 15 age group saw the largest percentage decrease (-5.2%), and the 75 and over group saw the largest percentage increase (+48.9%). • Between 2018 and 2028 the average age of the population of the area is projected to increase as the ‘baby boomer’ generation ages and more people are expected to live longer. • Between 2018 and 2028 the 0 to 15 age group is projected to see the largest percentage decrease (-8.1%), and the 75 and over age group is projected to see the largest percentage increase (+30.8%). The 45 to 64 age group is expected to remain the largest group. Population – Migration 2.9.4 During the period 2020-21, the level of in-migration i.e. people moving into the Perth and Kinross area, was 79303F 7, which was a 49.9% increase from the period 2019-20 (5290). The level of out- migration, which is people moving away from the area, was 5400 – an increase of 18.2% from 4570 in 2019-20. In 2020-21, Perth and Kinross had the 3rd highest level of net migration out of the 32 council areas, with a total net migration of 2530 people. During this period, the net migration in the area was higher for females (1307) than for males (1223), and the age group with the highest level of total net migration was the 30 to 34 group (296). Notably,
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40 the age group with the lowest level of net migration was 15 to 19 (-151). Population – Births, Deaths, and Life Expectancy 2.9.5 In 2022, there were 1153 births in Perth and Kinross - 49.1% of which were female, and 50.9% were male. This is a decrease of 3.4% on the 1194 births in 2021. The standardised birth rate for the Council Area decreased from 9.7 per 1000 population in 2021, to 9.2 in 2022. As a comparison, the rate in Scotland overall decreased from 8.7 to 8.6 during that same period. 2.9.6 The most common age group of mothers in 2022 was the 30 to 40 group (400 births), which was the same as in 2002. The least common age group was the 0 to 19 group (24 births) – a change from the 40 and over group which was the least common age group in 2002. Between 2002 and 2022, the 0 to 19 age group has seen the greatest percentage decrease in births (-68.8%), and the 40 and over group the greatest percentage increase (+16.2%). 2.9.7 The total fertility rate of the area has decreased from 1.44 in 2021 to 1.4 in 2022. Perth and Kinross had the 22nd highest rate in 2022 out of the 32 council areas, and it was higher than the rate for Scotland as a whole (1.28). 2.9.8 In 2022, there were 1922 deaths in Perth and Kinross. This represented a 5.5% increase from the 1821 deaths recorded for 2021. Of these 1922 deaths, 945 (49.2%) were female, and 977 (50.8%) were male. The standardised death rate for the area decreased from 12.0 per 1000 of the population in 2021, to 10.0 in 2022. During the same period, the rate in Scotland overall decreased from 11.6 to 11.5. 2.9.9 In 2022, the 90 and over age group saw the highest number of total deaths (427), and the 5 to 9 ages group saw the fewest (0). The most common age group for females was the 90 and over (259), and the 80 to 84 group (170) for males. 2.9.10 An analysis by the National Records of Scotland of the leading cause of death in Perth and Kinross, found that for males in 2022, Ischaemic heart diseases was responsible for 11.1% of all deaths, followed by Dementia and Alzheimer’s Disease (7.8%). This mirrors the leading cause of death for males in Scotland overall, with 14.0% being attributed to Ischaemic heart diseases, followed by Dementia and Alzheimer’s Disease at 6.8%. 2.9.11 In terms of females in the area, the same analysis identified the leading cause of death in 2022 was Dementia and Alzheimer’s Disease (12.7% of all female deaths), followed by Cerebrovascular disease (7.9%). For comparison, in Scotland overall for the same period, Dementia and Alzheimer’s Disease was the leading cause of death for females (13.1%), followed by Ischaemic heart diseases (8.7%). 2.9.12 In terms of life expectancy in Perth and Kinross, at birth, the life expectancy for females is higher than for males, at 82.7 years and 78.9 years respectively (2019-2021). However, male life expectancy at birth has increased at a faster rate than that for females between 2001-03 and 2019-21. The life expectancy at
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41 birth in Perth and Kinross is higher than at a Scotland level for both females and males. Population – Health and Wellbeing 2.9.13 Public Health Scotland’s online ScotPHO tool provides a health and wellbeing profile for Perth and Kinross across a number of indicators. Some of those headline indicators and their results are reported in the paragraphs to follow under their relevant categories, as defined on ScotPHO. An extract has also been included for each of the indicator categories to visually show how Perth and Kinross compares relative to the Scotland average. Figure 10 provides a key for interpreting the results charts in Figures 11 to 21. Figure 10: ScotPHO Key for Indicators Results Tables 2.9.14 Health and Wellbeing: Behaviours - Across the ‘Behaviours’ category, Perth and Kinross was statistically like the rest of Scotland as a whole for most indicators and was also statistically significantly better in terms of indicators for ‘Alcohol-related hospital admissions’ and ‘Smoking attributable deaths.’ The only indicator for which the area came out as worse than the Scottish average, was for the percentage of people smoking during pregnancy, which was 14.1% compared to the national figure of 12.92% during the 3 financial year period 2019/20 to 2021/22. Figure 11: ScotPHO Perth and Kinross Profile – Behaviours 2.9.15 Health and Wellbeing: Crime - For all indicators reported under Crime, apart from ‘Prisoner population’, Perth and Kinross came out statistically significantly better than the Scottish figure, and even then, it was slightly higher than the national value.
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42 Figure 12: ScotPHO Perth and Kinross Profile – Crime 2.9.16 Health and Wellbeing: Economy – For all indicators under the ‘Economy’ category, the Perth and Kinross Council Area performed statistically significantly better than the Scottish average. The indicators reported under this category include – Children in low-income families; Working age population employment deprived; Population income deprived; People claiming pension credits, aged 65 + years, and Working age population claiming out-of-work benefits. 8 Scottish Credit and Qualifications Framework Figure 13: ScotPHO Perth and Kinross Profile – Economy 2.9.17 Health and Wellbeing: Education - The data under the ‘Education’ category presents a slightly mixed picture for the Council Area. In terms of the indicators for: Secondary school attendance by looked after children; Working age adults with low or no educational qualifications, and Secondary school attendance in general, the area performs statistically significantly better than the Scottish average values. However, for the indicators relating to School leavers in positive destinations, and School leavers with 1 or more qualifications at SCQF4F8 Level 6, Perth and Kinross comes out statistically lower than the Scottish average. Finally, in respect of the Annual participation (in education, training, or employment) measure for 16–19-year-olds, and School leavers with 1 or more qualifications at SCQF Level 4, Perth and Kinross
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43 performs slightly better and about the same, respectively, than the Scottish average figures. Figure 14: ScotPHO Perth and Kinross Profile – Education 2.9.18 Health and Wellbeing: Environment – Under the Environment category, the Perth and Kinross Area is performing statistically significantly worse compared to the Scotland average in terms of the percentage of the area’s population who are living in the 15% most ‘access deprived’ areas. In relation to the indicators on neighbourhood rating and proximity to a derelict site, the Perth and Kinross Area is performing statistically significantly better than the Scotland average figures for the same indicators. Figure 15: ScotPHO Perth and Kinross Profile – Environment 2.9.19 Health and Wellbeing: Ill Health and Injury - For all indicators under the Ill Health and Injury category, the Perth and Kinross Council Area is performing statistically significantly better than the Scotland average. Figure 16: ScotPHO Perth and Kinross Profile – Ill Health and Injury 2.9.20 Health and Wellbeing: Mental Health - When considering the results of the Mental Health category indicators, we can see that the Council Area is performing statistically significantly better than the Scotland average in terms of the percentage of the population who have been prescribed medication for anxiety, depression, or
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44 psychosis. However, the recorded number of deaths from suicide across the area from 2017 to 2021 per 100,000 of the population is just slightly higher than the Scotland average figure, and the level of psychiatric patient hospitalisations between 2019/20 to 2021/22, per 100,000 of the population is significantly worse than that of the Scotland average for the same period. Figure 17: ScotPHO Perth and Kinross Profile – Mental Health 2.9.21 Health and Wellbeing: Immunisation and Screening - In relation to the indicators relating to uptake of immunisations and screening programmes, the Council Area is performing statistically significantly better that the Scotland average on bowel and breast screening uptake; almost the same in terms of immunisations 6 in 1 uptake at 24 months, and statistically significantly worse for uptake of MMR immunisations at 24 months. Figure 18: ScotPHO Perth and Kinross Profile – Immunisation and Screening 2.9.22 Health and Wellbeing: Women and Children’s Health - For most indicators in this category, the Council Area is performing statistically significantly better than the Scotland average, and for the remaining 2 indicators for ‘Healthy birth weight’ and ‘Teenage pregnancies’ it is not statistically significantly different to the Scotland average figures.
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45 Figure 19: ScotPHO Perth and Kinross Profile – Women and Children’s Health 2.9.23 Health and Wellbeing: Life Expectancy and Mortality – Looking at the results under this category, the Perth and Kinross Council Area is performing, for most indicators, statistically significantly better than the Scotland average, or about the same for a few of the indicators. Figure 20: ScotPHO Perth and Kinross Profile – Life Expectancy and Mortality 2.9.24 Health and Wellbeing: Social Care and Housing - For 2 out of the 4 indicators for the Social Care and Housing category (‘Children looked after by the local authority’, and ‘single adult dwellings’), the Council Area is performing about the same as the national average. In relation to the percentage of adults who are claiming incapacity benefit or severe disability allowance, the Area is performing statistically significantly better. However, the percentage of people aged 65+ in Perth and Kinross with high levels of care needs who are cared for at home is much lower than
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46 the Scotland average, and as such the Area is performing statistically significantly worse. Figure 21: ScotPHO Perth and Kinross Profile – Social Care and Housing 2.9.25 The ScotPHO data provides us with a very useful profile of how the health and wellbeing of the population of Perth and Kinross compares overall to that of the Scotland average. For most of the indicators under the Health and Wellbeing category, the Council Area is performing either statistically significantly better, or similar to that of the national average. However, for some, namely those indicators in relation to – older members of the Area’s population with high levels of care who are being cared for at home, rather than in a health or social care facility; MMR immunisations uptake; psychiatric patients hospitalisation rates; and the percentage of people living in the 15% most access deprived areas, the Perth and Kinross Area is performing statistically significantly worse than the national average figures for the same indicators. RURAL AREAS AND POPULATION DECLINE 2.10.1 Part 2, Section 16B(3) and Section 15(5)(cf) of the Planning Act 2019, in the preparation of their Evidence Report, requires planning authorities to provide their views on the extent to which there are rural areas within the plan area which have experienced a substantial decline in population. 2.10.2 The Scottish Government’s Urban Rural Classification establishes a consistent means of defining urban and rural areas across Scotland. The classification is based on the two main criteria of population and accessibility. The most recent publication is the Scottish Government Urban Rural Classification 2020, which was released in May 2022. It groups settlements into 4 categories and classifies accessibility using 3 categories, and reports it for a 6- fold category and 8-fold category: 1. Large Urban Areas – populations of 125,000 or more 2. Other Urban Areas – populations of 10,000 to 124,999 3. Small Towns – populations of 3000 to 9999 4. Rural Areas – populations of less than 3000 1. Accessible – areas within 30-minute drive of a settlement with a population of 10,00 or more. 2. Remote - areas that are more than a 30-minute drive (6-fold classification) or areas that have a drive time of between 30 and 60 minutes (8-fold classification) from a settlement with a population of 10,000 or more. 3. Very Remote - areas that are more than a 60-minute drive time from a settlement with a population of 10,000 or more (using the 8-fold classification only).
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47 2.10.3 Table 18 and Figure 22 to follow set out the 6-fold Urban Rural categories for the Perth and Kinross Area and tells us that slightly more people in Perth and Kinross live in rural and remote areas compared to those which live in urban and accessible small towns (56.8% of the population versus 43.4%), highlighting the strong rural nature of the area. Table 18: Percentage of PKC Population in 6-Fold Categories Large Urban Other Urban Accessible Small Towns Remote Small Towns Accessible Rural Remote Rural 1.2% 31.2% 11% 10.9% 35% 10.9%
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48 Figure 22: Perth and Kinross 6-Fold Urban Rural Classification
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49 2.10.4 As reported above, the National Record of Scotland mid-year estimates 2021 showed a 1.3% increase in population from 2020, and the population of Perth and Kinross is projected to continue to increase in the period to 2028. Although the overall picture in Perth and Kinross is one of population growth, that growth has not been evenly distributed across the Plan Area. 2.10.5 As explored in more detail under the Rural Development issue of this Evidence Report, there are several areas within Perth and Kinross which have seen a decline in population of more than 6%. This ranges from a 6% fall in the Comrie, Gilmerton and St Fillan’s datazone, to an 11.5% decline in the Rannoch and Aberfeldy datazone. Of the 8 datazones with a population decline of 6% or more, 3 are Remote Rural Areas. The other 5 datazones are Accessible Rural Areas showing that even in the more accessible parts of Perth and Kinross there are still pockets where the population has been in decline. 2.10.6 Scottish Government-funded research identifies those parts of Scotland where less than 10,000 people can be reached within 30 minutes travel using roads and ferries. One of these Sparsely Populated Areas incorporates part of the Perth and Kinross area. Overall parts of the Highlands and northern Scotland (including Perth and Kinross and Stirling Sparsely Populated Area) are 9 (Scottish Government Advisory Group: Place-based policy approaches to population challenges – Lessons for Scotland, P4) projected to lose between 13% and 17% of their overall populations, and more than 20% of their working age populations from 2018 to 2043 if current trends continue. 2.10.7 Further Scottish Government research9 considers how population within individual datazones has been changing with a view to identifying those areas with high numbers of ‘shrinking’ datazones. In general, the sparsely populated areas, very remote rural areas, and very remote small towns are the most affected. The least affected are generally accessible rural areas. 2.10.8 In Perth and Kinross 12 datazones are identified as shrinking. However, this only accounts for 6.5% of all datazones in the area and 5.5% of the overall population, meaning that across Scotland Perth and Kinross ranks 29th both in terms of percentage of the number and population living within shrinking datazones. 2.10.9 Please refer to the Rural Development issue of this report for further information regarding Scottish Government identified population challenges, and the issues relating to these, and what they mean for rural areas of Perth and Kinross and meeting the housing needs of the population.
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50 HEALTH NEEDS OF THE POPULATION OF THE AREA 2.11.1 Part 2, Section 16B(3) and Section 15(5)(cd) of the Planning Act 2019, in the preparation of their Evidence Report, require planning authorities to set out their views on the health needs of the population of the plan area, and the likely effects of development and use of land on those health needs. As this matter has been explored in more detail under the Infrastructure – Health Care Facilities issue of this Evidence Report, a brief overview of the key challenges in terms of the health needs of the population of Perth and Kinross is presented here. 2.11.2 The Perth and Kinross Integration Joint Board Strategic Commissioning Plan 2020-2025 Strategic Needs Assessment has enabled local population profiles to be developed, and these highlight the following key messages and challenges with respect to the health needs of the population of Perth and Kinross: • Life expectancy is lower in the most deprived areas, primarily Perth City. • An increase in the over 85-year-old age group and with increasingly complex needs is expected. • There is a growing population of older people in North Perthshire. • 31.5% population are access deprived due to the rural nature of Perth and Kinross. • Approximately 30% of people are living with long-term conditions and this is associated with age and income deprivation. • Poor mental health affects more people in deprived areas. • Uptake of support from the Drugs and Alcohol Team is greater in Perth City than in either the North or South Perthshire Localities. • There is a growing ageing population of people with learning disabilities. • Several specific long-term conditions are more prevalent in Perth and Kinross than in Scotland as a whole. These are: Hypertension, Hypothyroidism, Coronary Heart Disease, Cancer, and Dementia. 2.11.3 In considering the ScotPHO indicator profiles for the area, as previously highlighted under the Population section of this report, for most of the indicators under the Health and Wellbeing category, the Council Area is performing either statistically significantly better, or like that of the national average. However, for some, namely those indicators in relation to – older members of the Area’s population with high levels of care who are being cared for at home, rather than in a health or social care facility; MMR immunisations uptake; psychiatric patients hospitalisation rates; and the percentage of people living in the 15% most access deprived areas, the Perth and Kinross Area is performing statistically significantly worse than the national average figures for the same indicators. EDUCATION NEEDS OF THE POPULATION OF THE AREA AND SERVICE CAPACITY 2.12.1 Part 2, Section 16B(3) and Section 15(5)(ce) of the Planning Act 2019, in the preparation of their Evidence Report, require
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51 planning authorities to set out their views on the education needs of the population of the plan area, and the likely effects of development and use of land on those needs. Part 2, Section 16B(3) and Section 15(5) (ce)(cg)(d) and (e) of the Act also require planning authorities to set out their views on the capacity of education services in the plan area, and how that infrastructure is used. A more in-depth analysis of the education needs of the people of Perth and Kinross and the existing service provision and its capacity, is provided under the Infrastructure – Education Facilities issue of this Evidence Report, but an overview of that work is provided in the paragraphs to follow. 2.12.2 In summary, the Council’s Education and Children’s Services Learning Estate Strategy informs us that education infrastructure in the Perth and Kinross Area continues to serve the local population adequately. 2.12.3 Some of the key considerations which the Council considers when determining the capacity of its education services are - demographics; the condition, suitability, distribution, capacity and suitability of the learning estate; additional support needs across the area, and any planned development (LDP site allocations and proposals via planning application process). A summary for each of these elements is set out below. 2.12.4 Demography - In terms of the demographic profile of the area, population projections indicate the population of Perth and Kinross is expected to increase by 1% between 2018 and 2028. However, it is worth noting that between 2001 and 2021 the 0 to 15 age group saw the largest percentage decrease (-5.2%), and the 75 and over group saw the largest percentage increase (+48.9%), pointing to an ageing population for the Perth and Kinross Area. 2.12.5 The Learning Estate – The Council’s school estate is made up of 70 primary schools, 11 secondary schools, 1 stand-alone nursery, and 1 Additional Support Needs (ASN) school. Perth and Kinross Council currently has 6 community campuses. 2.12.6 Investment in the Council’s school estate is set out through the School Estate Transformation Programme. In taking forward the School Estate Transformation Programme, the School Estate Management Plan (SEMP) highlighted the challenges for managing the school estate in future years, including - a changing population, house building in certain locations, ongoing deterioration in building infrastructure, pressure on planned maintenance budgets, and the extension to Early Years provision and Free School Meals. A total of £81m has been invested in the school estate since 2015/2016 and the programme will deliver £160m of further improvements to the Learning Estate between 2021 and 2029. The Council approved its updated 8-year capital programme in October 2021. 2.12.7 Condition of Primary and Secondary School Estates – The majority of schools published as part of the Scottish Government School Estate Statistics 2024 were rated ‘Good’ and ‘Satisfactory’.
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52 However, one primary and one secondary school were rated ‘Poor’. This classification is defined as “showing major defects and/or not operating adequately…”. No schools were rated ‘Bad’, and the Additional Support Needs school was rated ‘Satisfactory’. 2.12.8 Suitability – The majority of schools published as part of the Scottish Government School Estate Statistics 2024 were rated ‘Good’ and ‘Satisfactory’. However, one primary and two secondary schools were rated ‘Poor’ i.e., “showing major problems and/or not operating optimally (the school buildings and grounds impede the delivery of activities that are needed for children and communities in the school)”. No schools were rated ‘Bad’. The Additional Support Needs school was rated ‘Satisfactory’. 2.12.9 Early Years Capacity – The Council’s Education and Children’s Services anticipate that Early Years infrastructure can accommodate pupils, based on population changes and housebuilding activity. It is not envisaged that the Council’s policy on developer contributions will be expanded to include Early Years provision. 2.12.10 Primary Schools Capacity - According to the Scottish Government School Estate Statistics 2024, primary school pupil rolls in Perth and Kinross have decreased in number since 2018, which is broadly consistent with patterns across Scotland. 69 primary schools in Perth and Kinross were surveyed as part of the School Estate Statistics and found that some primary schools in the area have particularly low pupil numbers (11 at less than 50% of capacity) and some have high capacity (5 at 90-100% of capacity). Currently no schools are over-subscribed i.e., roll greater than capacity. The Scottish Government’s pupil projections for Perth and Kinross (2022-2027) show a decline in Primary School pupil numbers during this period, which mirrors the national trend. 2.12.11 The Council monitors pupil rolls in connection with housing development projections published in the annual Housing Land Audit, as well as planning applications for windfall developments. 2.12.12 In May 2018, Perth and Kinross Council’s Education and Children’s Services sought approval to use the Scottish Government’s space capacity metric measurement to manage the accommodation available in primary schools where there are challenges in accommodating catchment children. This helps to ensure that teaching staffing budgets are not exceeded whilst ensuring catchment children have the best opportunity to attend their catchment school. 2.12.13 Other interventions by the Council may however be required to accommodate development growth in certain primary school catchments and support LDP3’s spatial strategy, including extensions and replacement schools to provide further capacity. The developer contributions policy and guidance is applied to eligible developments to “claw back” a proportion of this investment for school projects, where additional capacity is created.
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53 2.12.14 Secondary Schools - According to the Scottish Government School Estate Statistics 2024, secondary school pupil rolls in Perth and Kinross have increased in number since 2017, this is also consistent with patterns across Scotland. There are 11 secondary schools in Perth and Kinross, and the School Estates Statistics found that one school is in the lower capacity quartile and one school is in the higher capacity quartile, again with no schools currently over-subscribed. The Scottish Government’s pupil projections for Perth and Kinross (2022-2027) indicate an increase, then a decline in secondary pupil numbers during this period, which mirrors the national trend. 2.12.15 As is the case with primary schools, the Council’s Education and Children’s Services monitor pupil rolls in relation to housing development projections, and it is anticipated that existing secondary school infrastructure can accommodate pupil projections, calculated based on population changes and housebuilding activity. As such, the Council’s developer contributions policy approach remains relevant to primary education capacity requirements and is not envisaged that these contributions will be required for capacity provision in secondary schools. 2.12.16 Additional Support Needs – As previously highlighted the Council has 1 specialist ASN school, and of the 70 primary schools and 11 secondary schools across our School Estate, 10 have specialist ASN provision. 2.12.17 Development – In September 2008 the Council produced a background paper ‘A methodology for calculating the pupil per household ratio for areas of new housing developments’, as part of which was established a pupil product ratio, which is used to inform the management of our school estate, pupil forecasting, and development contributions. 2.12.18 Education infrastructure is an essential component in creating and supporting our local communities. It is directly impacted by new housing development, and as such is a key consideration in the development of our LDP3 spatial strategy through the site assessment process. The principles contained within the Council’s Learning Estate Strategy are in alignment with NPF4, the National Investment Hierarchy, and education-specific priorities (the National Improvement Framework, and Scotland’s Learning Estate Strategy: Connecting People, Places and Learning)
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54 3 Participation and Engagement PARTICIPATION AND ENGAGEMENT STATEMENT 3.1.1 The paragraphs to follow provide details of how, in preparing our Proposed Evidence Report, Perth and Kinross Council has sought the views of those key stakeholders as set out in Part 2 of the 2019 Planning Act, and the extent to which the views expressed have been considered. 3.1.2 In some instances, it may be more relevant to provide details of how those views expressed have been considered under specific policy topics. Please refer to ‘Statements of Agreement and/or Dispute’ for each topic considered under Section 5 ‘Evidence Gathering - Information on Issues’ of this report and the ‘Summary of Stakeholder Engagement’ relevant appendices to view that detail. The Public at Large 3.2.1 Engagement with the public forms an essential part of the process of preparing an Evidence Report. Section 16B of the Act prescribes several requirements, including - that the views of the public are sought, and that the Evidence Report includes a statement on how the views of the public have been taken into account. 3.2.2 In meeting these requirements under Section 16B, the Council has firstly sought the views of the public through our Big Place Conversation process, using the Place Standard Tool, to find out what community’s feel is good within their areas, and what could be improved. Secondly, our suite of Evidence Report Topic Papers were publicly consulted upon through the Council’s Consultation Hub, and amendments were then made to the relevant chapters and issues of this Evidence Report taking account of the feedback received. Where it has been considered more appropriate to action some suggestions raised within that feedback at another stage in the plan preparation process this has been highlighted in response to individual’s comments under each of the policy issues. 3.2.3 Development Plan Scheme (DPS) – The DPS is prepared to ensure everyone has a clear understanding about their role and the timeline for engagement from the outset, to aid the delivery of an effective process. The Development Plan scheme is updated annually and approved by Committee. It sets out the timetable for the preparation of the Local Development Plan and contains information on opportunities for community engagement in the planning process, and how and when stakeholders can get involved. 3.2.4 The Big Place Conversation (2023): Place Standard Engagement – The most important part of our engagement with the public at large has been through the Big Place Conversation (BPC) exercise.
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55 3.2.5 This extensive engagement process took place from January to September 2023. We had an online survey open during this time on our 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 facilitated Place Standard discussions, which were both in person and online. The drop-in sessions were more informal events to allow for quicker feedback on the Place Standard topics to complement the roundtable discussions. Our engagement gathered feedback from communities on how they viewed different elements of their place and where they felt improvements could be made. 3.2.6 Through our Big Place Conversation engagement, we received 272 survey responses, and nearly 1300 people attended the 114 events which were held during our engagement programme. More information about the Big Place Conversation engagement can be found in our overall Summary Report. The results have also been broken down into summary reports for Perth and Kinross Council Ward areas, and Community Council areas, and they have been published on Big Place Conversation results webpage. 3.2.7 The main purpose of these conversations with our communities was to help shape the next Plan as well as provide an evidence base for community-based plans and the Councils Mobility Strategy. The evidence has also been shared widely within the Council and with communities to inform the development of other strategies and local plans. 3.2.8 Evidence Report Topic Papers (2024) – As previously mentioned, the Council produced a series of LDP3 Evidence Report Topic Papers, covering the individual subject matters of NPF4’s suite of National Planning Policies. These papers, which set out the detailed evidence the Council has gathered to help produce our Evidence Report, and which we hope to use to help prepare our Proposed Plan, were published on the Council’s Consultation Hub and open for comments for a period of 6 weeks during July and August 2024. 3.2.9 As part of our consultation process for LDP3 Topic Papers we welcomed the views of the public at large, on the sufficiency of the evidence gathered, our interpretation of the implications of that evidence to the Proposed Plan, and on how we intend to use that evidence to develop our LDP3. We also asked respondents to provide links to other sources of available information or data which they felt we had not included, alongside an explanation of why they considered any additional sources of information to be relevant to the preparation of the Local Development Plan. 3.2.10 Under each of the individual issues for this Evidence Report in Sections 5 and 6, and Appendices A-E, a summary of the comments made during the topic paper consultation, whether they were in dispute, and the PKC response to these comments,
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56 including how the Evidence Report has been amended to take comments into account, has been provided. Key Agencies and Other Parties 3.3.1 As part of the development of our topic papers and this Evidence Report we engaged with the key agencies as prescribed through the Planning Act. The key agencies of relevance to the Perth and Kinross LDP3 Area, and with whom we engaged are: • NatureScot • SEPA • Scottish Water • Scottish Enterprise • Tactran • NHS Tayside, and • Historic Environment Scotland 3.3.2 All key agencies were welcome to respond in relation to any of our topic papers during the 6-week consultation period, but where feedback was specifically sought on a particular issue, we sent targeted engagement invitations to key agencies and other relevant parties/stakeholders flagging those papers we felt were most relevant and could benefit from their input – see Table 19 to follow. 3.3.3 We engaged and worked closely with the following list of internal Perth and Kinross Council Teams in preparing this Evidence Report: • Climate Change and Sustainable Development Team • Conservation Team • Culture and Community Service Team • Employability, Skills and Special Projects Team • Estates and Commercial Investment • Enterprise and Investment • The Water Team • Structures and Flooding • City and Town Centre Management • Perth and Kinross Community Planning Partnership • Property Services – Compliance Team • Property Services – Education • Transport Planning • Housing Strategy • Communities – Place Development • Communities – Safer Communities • Perth and Kinross Health and Social Care Partnership – Primary Care Services 3.3.4 During our Big Place Conversation exercise, the other parties which we engaged with and consulted were: • Community Development Trusts • Climate Cafes • Kinross-shire Partnership • PKAVS • Rainbow Heartlands • Perthshire Businesswomen’s Network • Sheltered housing tenants
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57 3.3.5 Table 19 below provides a list of those parties from whom we sought views in relation to specific NPF4 policy topics. Where feedback was received, it has been summarised and responses provided under the individual issues in Sections 5 and 6 and Appendices A-E of this report. Where any disputes or concerns were raised by key agencies, we have sought to resolve those disputes in advance of finalising this Evidence Report. In those instances, the individual issue summaries have recorded the outcome of those exchanges. Table 19: Evidence Report Topic Papers Targeted Engagement Policy Topic Ref: Stakeholders consulted/engaged 001 Plan Area • SEPA, Nature Scot and Historic Environment Scotland (HES) • Perth and Kinross Health and Social Care Partnership 004 Tackling Climate and Nature Crises • Perth and Kinross Climate Commission • SEPA, Nature Scot • Tayside Biodiversity Partnership 005 Biodiversity and Natural Places • Scottish Environment Link • Scottish Forestry • Forestry Commission Scotland • Peatland Action • NFU Scotland • Perthshire Nature Connections Partnership • NatureScot • SEPA • Tayside Biodiversity Partnership Policy Topic Ref: Stakeholders consulted/engaged 006 Soils • SEPA, Nature Scot and Historic Environment Scotland (HES) • James Hutton Institute (JHI) • Perthshire Nature Connections Partnership (PNCP) • NFU Scotland • Neighbouring planning authorities (Aberdeenshire, Angus, Dundee, Highland, Stirling, Fife, Clackmannanshire, Argyll & Bute, Cairngorms, Loch Lomond & Trossachs) • Peatland Action • Forestry Commission Scotland and Scottish Forestry • Scottish Environment Link • Scottish Govt 007 Forestry, Woodland and Trees • SEPA, Nature Scot • Scottish Forestry Perth and Argyll Conservancy • Perth and Kinross Countryside Trust • NFU Scotland East Central • Angus Council Environment and Development Planning Team • Cairngorms National Park Planning Team • The Highland Council Development Plans Team • Loch Lomond and the Trossachs National Park Authority Planning Team
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58 Policy Topic Ref: Stakeholders consulted/engaged 008 Historic Assets and Places • Historic Environment Scotland • Perth and Kinross Heritage Trust 009 Greenbelt • Nature Scot • TACTRAN • Ramblers Scotland • Local landowners 010 Brownfield, Vacant and Derelict Land • HES • Scottish Enterprise 011 Coastal Development and Aquaculture • Tay Estuary Forum • JHI • Scotland’s Centre of Expertise for Waters • Marine Scotland • Sniffer • Tay and Earn Trust • PKC Water Team • PKC Flooding Team • Nature Scot • SEPA 012 Energy, Heat and Cooling • SEPA, Nature Scot and HES • PNCP • NFU Scotland • Neighbouring planning authorities • Forestry Commission Scotland and Scottish Forestry • Scottish Environment Link • Scottish Renewables • Scottish Enterprise • Scottish Futures Trust • National Grid Policy Topic Ref: Stakeholders consulted/engaged • SSEN Transmission • SSEN Distribution • SP Energy Networks • Scottish Gas Networks • Zero Waste Scotland • Marine Scotland • Crown Estate • Binn Eco Park • Scottish Government 013 Zero Waste • PKC Waste Services 014 Infrastructure • Perth and Kinross Health and Social Care Partnership • NHS Tayside • Scottish Water • Tactran • Transport Scotland 018 Design, Quality and Place • Architecture and Design Scotland • Public Health Scotland 019 Local Living and 20 min neighbourhoods • Tactran • Cycling Scotland • Live Active • NHS Tayside • Perthshire Chamber of Commerce • Rural Perth and Kinross LEADER Programme • Women’s Enterprise Scotland 020 Homes • Members of the P&K Housebuilders Forum (includes developers and RSLs) • Homes for Scotland • Scottish Federation of Housing Associations
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59 Policy Topic Ref: Stakeholders consulted/engaged • Scottish Land and Estates • Rural Housing Scotland • National Farmers Union Scotland • MECOPP • Scottish Enterprise 021 Blue and Green Infrastructure • Tay Estuary Forum • JHI • Scotland’s Centre of Expertise for Waters • Marine Scotland • Sniffer • Tay and Earn Trust • PKC Water Team • PKC Flooding Team • Nature Scot • SEPA • PKC Community Resilience • PKC Flood Responses • PKC Community Greenspace 022 Play, Recreation & Sport • SportScotland • Live Active Leisure • A Place in Childhood • Play Scotland • Neighbouring planning authorities 023 Flood Risk and Water Management • Tay Estuary Forum • JHI • Scotland’s Centre of Expertise for Waters • Marine Scotland • Sniffer • Tay and Earn Trust Policy Topic Ref: Stakeholders consulted/engaged • PKC Water Team • PKC Flooding Team • Nature Scot • SEPA • PKC Community Resilience • PKC Flood Responses 024 Health and Safety • PKC Environmental Health • Health and Safety Executive 025 Community Wealth Building • N/A 026 Business and Industry • Federation of Small Business • Scottish Enterprise • Scottish Land and Estates • Perth Chamber of Commerce • Perth City Centre Regeneration Working Group • Perth City Traders Associations • Perth City Leadership Forum • Growbiz • Agents/consultancies with interests in employment land • PKC Estates and Investment teams 027 Retail, City, Town & Commercial Centres • Federation of Small Business • Scottish Enterprise • Perth Chamber of Commerce • Perth City Centre Regeneration Working Group • Perth City Traders Associations • Perth City Leadership Forum • Agents/consultancies with interests in retail
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60 Policy Topic Ref: Stakeholders consulted/engaged • PKC Estates and Investment teams 028 Rural Development • Scottish Land and Estates • Rural Housing Scotland • Scottish Rural Network • Forestry and Land Scotland • Nature Scot • Scottish Enterprise • Local landowners and estates 029 Tourism • Scottish Agritourism • Association of Scotland’s Self Caterers • Visit Scotland • Forestry and Land Scotland • Scottish Enterprise • Local Tourism Associations 030 Culture and Creativity • Culture Perth and Kinross 031 Minerals • N/A Children and Young People 3.4.1 Big Place Conversation (2023): Place Standard Engagement - We undertook an extensive programme of engagement with children and young people across the Perth and Kinross Council (PKC) Area as part of our Big Place Conversation (BPC) engagement. This involved Place Standard sessions with primary and secondary schools, as well as dedicated workshops with established youth groups. We held 28 dedicated sessions, which were attended by nearly 400 children and young people. 3.4.2 The purpose of the children and young people engagement was to gather views from this demographic on what they liked about their place/community and what could be improved. We used the Place Standard Tool for Children and Young People for our engagement, which focuses on the same 14 themes as the traditional Place Standard Tool. 3.4.3 In developing the children and young people engagement programme we engaged with the Council’s Children/Youth Services Team, youth group leaders, as well as with Members of the Scottish Youth Parliament (MSYPs). An invitation to participate in our engagement was issued to all schools across PKC, positive responses were then followed up and sessions arranged for all schools who wished to participate. 3.4.4 Our children and young people engagement comprised a mix of drop-in sessions with posters and post-it notes, as well as facilitated, sit-down sessions. We held sessions across all the localities in the PKC Area, and these were delivered and facilitated by Development Plans Team Officers with support from volunteer planning students. 3.4.5 The results of all the engagement sessions with children and young people have been recorded in event reports. These results have been compiled and are included in our summary reports. In particular, our Big Place Conversation overall Summary Report summarises the key issues highlighted by children and young people across PKC.
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61 3.4.6 Play Sufficiency Assessment - From August to November 2023, the ‘Playing Out in Perth and Kinross Survey’ was conducted online to gather insights on the usage of play sites, the types of activities enjoyed, and areas for improvement. The survey featured a mapping tool that allowed for site-specific feedback, helping to identify private and informal play spaces for further assessment. 3.4.7 A total of 322 responses were received from across all localities in Perth and Kinross. 170 respondents were girls, 135 boys, and 17 preferred not to answer. Most were aged between 4-8 years old, followed by the 9-14 age group, and then those aged 15 or over. 3.4.8 The survey primarily targeted children and young people, though parents and guardians were encouraged to participate. It was promoted through the network of schools, youth groups, and relevant community groups (including Community Councils) that was established during the BPC, as well as through PKC’s social media channels and consultation hub. 3.4.9 The survey results are summarised in the Play Sufficiency Assessment StoryMap, which also includes an interactive map containing the site-specific feedback received for formal playgrounds managed by PKC. 3.4.10 PKC Youth Climate Conference - In 2022, we held numerous workshops with attendees at the Perth and Kinross Youth Climate Conference. The conference included secondary school aged pupils from schools across PKC. The four workshops – delivered and facilitated by Development Plans Team Officers – involved Place Standard discussions using the ‘Climate Lens’ version of the Place Standard Tool. The purpose of the workshops was to gather views from young people on what they liked about their place/community and what could be improved, focussing on climate issues. 3.4.11 In 2023, we continued our involvement in the Youth Climate Conference by hosting another series of four workshops. This year's focus was on engagement to help inform the development of PKC's Open Space Strategy. We gathered feedback on how urban greenspaces could be managed to mitigate and adapt to climate change. The feedback was collated into the Big Place Conversation responses and will contribute to the development of our blue-green infrastructure policy and spatial strategy. Disabled Persons 3.5.1 Through connecting with established groups within Perth and Kinross we engaged in conversations with disabled people using the Place Standard questions in a café style format. We also attended organised events to facilitate drop-in opportunities, which followed the format of other drop-in sessions held across the Council Area as part of the wider Big Place Conversation exercise. Some of the conversations we held were with attendees at:
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62 • VisionPK coffee mornings in Kinross and Aberfeldy. VisionPK represents people in our communities with sight and hearing difficulties. • We had a lively conversation with attendees from around Kinross-shire at a meeting of SPARKs in Kinross. SPARKs is a dedicated self-support group for adults who consider themselves to have a disability. • We attended the Disability Access Day in a drop-in capacity inviting one-on-one conversations with attendees. • We held conversations with and received valuable feedback from The Social Care Users Committee in Blairgowrie, and with the Making Where We Live Better Group for people with learning difficulties. 3.5.2 In total 40 participants, identifying as disabled persons, participated via in person events, with a further 22 people taking part online. In analysing the feedback received through our engagement, we found that comments received from older people and those living in sheltered accommodation also share commons concerns with those identifying as disabled who took part. 3.5.3 Information on the results can be found in the Big Place Conversation Report summary which was used in evaluating the evidence across the various issues for this Evidence Report and will help inform the development of our place-based strategies in the Proposed Plan. Gypsies/Travellers 3.6.1 Previous engagement with Gypsy/Travellers in 2022 informed the Gypsy/Traveller Site Standards Guidance Note. This covered a range of issues relating to sites, their location and facilities. Engagement was also carried out to inform the design of the proposed transit site in Perth, with this information being used for the guidance note. 3.6.2 This information gathered as part of the engagement for the Guidance Note and design of the proposed site in Perth provides a picture of what is important to people when choosing where to live and the facilities and services that are needed on site or nearby. It will also be taken into account as part of the development of the Proposed Plan. 3.6.3 As part of the Big Place Conversation, conversations took place with private residents of Greenacres, south of Kinross, and with a small group of residents on Double Dykes in Perth and one person in settled accommodation. In 2023 a human rights analysis [Core Doc Refs: CD29, CD30] was carried out by Making Rights Real with the residents of the Council owned Gypsy / Traveller site at Double Dykes. The results of this have been included in the Big Place Conversation Results. 3.6.4 A review of Gypsy/Traveller need across Tayside was undertaken in 2017. This concluded that there was no immediate shortage of permanent pitches in Perth and Kinross but there was likely to be a shortage of transit sites. The Council carried out engagement
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63 with Gypsy/Travellers to identify historic stopping places and reviewed these against ownership and safety criteria. The Council participated in a Negotiated Stopping Places Pilot, but due to constraints it became apparent that there were no suitable sites to direct travellers to. As a result, a 10-pitch site has been identified in Perth to meet the greatest need. An updated accommodation needs assessment for Gypsy/ Travellers has not been undertaken. Community Councils 3.7.1 Big Place Conversation (2023) - Community Councils are key partners in developing the Local Development Plan. As part of the Big Place Conversation all extant community councils were engaged with to help shape the engagement in their area. This extended in some areas to engagement with active Community Development Trusts who have existing Community Action Plans or are looking to develop Local Place Plans. 3.7.2 Community Councils participated in public events including the school programme, held special meetings to submit online responses, or offered a one-on-one conversation with a Development Plans Team Officer. Where Community Councils were unable to fully participate, they were often helpful in suggesting engagement methods and opportunities including tying in with their own engagement or gala days. 3.7.3 All Community Councils in each Council Ward were provided with detailed results in September 2024 and summary reports by November 2024. Feedback has also been provided through presentations to Stronger Communities networking events. 3.7.4 Feeback received on behalf of Community Councils as part of our Topic Papers consultation exercise has also been reviewed and responded to, where relevant, as part of the analysis of individual policy issues under Sections 5 and 6, and Appendices A-E of this Report. How and where the Evidence Report has been amended, considering that feedback, has also been recorded in these sections. Ethnic Minorities 3.8.1 Invitations were extended to the variety of groups in Perth and Kinross to participate, but with limited success. A contributing factor has been the amount of engagement which groups have faced recently. An event was held in Perth with 6 participants of an English for Speakers of Other Languages (ESOL) group with participants from a range of ethnic minorities. However, Place Standard exercises had been carried out by the Council’s Equalities Team in 2021. Where relevant this information has been included in the Big Place Conversation summaries. This reached 39 people in ethnic minority groups people including local South Asian, Chinese community members.
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64 4 Perth and Kinross LDP2 Monitoring DELIVERY OF PERTH AND KINROSS LOCAL DEVELOPMENT PLAN 2 4.1.1 The Scottish Government’s LDP Guidance highlights that in preparing their Evidence Report, planning authorities should evaluate whether their previous local development plan has delivered on its outcomes and allocations, and identify any lessons which have been learnt for the preparation of the new plan. The Guidance also suggests that planning authorities may wish to consider the appropriateness of their previous spatial strategy. However, it does makes clear that new proposals or site- specific detail should not be included at the Evidence Report stage. 4.1.2 This section of our Proposed Evidence Report considers how effective the implementation of our Perth and Kinross Local Development Plan 2 (LDP2) has been since it was adopted in November 2019, but concentrates on those matters suggested in the Scottish Government’s May 2023 LDP Guidance. 4.1.3 In considering the effectiveness of the Plan’s implementation, it is important to note that in doing so, we must be mindful of the introduction in 2023 of a suite of National Planning Policies through National Planning Framework 4, and the revocation of our Strategic Development Plan (SDP) – TAYplan2 through the 2019 Planning Act. 4.1.4 In light of this, a separate evaluation of our LDP2 policies has been carried out as part of the preparation of this Evidence Report, and in conjunction with our Development Management colleagues, to identify which LDP2 policies have been superseded by NPF4, where possible tensions exist between any of the national policies and equivalent policies in LDP2, and whether there may be a need for a local policy response to be developed through LDP3 to address any local level detailed issues which are not currently covered by NPF4. An overview of the outcomes of this exercise can be viewed in Appendix E to this report. 4.1.5 In respect of LDP2’s Spatial Strategy, the context for this was set by TAYplan, and followed a tiered ‘Principal Settlement’ approach to directing future sustainable development. It also identified long term Strategic Development Areas. As that SDP was revoked under the 2019 Act, and considering the introduction of NPF4’s Spatial Principal to rebalance development to “create opportunities for communities and investment in areas of past decline”, namely rural areas which have experienced population decline, and its new policy on local living and 20 minute neighbourhoods, it is likely that whilst the principle of directing future growth to the most sustainable locations i.e. Principal Settlements is still appropriate and relevant, the LDP2 Spatial Strategy will need to evolve to incorporate the outcomes of our work on identifying local living and 20 minute neighbourhoods (including networks of) in the context of Perth and Kinross, along with the review under the Rural Development issue of this
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65 Evidence Report relating to NPF4 Policy 29’s Policy Outcome of a balanced and sustainable rural population. Perth and Kinross LDP2 – Form and Content 4.2.1 The Adopted Perth and Kinross Local Development Plan 2 contains a Vision, and a Spatial Strategy, which is divided into the 4 distinctive themes of – A Successful, Sustainable Place, A Low- Carbon Place, A Natural, Resilient Place, and A Connected Place. 4.2.2 The Plan’s Vision was that of the then adopted Strategic Development Plan (TAYplan2, 2016-2036): “By 2036, the TAYplan area will be sustainable, more attractive, competitive and vibrant without creating an unacceptable burden on our planet. The quality of life will make it a place of first choice where more people choose to live, work, study and visit and where businesses choose to invest and create jobs.” 4.2.3 Each Spatial Strategy Theme has its own more focused vision, a set of key objectives, and a suite of associated policies. Section 4 of LDP2 is the ‘Settlement Statements’ section, which provides a map of each settlement within the Perth and Kinross Area, a summary of the key characteristics of that settlement, and any identified site proposals. For any site proposals a table has been provided setting out the relevant details for the development of the site, including size, allocated land uses (employment, residential, mixed uses etc.), and any site-specific developer requirements. 4.2.4 The section to follow sets out, for each of the Plan’s 4 themes, a summary of how well the implementation of the Plan has delivered against the identified objectives and allocations. Implementation of LDP2 Spatial Strategy Themes A Successful, Sustainable Place 4.3.1 The Plan identifies 7 Key Objectives under this first theme, these objectives and a summary of how successful their implementation has been to date, and where relevant any lessons learnt, are set out below. 1. Creation and continuation of high-quality places that meet the needs of the existing and future communities. In support of this objective, Policy 1 Placemaking and its associated supplementary guidance (SG) have been well used to aid decision making. The Placemaking guide SG helps clarify how to apply Policy 1 Placemaking, it provides guidance on an appropriate design process (site appraisal, engagement, vision, and implementation), guidance on applying the policy principles, and provides technical guidance. The Placemaking guide provides clear explanations as to how to achieve high quality development that responds to the unique setting of Perth and Kinross. The Council also prepared detailed site-specific guidance, through the Thimblerow Development Brief (2021) to help guide a high-quality exemplar scheme demonstrating the potential for city centre living in a low carbon development. Design training with developers/agents, officers, and Elected Members has been carried out to raise awareness and improve
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66 application of the placemaking policy framework. A collaborative approach, together with this policy framework, provides clear expectations for design, quality and place taking account of the local context, characteristics, and connectivity of the area. This approach helps deliver high quality places, and in the Scottish Household Survey (2022) 95% of residents ranked their neighbourhood as very or fairly good. During the period from late November 2019 through to late August 2024, Policy 1 was used a total 5634 times in the decision-making process for planning applications. This represents 97.8% of the overall planning applications determined during that time, indicating its importance in the decision making. 8.9% of those applications for which this policy was applied were refused, with the related Report of Handling citing that was part of or the reason for refusal was due to the proposal being contrary to Policy 1 of LDP2. 2. Support for local businesses to ensure economic growth in the region. The most recent Employment Land Audit (ELA) in 2022 identified there is a total of 292.72 Hectares (Ha) of Employment Land, of which 44.98 Ha are Windfall Sites, and 247.74 Ha are allocated Employment land in the Local Development Plan (LDP). This is a healthy land supply in the context of an average take up of employment sites in last 8 years of 2.1 Ha per annum. To support this objective Policy 7 Employment and Mixed-Use Areas has supported the safeguarding of existing employment How successful has its implementation been? It is considered that this objective has been met. The Council’s Placemaking Guide is still very relevant, as it was developed on the basis of the Scottish Government’s six qualities of successful places (SPP 2014), which have been updated slightly to the current set of qualities at Annex D of NPF4, with the key elements and objectives remaining the same. The Guide’s continued use will help support the delivery of the six qualities on the ground, but it is likely that it will require a review and some minor updates, as part of our LDP3 development, to ensure the references contained within it and the terminology used are in line with NPF4, to allow its future use alongside LDP3.
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67 land and LDP2 has also allocated sites for economic development. There has also been support for the expansion of existing businesses and creation of new ones in rural areas through Policy 8: Rural Business and Diversification. There have been 190 applications assessed against Policy 7 Employment and mixed-use areas, and 175 have been approved (92% approval rate). This evidence highlights that this policy has been supportive of a lot of employment related development within these areas. The tourism industry is a significant economic driver in Perth and Kinross, and it has above average levels of employment in accommodation and food services. Through Policy 8: Rural Business and Diversification, proposals for new tourism-related developments, and the expansion of existing facilities, have been supported where it can be demonstrated that they will improve the quality of new or existing visitor facilities, allow a new market to be exploited, or extend the tourism season. Policy 9: Caravan Site, Chalets and Timeshare Developments provides further specific support for these uses where proposals are an expansion of an existing facility, are replacing static caravans, or meet a specific need. Policy 8 has been used 461 times and there have been 408 approvals (88.5% approval rate) and Policy 9 has been used 119 times, and there have been 86 approvals (72.3% approval rate). This evidence highlights that that these policies have been supportive of a lot of rural business and tourism development. The Tay Cities Region Deal, signed in 2020, covers the areas of north Fife, Angus, Dundee and Perth and Kinross and will see an injection of an estimated £400m into the region over 15 years. In Perth and Kinross, this includes two plant science centre’s focusing on solutions for the food and drink industry regarding climate change and the green recovery at the James Hutton Institute in Invergowrie. The Deal will also fund Perth Innovation Highway - a 5-mile smart technologies corridor linking Perth Eco-Innovation Park at Perth West, a 25 Hectares of employment land and Perth City Centre. Deal funding is also provided for a low carbon transport and active travel programme including the development of a low carbon transport hub at Broxden Park and Ride in Perth. This will help make this core employment location more sustainable. Funding will also be provided for high-speed broadband access in rural Perth and Kinross. Support is also being provided for a flagship plastics recycling project at Binn Eco-Park as well as support for engineering via Aviation academy and Tayside Engineering Partnership projects. The Cross Tay Link Road will provide new major road infrastructure to support the growth of Perth and the future development of employment areas. The Deal’s investments also include a skills and employability programme, supporting the region’s culture and tourism offerings. How successful has its implementation been? It is considered that LDP2 has provided considerable support for local businesses, whilst the Tay City Deal has been significant in helping fund projects to ensure economic growth, and this objective has been met.
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68 3. Provide an ongoing supply of readily available commercial/ industrial land of 25ha across Perth and Kinross. At the time of the most recent ELA 2022, there was 36.94 Ha of serviced employment land, and with limited take up in the interim, this will not have changed significantly when the 2024 audit is prepared, late 2024. This objective has been assisted by allocation of employment land in the Local Development Plan, and requirements for strategic sites to service employment land alongside the delivery of more profitable uses, largely housing. However, providing an ongoing supply largely relies on the Council servicing sites for employment land, as the private market would not ensure there is sufficient readily available commercial/ industrial land. Whilst overall employment land supply is healthy, delivery is not without challenges with the share of employment sites owned by the Council being low. The Council supplied Ryden with its employment land assessment matrices for 41 LDP2 allocated sites. Ryden provided a summary assessment relating to these sites for the Perth area, Strathearn, Kinross, Highland, and Strathmore and the Glens. The Council’s employment land matrices utilise a ‘balanced scorecard’ approach to determine the sites most likely to require intervention. This considers marketability, any evidence of market failure, planning constraints, potential demand, and consideration of the site against strategic priorities. This work considering LDP employment land allocations and their relative priority for public sector intervention will help inform the LDP review, help with delivery of LDP sites, and will inform Perth and Kinross Council’s Investment Property Strategy, its Commercial land and property portfolio, and Commercial Property Investment Programme. It will also assist in maintaining the Perth and Kinross Council Corporate Plan key performance indicator for the area of immediately available serviced business land to an appropriate level. 4. Focus on retail and commercial development in accessible centres that provide employment and services to residents and visitors. The existing LDP2 focuses retail, commercial, and other significant footfall development through, Policy 10: City, Town and Neighbourhood Centres, Policy 11: Perth City Centre Secondary Uses Area, Policy 12: Commercial Centres and Retail Controls, and 13: Retail and Commercial Leisure Proposals, and How successful has its implementation been? This objective is not wholly within the control of LDP2, but LDP2 has nevertheless helped support efforts to meet it. As there is sufficient supply of readily available commercial/industrial land available, it is considered that this objective has been met. However, the servicing of employment land has not been defined in a consistent way, and a road being provided up to edge of a larger area (which has been delivered in some instances), rather than to individual plots within, does not contribute to the serviced land supply. A definition for serviced employment land in LDP3 would better assist with the delivery of serviced employment land.
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69 through its spatial strategy and hierarchy of centres. This has supported the role of our centres, in these challenging times. The Perth and Kinross City and Town Centre Retail Study was updated in February 2023. It provides the evidence base to assist PKC with its work on the LDP review. The retail capacity forecasts for retail floorspace has identified an overall over- supply of both convenience and comparison goods in the Perth and Kinross Area covering the Local Development Plan period from 2027 to 2037. The amount of surplus retail floorspace forecasted is particularly acute in Perth City Centre, and this is additional to the centre’s vacancies which, in floorspace terms, stand at around 14% according to Experian Goad. The evidence all points to a need to move on from retail led city and town centres towards more multi-purpose destinations in their offer, use and experience. How successful has its implementation been? Whilst LDP2 has largely met this objective, through its retail and town centre policies, and hierarchy of centres, NPF4 has updated the LDP2 retail policy framework and helps strengthen the town centre first principles for all significant footfall generating uses, and the development plan/retail study led approach to identifying and allocating for retail deficiencies. Also, NPF4, through its local living policy clarifies the importance of neighbourhood centres, and LDP3 will need to update the neighbourhood centres and identify these more comprehensively. LDP3 will likely make some changes to better dovetail with and support NPF4. NPF4 introduces a stricter approach to out of centre retail to protect existing centres. Out of 35 applications related to creating new retail space or retaining or altering an element of existing retail provision, 2 have been refused (approval rate of 94.3%). However, there are significant retail applications contrary to the Development Plan currently under consideration, and this high rate of approval may not be sustained going forward. It is noted that it is mainly larger retail planning applications that are not in accordance with NPF4.
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70 5. Ensure provision of housing that is socially inclusive and meets a wide range of needs. In terms of the quantity of new housing which has been delivered during the Plan period, this is monitored annually in the Council’s Housing Land Audit (HLA). The housing land requirement for LDP2 was set by the Strategic Development Plan, TAYplan2, at an average of 1,000 units per year. Whilst shortfalls in housing land supply in some housing market areas have been observed during the Plan period, this has not been a land allocation issue but rather the delivery of that land in the short-medium term. In relation to housing provision being socially inclusive and meeting a wide range of needs, several policies have worked together to seek to achieve this. The Housing in the Countryside policy has developed over several different Plans and the most recent iteration, Policy 19 in LDP2, has actively supported proposals for the erection or creation of single and small groups of houses in the countryside which fall into at least one of the six well established categories. Policy 20: Affordable Housing is another long-established policy which has sought an affordable housing contribution amounting to an equivalent of 25% for sites of five or more units over several Plan periods now. Both Policy 20 and Policy 19 rely heavily on their detailed associated statutory supplementary guidance for implementation. The ‘Developer Contributions and Affordable Housing Supplementary Guidance’ was revised in December 2023. This revision reasserts the sequential approach to the provision of the affordable housing contribution: on-site first then off-site with commuted sums only being accepted in exceptional circumstances. Policy 21 sets the policy framework to assess new sites for Gypsy/Travellers. This has been supplemented by a Gypsy/Traveller Site Standards Guidance Note following discussion with residents on Council and private sites There were no specific site allocations for new Gypsy/Travellers’ sites in LDP2, although the settlement boundary of Greenacres private site was drawn to allow for expansion. Only a small number of planning applications have been submitted relating to Policy 21 during the lifetime of the Plan. Most notably permission was granted for replacement chalets on an existing Gypsy / Travellers site, and permission refused for an extension to another small existing Gypsy/Traveller site on health and safety grounds. Following the 2017 Tayside review of accommodation needs which identified the need for transit provision the Council completed a review of potential sites informed by discussions with Gypsy/Travellers on traditional use, safety and ownership. This resulted in the commitment to a 10-pitch site in Perth which is currently in pre-planning stages. Policy 22: Particular Needs Housing Accommodation has been used in assessing planning applications since the adoption of LDP2 and has helped facilitate the development of a residential assisted living scheme for over 55s, a change in house type to allow for a specialist need bungalow to be provided on a larger scheme, assisted living units, and a 10-unit House in Multiple Occupation (HMO) aimed at providing student accommodation. Policy 25: Housing Mix is a new policy which was added to LDP2 to help secure a more appropriate mix of housing for developments on sites with a total capacity of 20 or more homes. These proposals should meet the needs of smaller households, including older people and lower income
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71 households, and address part of this need by providing at least 10% of their homes as one- or two-bedroom homes. 6. Promotion of a strong cultural character through arts, cultural, community sport and recreational facilities offering opportunities for social interaction and local identity. To support this objective Policy 16: Social, Cultural and Community Facilities has provided protection against loss of or change of use of land or buildings presently or last used for community purposes, whilst Policy 14: Open Space Retention and Provision provides protection for existing open spaces which have value to the community for either recreational or amenity purposes, and also secures appropriate provision of new open spaces within new developments. NPF4 does not currently address protection of open space for landscape/ amenity reasons, only referring to whether there is a green infrastructure deficit. Relying on NPF4 alone could mean many of our current open spaces would have less policy protection. 7. Maintain the distinctiveness and diversity of the area through the protection and enhancement of the natural and historic environment. To support this objective, policies 26: Scheduled Monuments and Archaeology, 27: Listed Buildings, 28: Conservation Areas, 29 Gardens and Designed Landscapes, 30: Protection, Promotion and Interpretation of Historic Battlefields, and 31 Other Historic Environment Assets have together provided a suite of policies which have protected this full range of historic environment assets. Also, the allocation of sites for development, has directed development to appropriate locations, and identified site specific developer requirements in relation to the historic environment, which have also helped protect the distinctiveness and diversity of the area. LDP2 largely contributes to this objective in a reactive sense, seeking to protect existing assets, and support their appropriate reuse where proposals come forward, but it cannot control the delivery of this objective in terms of How successful has its implementation been? The delivery of houses is largely outwith the Council’s control, but the suite of policies within LDP2 have helped ensure that where houses have been permitted, they have met this objective. How successful has its implementation been? The LDP2 policies are currently meeting this objective, whilst LDP3 will need to consider how it dovetails with NPF4. In particular, NPF4 Policy 31 emphasises the importance of protecting and supporting our creative sector, culture, heritage, and the arts which should be reflected in the LDP3 Spatial Strategy, including identifying those specific buildings/areas of land to be protected/supported.
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72 bringing forward proposals, and enhancements, and it is noted that in May 2024, 115 buildings within the Perth and Kinross Area were included on the Buildings at Risk Register for Scotland. The protection and enhancement of the natural environment is covered under Theme 3: A Natural, Resilient Place, please refer to this theme for more information. A Low-Carbon Place 4.4.1 The Plan identifies 6 Key Objectives under this theme, these objectives and a summary of how successful their implementation has been to date, and any lessons learnt, where relevant, are set out below. 1. Improve the long-term resilience and robustness of the natural and built environment to climate change. This Key Objective was also repeated under the ‘A Natural, Resilient Place’ Spatial Strategy, demonstrating the overarching nature of these issues and the need to tackle the dual climate and ecological crises together. Due to the interconnected nature of our planning policies and the need to take a coordinated approach to addressing the twin crises, there are several policies in LDP2, spread across all 4 Spatial Strategy themes, which seek to improve the resilience and robustness of our natural and built environment of Perth and Kinross against the effects of a changing climate and loss of biodiversity. These policies include but are not limited to, Policy 1: Placemaking and its associated supplementary guidance; Policy 3: Perth City; Policy 4: Perth City Transport and Active Travel; Policy 6: Settlement Boundaries; Policy 8: Rural Business and Diversification; Policy 10: City, Town and Neighbourhood Centres; Policy 14: Open Space Retention and Provision; policies 26 to 31 regarding historic assets and places; policies 32 and 33 relating to renewable, low and zero carbon energy technologies; Policy 34: Sustainable Heating and Cooling; Policy 36: Waste Management Infrastructure; Policy 38: Environment and Conservations (designations); Policy 39: Landscape; Policy 40: Forestry, Woodland and Trees and associated Forest and Woodland Strategy; Policy 41: Biodiversity; Policy 42: Green Infrastructure; Policy 44: Perth Lade Corridor; Policy 46: Loch Leven Catchment Area; Policy 50: Prime Agricultural Land; Policy 51: Soils; Policy 52: New Development and Flooding; Policy 53: Water Environment and Drainage; Policy 56: Noise Pollution; Policy 57: Air Quality; Policy 58: Contaminated and How successful has its implementation been? As previously highlighted, although it is not wholly within the control of LDP2, the Plan has nevertheless contributed and supported efforts to meet this objective, and whilst there are opportunities for improvement, it is largely being met. The LDP3 Spatial Strategy should explore interconnections between our historic environment with other key policy connections to help maximise opportunities for its protection and enhancement.
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73 Unstable Land; Policy 59: Digital Infrastructure, and Policy 60: Transport Standards and Accessibility Requirements. Subject to site specific detailed consideration, LDP2 policies 32- 35 support development proposals in terms of mitigating against the effects of climate change and promoting low carbon actions. These policies are further supported by key Guidance on: Delivering Zero Waste, Placemaking, and Renewable Energy. LDP2 policy 59 supports development which makes provision for digital infrastructure provided the environmental impacts on the natural and built environment are minimised. This provides opportunities to support local living and working, potentially reducing the need to travel. LDP2 policy 60 promotes a shift to the more sustainable modes of travel of walking, cycling and public transport giving people travel choices that minimise the long-term impacts on our climate. 2. Ensure that development and land uses make a positive contribution to helping to minimise the causes of climate change and adapting to its impacts. Subject to site specific detailed consideration, LDP2 policies 32- 35 support development proposals in terms of mitigating against the effects of climate change and promoting low carbon actions. These policies are further supported by key Guidance on: Delivering Zero Waste, Placemaking, and Renewable Energy. Out of 657 planning applications referring to Policy 52 New Development and Flooding, 115 of those applications have been refused. This is a relatively substantial refusal rate of 17.5% which suggests that this policy is being applied effectively, and applications contrary to this policy are largely being refused. How successful has its implementation been? This objective is considered to have been met through the suite of LDP2 policies and guidance which is enabling the shift towards renewable and low carbon energy technologies, whilst at the same time ensuring suitable environmental protections are in place. How successful has its implementation been? To the extent that LDP2 has influence over new development and land use, this objective is considered to have been met. Wider land use considerations e.g. agriculture, are considered further under the Council’s Climate Change Strategy and Action Plan. LDP3 will need to consider local living and the concept of 20 minute neighbourhoods, alongside climate change adaptation and mitigation measures, using nature based solutions where possible – as per NPF4 – to further support the creation of more resilient and adaptable places, providing those benefits of living locally, having access to facilities and services, and reducing private car use.
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74 3. Protect the natural and built environment and ensure that new development embraces the principles of sustainable design and construction, energy efficiency and heat decarbonisation. Relevant LDP policies inform development proposals to ensure protection of the natural and built environment alongside key Guidance including on: Delivering Zero Waste, Planning and Biodiversity, International Sites (Loch Leven SPA, Dunkeld- Blairgowrie Lochs SAC, and River Tay SAC), Placemaking, and Renewable Energy. The Placemaking Guidance includes guidance that is used to inform considerations of energy efficiency, passive design, construction and materials, retrofitting sustainable design, and recycling facilities and initiatives. The Renewables Draft Guidance also includes detailed guidance on how to address key concerns around natural heritage. Policy 32 of the LDP2 also implements Section 3F of the Climate Change (Scotland) Act in terms of requiring a proportion of carbon emissions reductions to be delivered through low and zero carbon generating technologies. 4. Protect and enhance the character, diversity and special qualities of the area’s landscape to ensure that new development does not exceed the capacity of the landscape in which it lies. LDP2 Policy 39 has promoted the local values of the area’s landscapes including safeguarding views from the impacts of development, providing mitigation and enhancement and protecting the experience of the night sky. Local Landscape Areas first identified in 2015 have continued to be a primary How successful has its implementation been? This objective is considered to have been met. LDP2 policies and guidance ensure that appropriate consideration of impacts on the natural and built environment are made, including any mitigation measures necessary. The principles of sustainable design and construction, energy efficiency and heat decarbonisation are being driven through suitable planning proposals as well as wider legislative proposals including Building Standards and Heat Networks Zoning. LDP3 will need to consider the opportunities for decarbonising heat through alignment with the Council’s LHEES, and opportunities from the Local Area Energy Plan realised.
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75 consideration where potentially affected by both built development and forestry applications with mitigation such as broadleaf planting and safeguarding recreational routes and viewpoints. When responding to consultation requests for felling permissions, long term forestry plans and woodland creation proposals, the presence of Local Landscape Areas are routinely highlighted, and application of the supplementary guidance recommended to Scottish Forestry and private landowners and land managers. NPF4 does not contain a specific landscape policy for non- designated landscapes and there has been significant additional pressure because of the qualification in NPF4 Policy 11 regarding the significant impacts of renewable energy which may see a degradation of our valued landscapes. While work is ongoing on designating Local Geodiversity Sites, candidate sites are available to planners which has allowed applications and particularly in the context of forestry consultations to ensure adverse impacts are avoided. The survey information on quarry and mining sites is also being used to inform restoration proposals. Policy 43 is a restrictive policy which has limited development in the designated Green Belt area to those outlined in previous national and regional level plans and policies. All proposals have also had to comply with the overall objective of the Green Belt to protect and enhance the character, landscape setting and identity of settlements. Polic 33 gives support to proposals for the utilisation, distribution and development of renewable and low carbon sources of energy subject to site specific detailed consideration. All proposals have been required to take account of individual or cumulative effects on landscape character, Local Landscape Areas, Wild Land Areas and National Scenic Areas. 5. Conserve and enhance habitats and species of international, national and local importance. This Key Objective is also repeated under the ‘A Natural, Resilient Place’ theme. How successful has its implementation been? This objective is considered to have been met in the context of LDP2 policy and guidance, which provide protection for important landscapes, including nationally and locally designated areas. The expectations around landscape impacts from renewable energy developments have shifted through NPF4 Policy 11 with significant localised effects to be expected. Careful project design and mitigation will be key to minimising significant landscape impacts arising as a result of renewable energy developments. Supplementary Guidance to support LDP Policy 39 (Landscape) is an important guide in considering impacts from these types of developments and forestry related developments on local landscape areas.
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76 Potential impacts on European Protected Species, priority species and habitats are required to be identified through PKC’s Planning for Nature guidance. This includes the requirement for Habitat Regulations Appraisal where a European Site is potentially affected. Internationally recognised habitats, namely the Tay SAC, Lunan Lochs and Loch Leven catchment areas, have received particular protection in applications including enhancement through additional phosphorus mitigation in the Loch catchments. Through Planning for Nature, the requirement for enhancement for Tayside LBAP species has been promoted with swift, house martin and barn owl nest resources, hedgehog highways, bat roosts and mitigation for amphibian dispersal becoming standard. The introduction of NPF4 has seen a greater awareness of biodiversity measurement with significant uplift in biodiversity on some sites. In 2024 (to August) 92% of developments (excluding householders) will deliver enhancement - the remainder due to a lack of opportunities on site, and 12% provided a site biodiversity action plan. There is still room to improve practice with 6% of applications not mentioning biodiversity. NPF4 precludes a requirement for householder development enhancement measures which in 2024 could have delivered biodiversity enhancement on 35 homes with a potential 70 nesting/roosting resources. Local Biodiversity Sites have been identified in candidate form and are used to inform applications particularly when we are consulted on forestry applications. While threats from forestry still occur, control over development has ensured that these candidate sites are not adversely affected. 6. Promote the sustainable development of electricity generation from a diverse range of renewable and low-carbon energy technologies, including the expansion/repowering of renewable and low-carbon energy generation capacity and heat networks, in accordance with national objectives and targets. Proposals for new and repowered/expanded energy generation supported by Policy 33 subject to detailed assessment against relevant policy criteria. Draft Guidance on Renewable Energy has been prepared and will be updated in 2025 to reflect updated national planning policy framework. NPF4 has significantly updated the planning policy framework in support for renewable energy generation, through Policy 11: Energy, Heating and Cooling. Significant weight – through How successful has its implementation been? This objective is met as a priority. Improvement has been made in the quality of applications received, although despite NPF4 and PKC guidance there are still applications being submitted without baseline environmental information, enhancement proposals or further surveys that had been identified in ecological reports which may require policy in LDP3 to address this. In 2024, 36% of applications contained insufficient information on biodiversity on receipt requiring further information to be requested or carried out.
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77 NPF4 Policy 11e – is placed on the contribution of the proposal to renewable energy generation targets and greenhouse gas emissions reduction targets. This is further supported by NPF4 Policy 1: Tackling the Climate and Nature Crises) which gives significant weight to the global climate and nature crises. The uptake of heat network development has been limited since the adoption of LDP2. Key strategic sites have considered the viability of heat network deployment and proposals for future safeguarding have been incorporated into long-term plans, where applicable. Future for decarbonising heat, including identifying heat network zones, will be driven by the Council’s Local Heat and Energy Efficiency Strategy (LHEES) adopted in 2024. This will align with NPF4 Policy 19 (Heat and Cooling), where the LHEES is expected to drive localised heat decarbonisation. A Natural, Resilient Place 4.5.1 The Plan identifies 5 Key Objectives under this theme, some of which have been repeated under other LDP2 Spatial Strategy themes. These objectives and a summary of how successful their implementation has been to date, and any lessons learnt, where relevant, are set out below. 1. Conserve and enhance habitats and species of international, national and local importance. This Key Objective is repeated in the ‘A Low-Carbon Place’ theme (refer to Key Objective 5). The evaluation provided under that theme is applicable to this theme also. 2. Identify and promote green networks where these will add value to active travel, the provision, protection and enhancement and connectivity of habitats, recreational land, and landscapes in and around settlements. Green infrastructure and Planning for Nature guidance has promoted consideration of connectivity of habitats and How successful has its implementation been? This objective is considered to have been partially met in the context of supporting renewable energy proposals subject to suitable environmental and amenity considerations, whilst heat networks will be further considered under the newly published LHEES and emerging national plans and policy around heat network zoning. How successful has its implementation been? This objective is met as a priority. Improvement has been made in the quality of applications received, although despite NPF4 and PKC guidance there are still applications being submitted without baseline environmental information, enhancement proposals or further surveys that had been identified in ecological reports which may require policy in LDP3 to address this. In 2024, 36% of applications contained insufficient information on biodiversity on receipt requiring further information to be requested or carried out.
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78 enhancement of opportunities to promote greening of active travel routes within control of the developer. Indicative landscaping in development plan allocations have helped promote delivery of green networks and enhancement of habitat. LDP Policy 14 has helped to protect existing designated open spaces from inappropriate development. 3. Improve the long-term resilience and robustness to the natural and built environment to climate change. LDP2 Policy 51: Soils has minimised development on carbon rich soils, peatland and priority peatland habitat to several limited exceptions, as well as ensuring peatland management plans are secured through condition(s) to promote best practice for the handling, storing and reinstatement of any carbon rich/peaty soils. Where developments impact on soils more generally, planning conditions have been secured for soil management plans to ensure good soil management throughout the development process including during construction and as part of reinstatement. Where Policy 51 is referenced, the approval rate is 84%. LDP2 Policy 50: Prime Agricultural Land protects this key natural resource from being lost to inappropriate development. Where Policy 50 has been referenced in relation to applications for development, the approval rate is 80%. LDP2 Policy 53C: Surface Water Drainage has secured proposals for new development which avoid pollution and attenuate flows to greenfield run-off levels. Policy 53C also promotes natural solutions, encouraging them to achieve multiple benefits, and in terms of flood risk and flood risk assessment, and open space provision for new developments, supplementary guidance documents provide detailed guidance on the design process, how to consider drainage from the outset, as well as providing design guidelines for natural SuDS features. Securing integrated natural green and blue network SuDS solutions has been fairly successful on larger strategic sites where land take is less of a concern. However, most development proposals still favour engineering solutions, and where proposals meet greenfield run-off levels it is difficult to secure improvements for multi benefit solutions. The need for more detailed guidance on SuDs/maintenance standards has been identified in the current review of the Roads Development Guidance. The protection of Local Biodiversity Sites continues to provide genetic reservoirs. How successful has its implementation been? This objective is considered to have been met in the context of LDP2 policy and guidance. In line with NPF4, LDP3 will look to identify opportunities for new and enhanced blue and green networks which provide multiple benefits for people and nature across Perth and Kinross.
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79 4. Ensure that development and land uses make a positive contribution to helping minimise the causes of climate change and adapting to its impacts. The Council’s Planning for Nature guidance introduced a requirement for the compensation of tree loss on a 1:3 basis, providing a disincentive for tree loss and a greater uptake of carbon from replacements. The guidance also requires that surveys are undertaken prior to development to ensure that interventions do not adversely impact on woodland or peatland habitats. Until the introduction of NPF4, Policy 32 of the Adopted LDP2 required 10% of carbon emissions to be met through low and zero-carbon generating technologies. LDP2 Policy 51 has minimised development on carbon rich soils, peatland and priority peatland habitat to several limited exceptions, as well as ensuring peatland management plans are secured through condition(s) to promote best practice for the handling, storing and reinstatement of any carbon rich/peaty soils. Peatland restoration proposals have also been secured through condition for a range of developments, primarily in upland areas. 5. Protect and enhance the character, diversity and special qualities of the area’s landscape to ensure that new development does not exceed the capacity of the landscape in which it lies. This Key Objective has also been repeated under the ‘A Low- Carbon Place’ theme of LDP2 (Key Objective 4). The evaluation provided under that theme is applicable to this theme also. How successful has its implementation been? This objective is considered to have been met in the context of LDP2 policy and guidance, although, it could be extended to include the protection of prime agricultural land as a key asset for ensuring good quality soils for growing a wide range of crops. In line with NPF4, greater weight will be given in decision making, including the development of LDP3’s Spatial Strategy to tackling the climate and nature crises, including the identification of mitigation and adaptation measures to improve the resilience of our places to the effects of a changing climate. How successful has its implementation been? This objective is considered to have been met. Action as a result of the implementation of these policies has helped minimise the effects of climate change on the Perth and Kinross Area.
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80 A Connected Place 4.6.1 The Plan identifies 4 Key Objectives under this theme. These objectives and a summary of how successful their implementation has been to date, and where relevant, any lessons learnt, are set out below. 1. Identify and provide for new and improved social and physical infrastructure to support an expanding and changing population. The period of this Local Development Plan has seen changes to the size and composition of the population of the plan area. Two major trends that have been identified are that the population has grown, and the proportion of older people continues to increase. One of the main functions of a plan-led system is to consider the infrastructure needs of the plan’s policies and proposals and to plan for its provision as and when it is needed. Improvements to social and physical infrastructure identified in the plan have therefore been set out in two ways: Firstly, each of the Plan’s proposals sets out the scale of development expected on each site and specifies what developers have been required to do when designing and delivering development, emphasising improvements to infrastructure in a list of site-specific developer requirements. Secondly, where the cumulative impact of new developments will exacerbate or generate a future need for additional infrastructure provision or community facilities, contributions have been sought through two of the plan’s policies. Policy 5: Infrastructure Contributions sets out where contributions have been sought towards primary education, transport infrastructure, and offers scope to include other requirements on a case-by-case basis. Policy 20: Affordable Housing sets out the Council’s requirements for the provision of affordable housing. The Developer Contributions and Affordable Housing Supplementary Guidance was regularly reviewed to ensure that the plan’s Proposals were delivering against this objective. How successful has its implementation been? This objective is considered to have been met in the context of LDP2 policy and guidance, which provide protection for important landscapes, including nationally and locally designated areas. The expectations around landscape impacts from renewable energy developments have shifted through NPF4 Policy 11 with significant localised effects to be expected. Careful project design and mitigation will be key to minimising significant landscape impacts arising as a result of renewable energy developments. Supplementary Guidance to support LDP Policy 39 (Landscape) is an important guide in considering impacts from these types of developments and forestry related developments on local landscape areas.
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81 2. Establish clear priorities to ensure stakeholders and agencies work in partnership so that investment is co-ordinated, and best use is made of limited resources to enable the delivery of the strategy, supporting the aims and objectives of the Strategic Transport Projects Review, the Regional Transport Strategy, and the Tay Cities Deal. The Local Development Plan Delivery Programme monitors overall delivery of the Plan’s policies and proposals, and it includes a section identifying the strategic actions and infrastructure developments required to implement the Plan. The Delivery Programme includes a table of the strategic, national and regional actions required, along with a description of the lead partners and progress notes. Examples of projects that have progressed well include Shaping Perth’s Transport Future, and improvements to national and regional rail corridors and infrastructure. There has been mixed progress with A9 trunk road improvements. 3. Ensure investment in the renewal and enhancement of existing infrastructure is consistent with the strategy of the Plan to make best use of the investment embedded in our existing settlements. The Plan’s Strategy for this theme aimed to make Perth and Kinross one of the best-connected areas in Scotland. The Plan aimed to make the settlements across Perth and Kinross better connected to transport links, and to ensure that connections are made across a wider region. A framework of projects was identified in the Plan (Strategy Map 5) showing important existing infrastructure and planned infrastructure investment. Proposals for park and rides, trunk road improvements and new/improved railway stations were identified in the Plan. These were supported by Policy 60A: Existing Infrastructure and aligned with the Plan’s wider strategy. How successful has its implementation been? This objective is considered to have been met. The Local Development Plan proposals and policies (including associated Supplementary Guidance) ensure that appropriate consideration has been given to the provision of social and physical infrastructure necessary to support the level of development proposed in the Plan. The cumulative impact of development is also addressed. LDP3 will need to consider the NPF4 infrastructure first approach and regular reviews of the contributions guidance. How successful has its implementation been? This objective is considered to have been partially met. There has been progress with some, but not all of the projects and policies of strategic, national and regional importance listed in the Delivery Programme. These will be further considered in the preparation of LDP3.
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82 4. Provide a flexible policy framework to respond to changing economic circumstances and developing technology. The provision of digital infrastructure is vital to the economy, it supports local living, increases opportunities, and potentially it also reduces the need to travel. It is therefore important that the Plan is flexible enough to support efforts to deploy new technologies and remove redundant equipment. The LDP2 Policy 59: Digital Infrastructure required developers to make provision for digital infrastructure in all new-built developments. How successful has its implementation been? This objective is considered to have been partially met. There has been progress with some of the improvements to existing infrastructure including selected park and rides, but less progress with A9 junction improvements around Perth, and A9 dualling. Improvements to infrastructure have been made at Perth railway station. The LDP3 Spatial Strategy should consider how to work better with infrastructure providers, stakeholders and agencies to maintain investment in the renewal and enhancement of existing infrastructure. How successful has its implementation been? To the extent that LDP2 has had influence over changing economic circumstances and developing technologies, this objective is considered to have been met. The policy framework for developing technology has been suitably flexible, although it is acknowledged that proposals for the majority of digital communications infrastructure has not needed to be considered against the policy criteria. Over the Plan period, Building Standards overtook this policy in terms of the requirement to make provision for digital infrastructure in new developments. LDP3 will need to consider whether the remaining provisions of this policy will still be required moving forward, since NPF4 Policy 24 Digital infrastructure has updated the planning policy framework.
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83 Implementation of LDP2 Housing Land Allocations 4.7.1 An assessment of the performance of LDP2 housing allocations in meeting the identified housing land requirement for the Perth and Kinross Council (PKC) Area is set out in the 2022 Housing Land Audit and summarised below. 4.7.2 This assessment was not undertaken in the 2023 Audit as by then NPF4 had been published setting a new Minimum All- Tenure Housing Land Requirement. The Homes issue under Section 5 and Appendix D of this Report compares need against supply for the purposes of setting an indicative Local Housing Land Requirement in the Evidence Report. It should be noted that there is no longer a requirement to assess this at Housing Market Area level. Meeting the Housing Land Requirement (2022) 4.7.3 In 2022 the Council was required to identify a specified amount of land for housing in each of its housing market areas. Until 2022 this ‘housing land requirement’ (HLR) was set by the TAYplan2 Strategic Development Plan. The total housing land requirement for Perth and Kinross from the base date of 2016 to 2029 was 13,000 units. Table 1 in LDP2 set out the housing land requirement and supply position at Plan adoption stage and this was updated to reflect the position in 2022. This has been updated in Table 20 to follow. 4.7.4 In the three years prior to 2022 there were significant challenges because of Brexit, the global coronavirus pandemic, and a further economic downturn as the country entered a cost-of-living crisis. The question remained as to what the longer-term implications of these would be on the ability of developers to open new sites or continue with phases of larger sites. It was considered appropriate therefore, due to the high level of on-going uncertainty, to continue the cautious approach taken since the 2020 Audit and this meant that the programming for some sites was pushed back to later years. 4.7.5 As a result, there continued to be shortfalls in four of the six housing market areas, and an overall shortfall across Perth and Kinross. The housing land requirement set out in TAYplan2, however, was not an annual requirement but rather is one which was to be met over a longer timeframe which extended up to and beyond the current Plan period. Ultimately the issue was not one of land allocation but in the delivery of that land in the short-medium term.
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84 Maintaining and Effective Housing Land Supply (2022) 4.7.6 At 2022 the Council was required to, by the then Scottish Planning Policy, to maintain at least 5 years effective housing land supply (HLS). The effective HLS was that part of the total supply of land for housing which was free or expected to be free of development constraints and would therefore be available for the construction of housing in the next 5 years. 4.7.7 A table (see Table 21 to follow) considered the 5-year effective supply against the 5-year housing supply target for each of the housing market areas in Perth and Kinross at 2022. The calculation method reflected that in the annual Planning Performance Frameworks: = (5 𝑦𝑦𝑦𝑦𝑦𝑦𝑦𝑦 𝑦𝑦𝑒𝑒𝑒𝑒𝑦𝑦𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑦𝑦 ℎ𝑜𝑜𝑜𝑜𝑜𝑜𝑒𝑒𝑜𝑜𝑜𝑜 𝑙𝑙𝑦𝑦𝑜𝑜𝑙𝑙 𝑜𝑜𝑜𝑜𝑠𝑠𝑠𝑠𝑙𝑙𝑦𝑦 5 𝑦𝑦𝑦𝑦𝑦𝑦𝑦𝑦 ℎ𝑜𝑜𝑜𝑜𝑜𝑜𝑒𝑒𝑜𝑜𝑜𝑜 𝑜𝑜𝑜𝑜𝑠𝑠𝑠𝑠𝑙𝑙𝑦𝑦 𝑒𝑒𝑦𝑦𝑦𝑦𝑜𝑜𝑦𝑦𝑒𝑒 ) x 5 4.7.8 Shortfalls had emerged in maintaining a 5-year effective housing land supply in all housing market areas with the exception of the Kinross area. There was also an overall shortfall at Perth and Kinross level. 4.7.9 LDP2 Policy 24: ‘Maintaining an Effective Housing Land Supply’ set out the steps which would be taken in the event of shortfalls being identified. The first and foremost of these was that the Council would seek to work with landowners / developers to bring forward sites, including those identified as longer-term expansions. It was noted that, given the issue was not one of overall land supply but rather the short-medium term delivery of that supply, the Council would continue to seek to work with landowners and developers through the Delivery Strategy process under Policy 23: ‘Delivery of Development Sites’ to help to identify the scope for the programming of longer-term and stalled sites to be brought forward to help address the shortfalls.
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85 Table 20: Update to LDP2 Table 1: Housing Land Requirements (HLR) and Supply by Housing Market Area Housing Market Area Greater Dundee Strathmore and Glens Highland Perthshire Kinross Strathearn Greater Perth PKC total HLR 2016-2029 78 1,859 995 983 1,846 7,239 13,000 Completions to 2022 40 438 245 576 645 2,163 4,107 Effective supply 2022-2029 60 886 405 486 802 3,332 5,971 Windfall assumption 0 100 60 59 99 378 696 Small site allowance for Highlands 89 89 Surplus / shortfall 22 -435 -196 138 -300 -1,366 -2,137 Table 21: Perth and Kinross Effective 5 Year Supply Vs 5 Year Housing Supply Target (2022) Housing Market Area Greater Dundee Strathmore and Glens Highland Perthshire Kinross Strathearn Greater Perth PKC total 5-year effective supply 20 568 266 382 571 2,195 4,002 5-year supply target 25 605 360 355 600 2,285 4,230 Supply (in years) 4.0 4.7 3.7 5.4 4.8 4.8 4.7
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86 Implementation of LDP2 Employment Land Allocations 4.8.1 There is currently a generous 292.72 Hectares (Ha) of marketable land in the 2022 Employment Land Audit (ELA), which will not significantly change when we update our ELA (programmed for late Spring 2025). This generosity is suggested by the historically limited progress on the LDP2 employment use allocations and take up more generally for employment uses (Class 4 Office, Class 5 Industrial, and Class 6 Storage and Distribution). There is an eight-year average take up (development of Class 4, 5 and 6 uses) of 2.1 Ha per year. 4.8.2 This suggests there is a very healthy employment land supply in LDP2. However, take up may have been affected by limited serviced sites, and early review work for LDP3 suggests a potential minimum total of 100 Ha of effective employment land could be an appropriate minimum employment land requirement for LDP3. 4.8.3 Although the overall employment land supply is healthy, delivery is not without challenges with the share of employment sites owned by the Council being low. Where development viability is weak or marginal, even small constraints to development of land such as survey costs and risks, minor works, landscaping/ parking/ paths, or plot servicing can become absolute constraints to occupiers or developers making their investment. The Perth and Kinross Council Employment Land and Property Market Analysis (December 2022) identifies that the majority of allocated employment land supply is constrained and unlikely to be developed in the short-medium term without any public sector intervention. 4.8.4 Whilst most of the solution will not be within planning controls, there is a role for the LDP3. It may need to consider further opportunities for mixed uses allocations where appropriate and ensure there is appropriate cross funding between housing and employment uses. This approach would also support the local living and 20-minute neighbourhood policy. Also to ensure cross funded serviced sites are “oven ready” consideration should be given to defining serviced employment land in LDP3 so that there is a consistency in the quality of the cross funded employment land delivered. 4.8.5 There is LDP2 categorisation of two types of employment land, core and general which has a different policy approach associated to them both, providing greater flexibility on acceptable uses for the general employment land, and less flexibility for the core. If the LDP3 continues this approach, there will need to be a reassessment of their allocation as either core or general areas, in terms of existing function and character, and with consideration to vacancy rates.
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87 5 Evidence Gathering - Information on Issues APPROACH TAKEN TO THE COLLATION OF EVIDENCE 5.1.1 In preparing our Proposed Evidence Report, Perth and Kinross Council has taken a topic or issue-based approach, which for the most part follows the list of policy topics contained in Part 2: National Planning Policy, of National Planning Framework 4 (NPF4). 5.1.2 Where considered relevant, some of the NPF4 policy topics have been grouped together for evidence gathering and evaluation purposes, due to the overlapping or inter-connected nature of the subjects or topics, and to save duplication of effort in the collation of the data and information where there are the same requirements across similar or connection topics. 5.1.3 In advance of preparing our Proposed Evidence Report we produced a series of Topic Papers which set out the key information and evidence about the Plan Area and range of policy topics, which we propose to use to develop our new Local Development Plan 3. Our Topic Papers were then consulted on for a period of 6 weeks and we have used the feedback we have received through that consultation and engagement process to inform the individual issue templates under this section and in Appendices A-E of this report. A more detailed reflection on the format and outcomes of our participation and engagement programme to help inform the development of this Evidence Report has been provided under Section 3. 5.1.4 In presenting information on each of our 25 topic areas we have followed the suggested template at Figure 7, page 33 of the Scottish Government’s LDP Guidance. This is to ensure that the relevant requirements are covered in a consistent manner for each individual topic. 5.1.5 The issues for which a summary of evidence has been provided (and reported in detail under Appendices A-E), have, for ease of reference been grouped following NPF4’s 3 themes – Sustainable Places; Liveable Places, and Productive Places and an overview provided in the pages to follow. However, there are also separate Homes, and Infrastructure and Transportation groups due to the significance of these issues to the development of the Proposed Plan, and the breadth of information which they cover. These issues follow on directly from the Liveable Places theme group summaries and before the Productive Places group. 5.1.6 It is also worth noting that the Infrastructure and Transportation issue has many different elements, therefore this section has then been further divided under the subheadings of – Cemetery Provision; Communications and Digital; Education Facilities; Healthcare; Transport, and Water and Wastewater. 5.1.7 A summary of the overall gaps, uncertainties and key issues relating to the evidence, and a table of formal disputes to the Evidence Report have been provided in the tables to follow.
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88 5.1.8 As referred to in paragraph 5.1.5, after those tables, an overview of the summaries for each issue has been provided under the 5 relevant themes, which are then followed by a synopsis of the overall key issues for the Proposed Plan, any key policy connections across those issues, and likely implications for the development of our LDP3 Spatial Strategy.
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89 GAPS, UNCERTAINTIES, KEY ISSUES AND FORMAL DISPUTES
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90 TABLE OF GAPS, UNCERTAINTIES AND KEY ISSUES RAISED IN EVIDENCE Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence Sustainable Places Tackling the Climate and Nature Crises • Full suite of data sources unavailable for some of PKC Climate Change Strategy and Action Plan Key Performance Indicators. • Presumption taken that Perth and Kinross would follow Scottish trends between 1990 and 2005 for greenhouse gas or CO2 emissions to set 2030 emissions targets, due to the Scottish Government not having released the Perth and Kinross 1990 baseline for both. • Perth and Kinross Carbon Sequestration Study notes some uncertainty in defining peatland, its status and lack of robust data to allow monitoring of restoration sites, making estimated timescales for restoration inappropriate at present. • Perth and Kinross Carbon Sequestration Study, in terms of woodland expansion potential, the project report identifies significantly higher levels of carbon sequestration potential from the planting of Production Sitka Spruce, and lower from the expansion of Native Broadleaf (after 25 years). It is important to remember the national objective of expanding native woodlands, and policy of planting the right tree in the right place. As such, it is most likely that a mixed approach to planting will be the most appropriate one. This will be explored further in due course via the Council’s Forestry and Woodland Strategy review. • Currently no data available in relation to technological sinks and stores suggested for inclusion under the Scottish Government Local Development Plan Guidance, May 2023. • Data in Scotland Wetland Inventory has been developed by assimilating spatial data from Scottish Natural Heritage (now Nature Scot). The whole country has not been surveyed, and the data only displays known wetlands. Biodiversity and Natural Places (including Landscapes) • General experience of landscape is not covered by the data sources reviewed as part of this Evidence Report issue. NPF4 does not contain a policy on landscape, but our communities have a strong relationship with their surrounding landscapes, and there is potential for impacts on landscapes around local and regional significance as a result of development, including energy related proposals. The importance of continuing a local landscape policy along the lines of Policy 39 of LDP2 will need to be explored with communities during the Proposed Plan preparation. • Currently no policy covering Geological Conservation Review sites. • Many of the assessments for protected areas are out of date, not all protected areas are still of the quality of the last assessment, or the qualifying features may no longer be relevant, or valuable features may be present. • The Loch Leven source apportionment study is due to be refreshed in 2025. Data is likely to be available early 2026, but the final report may not be available to fully inform the LDP3 preparation stage.
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91 Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence • Protected species information and trends at a national level are not collated at a local authority level, furthermore there is no records centre for Perth and Kinross. • A review of the Tayside Biodiversity Partnership Local Biodiversity Action Plan (LBAP) will coincide with the development of the Proposed Plan. The Council will work closely with the partnership to ensure the Proposed Plan and Nature Networks are complementary to the ambitions of the LBAP review. • Local Biodiversity Sites programme will not be complete until mid-2025. Whilst sites will be adopted in time for the Proposed Plan consultation to allow the work to be incorporated, this may impact the early development of Nature Networks. • Networks are a new feature with tools only recently developed. Several potential opportunities and constraints are identified in the sources reviewed for this issue in Appendix A, but further engagement is ongoing to identify additional nature rich sites, restoration projects, local priorities and opportunities to ensure best value is delivered from the final nature network that is delivered as part of LDP3. This will involve partnership working between the Council and Perth and Kinross Countryside Trust, through their Perthshire Nature Connections Partnership, and is likely to run through 2025 for landscape scale Nature Networks, which will be developed alongside green infrastructure and green network identification. • A lack of biodiversity metric hinders the development of an approach to ensuring development complies with the mitigation hierarchy and provides the expected compensation and enhancement. Soils • Site surveys needed to support the detailed consideration of carbon rich soils, peatland, priority peatland habitats, and prime agricultural land. • No nationally consistent methodology for identifying land of lesser quality that is culturally or locally important for primary use. Forestry, Woodland and Trees • No single dataset provides a comprehensive overview of all trees and woodland of high biodiversity value within Perth and Kinross, and smaller scale woodlands, tree belts and hedgerows may be omitted from those datasets which in combination provide the best available information. • The National Forest Inventory (NFI) does not cover smaller areas of woodland, tree belts and hedgerows if they are less than 0.5 Ha, their canopy is under 20%, and they do not meet a minimum width of 20 metres. Where relevant, these assets should be picked up via other location specific studies, such as our Settlement Audit work, the assessment of individual site proposals, and work relating to the identification of habitat and nature networks. • The Ancient Woodland Inventory (AWI) is not definitive and should be used with care. Nature Scot advise that when evaluating woods it is important to - examine the site on the ground, looking for archaeological, biological and other
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92 Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence indicators of antiquity and of its current biodiversity value; examine old maps (woods not shown on the AWI, but present on the historic maps, are likely to be ancient and should be treated as such unless evidence is available to the contrary), and to seek specialist advice if in doubt. It is proposed that we will follow these additional steps in identifying ancient woodland within the Perth and Kinross Area as part of our LDP3 Spatial Strategy and the review of our Forest and Woodland Strategy. • The Ancient Tree Inventory (ATI) data is often supplied by members of the public but is verified by local recorders, as such although it is publicly available, it needs enhancement via citizen engagement. Engagement will be carried out as part of the development of our Proposed Plan and revised Forest and Woodland Strategy, and we will seek further information from the public and key stakeholders in respect of ancient trees identified on the ATI. • The Tree Preservation Orders identified in the Council’s Interactive Heritage Map require a review to ensure the records remain up-to-date and relevant. This will be prioritised as part of the development of our Proposed Plan. • Whilst for the most part still relevant, the Council’s Forestry and Woodland Strategy (FWS) will require a review to ensure that it is fully aligned with the National Strategy and meets the expectations and requirements of National Planning Framework 4. • As per the Tackling the Climate and Biodiversity Crises issue, the James Hutton Institute Carbon Sequestration Study for Perth and Kinross, in terms of woodland expansion potential, the project report identifies significantly higher levels of carbon sequestration potential from the planting of Production Sitka Spruce, and lower from the expansion of Native Broadleaf (after 25 years). It is important to remember the national objective of expanding native woodlands, and policy of planting the right tree in the right place. As such, it is most likely that a mixed approach to planting will be the most appropriate one. The project report also includes limited data on species resilience to the effects of a changing climate. It is proposed that we explore with Forestry Scotland and Forest Research the information they hold regarding species resilience to address this gap in the JHI Study. Historic Assets and Places • Historic Environment Scotland’s Historic Land Use Assessment is not available for the entire Perth and Kinross Council Area. However, it does provide a picture for the most populated areas. • At present, Conservation Area Appraisals (CAA) and guidance are available for 22 out of those 36 areas. However, this is currently a rolling review programme in place for reviewing our list of Conservation Areas which is expected to be completed during 2025-2026. • Due to the period which has lapsed since Perth and Kinross Design Charettes were produced, any data or statistics contained within them which has since been updated should be reviewed as part of the LDP3 Settlement Audit work.
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93 Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence The Audit should also consider if progress has been made against the key issues and actions identified in the charettes, and how those issues and actions compare to the feedback gathered through the Big Place Conversation. Green Belts • A further review of the green belt boundary taking account of new policy context and priorities set out in NPF4, and to align with timing of associated work around settlement audits, local living and 20-minute neighbourhoods, and the development of the LDP3 Spatial Strategy. Brownfield, Vacant and Derelict Land, and Empty Buildings • Not all brownfield land and vacant buildings will be included within the Scottish Vacant and Derelict Land Survey (SVDLS), only those which meet the criteria for inclusion in the national survey. The Proposed Plan will need to use the most up-to-date data available due to the emphasis in Policy 9 of NPF4 on encouraging, promoting and facilitating the reuse of brownfield, vacant and derelict land and empty buildings, and helping reduce the need for greenfield development. • Register of potential brownfield regeneration sites – pilot exercise only covers a specific area of Perth and Kinross. Expansion of this pilot across the Council Area will help identify the scale of the problem and any issues relating specifically to Perth and Kinross which may require a local policy response in LDP3, as well as highlighting potential sites for development. • A comparison of retail floorspace vacancy data is not available for smaller town centres of Aberfeldy, Alyth, Coupar Angus and Dunkeld. Coastal Development and Aquaculture • Unclear until planning application stage which areas are in an at-risk flood area. Mapping (currently based on 2009 climate projections) is to be updated and will be used in Proposed Plan site assessments if available but landowners / developers may be required to provide a Flood Risk Assessment in the interim to determine suitability for allocation. • Query regarding whether it is the intention of NPF4 to propose a more restrictive precautionary approach to development for coastal rural areas compared to otherwise similar inland rural areas? If not, the intention would be to consider the undeveloped coastline to be isolated/unspoiled coastline, and there would be no undeveloped coastline in Perth and Kinross. NPF4 does not define the undeveloped coastline. – unclear whether undeveloped means remote unspoiled coastline with wild land qualities, or if it is any area outwith a settlement boundary like the areas of significant constraint mentioned in Scottish Planning Policy 2014. If it is the former, there is no undeveloped coastline in Perth and Kinross. If the latter, then the Proposed Plan could identify the undeveloped coast accordingly. Energy, Heating and Cooling (including Infrastructure: Energy Supply Systems) • Formal Designation of Heat Network Zones – in line with the requirements of the Heat Networks (Scotland) Act 2021 – is still to take place. • Landscape Capacity for Wind - The Council’s Landscape Capacity Study for Wind was published in 2010 and therefore does not reflect the current planning policy framework for wind proposals. The expectations around landscape impacts
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94 Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence have shifted as per NPF4 Policy 11e(ii), whereby significant landscape impacts are to be expected at the localised level and/or provided appropriate design mitigation is included. There are no plans to update the landscape capacity study however the current draft Renewable Energy guidance is programmed to be updated in 2025 which will provide guidance to support implementation of NPF4 Policy 11, including in relation to project design and layout to mitigate landscape impacts. This will refer to NatureScot’s Landscape Sensitivity Guidance. • Pipeline Infrastructure - There are indicative plans for potential new pipeline infrastructure across Scotland including in the Perth and Kinross Area to support emerging plans around hydrogen production/transmission. Plans are at an early stage and will continue to be monitored and considered during the preparation of the Proposed Plan, where relevant. • UK Energy Governance - The development of UK energy governance arrangements will continue to be monitored and considered during the preparation of the Proposed Plan, where relevant. Zero Waste • The Perth and Kinross Waste Management Plan covers the period 2010-2025 but is likely to be updated. This is identified as an evidence gap in this issue. Liveable Places Design, Quality and Place • Perth and Kinross Placemaking Guide remains relevant but will require a review and some minor updates to ensure the references contained within it and the terminology used are in line with NPF4, to allow its future use alongside LDP3. • Perth and Kinross LDP2 Design Charettes were produced some time ago and as such the data and statistics within them has since been updated and should be reviewed as part of our LDP3 Settlement Audit work. The Audit should also consider if progress has been made against the key issues and actions identified in the Charettes, and how those issues and actions compare to the feedback gathered through the Big Place Conversation. • Our Local Action Plans contain important profiles of the localities of Perth and Kinross, but as they were all published in 2017 the statistical data reported within them are not the most recent available data. The list of ‘key Issues Identified’ and ‘What needs to change’ accompanying statements contained within the LAPs will be reviewed as part of our LDP3 Settlement Audit exercise but will be viewed taking account of relevant up-to-date data and information. • The Council Ward Profiles also contain some data and information which is now out of date. As part of the Settlement Audit exercise for developing the Proposed Plan, they should be viewed in the light of the most up-to-date information available for the key characteristics and challenges for those places. Local Living and 20 Minute Neighbourhoods • Age of Infrastructure Capacity Studies, Design Charette reports and Ward Profiles. LDP2 Infrastructure Capacity Studies were only carried out for the larger settlements. Data to be updated through the Settlement Audit work for LDP3 which will consider all settlements.
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95 Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence • Much of Perth and Kinross is rural but SIMD data zones in rural areas tend to cover a large land area and so is less helpful at identifying the smaller pockets of deprivation in these areas. • As part of the Settlement Audit work for LDP3, a Localities Profile template will be developed to set out those factors which officers will need to take account of in developing their understanding of each place and to satisfy the requirements of the Act, Regulations, Guidance and NPF4. • The indicators of access to public transport networks and high frequency services in the Scottish Living Locally Data Portal would benefit from more recent data. The SLLDP also offers limited information for rural areas. • Not all information regarding the facilities and services on offer within communities is currently mapped in GIS. • No timeframe for the carrying out of a future review of the provision of public conveniences. Blue and Green Infrastructure • Completion of the Open Space Quality Audit not expected until summer 2025 with the Open Space Strategy to follow at the end of the year. • Green and Blue Infrastructure was mapped for the LDP Supplementary Guidance but with the removal of statutory status for such documents, mapping will need to be included in LDP3 in some form. • Both the Green Infrastructure mapping and Open Space Audit will address accessibility and connectivity. This will be supplemented by consideration of nature networks to develop green networks. An initial consultation on priorities for nature networks took place alongside the consultation on topic papers. • Offsite delivery of enhancement for biodiversity through development is limited by current law around planning conditions and may be difficult to secure until new legal mechanisms are in place. Play, Recreation and Sport (including Play Sufficiency Assessment) • The provision of opportunities for play, recreation and sport is an evolving process and close collaboration with partners will be required to ensure LDP3 incorporates the most accurate information and provides an appropriate spatial strategy and policy framework to promote opportunities. • SportScotland Facilities Report is dependent on key stakeholder feedback and their Facilities Planning Model is based on modelling and not actual usage. Local data is therefore used to determine existing and modelled usage. • The Play Sufficiency Assessment does not include privately managed equipped play areas. These will be identified, assessed, and included in the outputs to help address the gaps in provision and accessibility. The current playground strategy only considers the 4-14 age range which has resulted in a data gap regarding the provision of activities for children and young people outwith this range. The Play Sufficiency Assessment only includes equipped playgrounds, but younger / older youngsters may need / seek other forms of play.
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96 Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence • The Playground Strategy excludes settlements of less than 50 houses as the density is too low to justify provision. This is being reviewed as part of this PSA and forthcoming Playground Strategy Update. Flood Risk and Water Management (including Drainage and Water Supply Systems) • Unclear until planning application stage which areas are in an at-risk flood area. Mapping (currently based on 2009 climate projections) is to be updated and will be used in Proposed Plan site assessments if available but landowners / developers may be required to provide a Flood Risk Assessment in the interim to determine suitability for allocation. • The Strategic Flood Risk Assessment helps identify some potential opportunities for improvements to the water environment through natural flood management and blue-green infrastructure and this will be built upon in the Proposed Plan spatial strategy. • The drought indicator method has not been developed to assess individual Private Water Supplies and is not provided at a finely grained resolution. Together with other water scarcity mapping it could help start determining vulnerable areas. Health and Safety • Safeguarding Zones around major hazard sites, major accident pipelines, and airfields will need to be checked to ensure they remain appropriate. • Locations of concern for suicide risk will need to be sensitively taken into consideration when preparing the Proposed Plan. • Once published, the measures contained in the Perth Air Quality Management Plan will need to be incorporated into the Proposed Plan. Homes Homes To inform the final Local Housing Land Requirement in the Proposed Plan: • More analysis is needed on the impact of residential properties as holiday accommodation. This will come from data on the higher Council Tax levy on second homes and the impact of the short-term let licencing requirements. • An updated needs assessment will need to be carried out on the accommodation needs of Gypsy/Travellers and Travelling Show people. • Enhanced consideration will be given to factors affecting the deliverability of the housing land supply through updated housing land audits.
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97 Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence Infrastructure and Transportation Cemetery Provision • Finding suitable land for potential burial ground/cemetery provision will potentially compete with other demands on land. There may be an opportunity to delivery cemetery provision alongside other appropriate land uses and demand for this will need to inform the spatial strategy. Communications and Digital • None identified Education Facilities • School roll capacity data needed to accommodate new development proposals for LDP3 will be assessed by the Council’s Property and Education and Children’s Services by reviewing individual primary catchment areas and secondary clusters. • The methodology for calculating the ‘Pupil Product Ratio’ was developed in 2008 and will require updating. • The Council has an ongoing priority to improve ASN provision in schools across the local authority area and is considering funding options to deliver capacity. Health Care Facilities • The Council relies upon evidence from NHS Tayside and the Perth and Kinross Health and Social Care Partnership to demonstrate infrastructure needs in the area. Aspects of this evidence is not available publicly at present. Transportation (Including Sustainable Transport) • Some of the datasets used are aged and would benefit from more up to date information. • There are data items that have yet to be obtained or are not available. The Council will work to identify, update and address those gaps during the preparation of the Transport Appraisal. The Transport Appraisal work will include the necessary measures to address gaps related to the quality, frequency and accessibility of public transport services. • PKC’s commitment and financial contribution to the development of transport infrastructure generally requires the use of external funding. Consequently, there is a degree of uncertainty regarding the availability of sufficient financial support at national and regional levels. This may impact the delivery of projects that, under the Infrastructure First principle, could threaten the viability of development. • Key transport routes serving settlements within Perth and Kinross are also linked to areas in the neighbouring local authorities. The performance of the network, and the ability to deliver improvements to the regional infrastructure, will often depend on the ability for PKC to work in coordination with other organisations. • There is significant uncertainty surrounding the wider transport industry with regards to the evolution of working and commuting patterns. Variations to these arrangements can create significant changes to travel behaviour, shaping demand on specific modes.
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98 Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence Water and Wastewater • Settlement audits will consider if the relevant Scottish water/wastewater asset is near capacity, and if it is in a current investment programme. Information on Scottish Water assets will allow the Council to consider if development should be planned in locations where there is existing or programmed capacity in the water and wastewater systems. However, the Proposed Plan spatial strategy will also be fully informed by the Strategic Environmental Assessment work, and the 20-minute neighbourhood and local living analysis and the settlement audit work, to ensure development is focussed on the most sustainable locations • During the LDP preparation process, we will continue to engage with Scottish Water to inform them of likely areas of development. Scottish Water has reiterated their commitment to not restrict development. With due communication and agreement on delivery timeline and phasing, future residential developments can be presumed to receive access to public water and wastewater services. For industrial uses, Perth and Kinross Council will engage with Scottish Water directly to identify potential stress points in the available capacity, and the need to deliver suitable infrastructure Productive Places Community Wealth Building • The Proposed Plan will need to take account of any updates that may be made to the Perth and Kinross Community Plan (Local Outcomes Improvement Plan) and the Locality Action Plans. These will need to be embedded into the Proposed Plan. • It will also need to consider the contents of any registered Local Place Plans, and whether they have implications for community wealth building in the area because there is a link between community asset transfer opportunities and Local Place Plans. Business and Industry • Potential Proposed Plan employment land requirement is indicative and may change upon completion of the 2024 Employment Land Audit. • To help address identified viability and deliverability issues in the allocated land supply, LDP3 will need to consider further opportunities for mixed uses allocations where appropriate and ensure there is appropriate cross funding between housing and employment uses. • To ensure cross funded serviced sites are oven ready consideration should be given to defining serviced employment land in the LDP so that there is a consistency in the quality of the cross funded employment land delivered. • The SVDLS and Urban Capacity Study, when completed, will provide an effective review of capacity and potential development sites.
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99 Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence • Significant limitations to using SIMD data to inform the employment land strategy as rural deprivation is dispersed. To identify where future business and industry may provide the most benefit there is a current gap in evidence in terms of the settlement audit work. • Perth and Kinross Council Employment land matrices utilise a ‘balanced scorecard’ approach to determine the sites most likely to require Council intervention and their relative attributes. When preparing these assessments, there was not always enough consideration of active travel links, an area of increased emphasis in national policy. Also, since they were prepared, there is an increased emphasis on generating economic prosperity for all people and places. Future updates should consider these aspects carefully. • A transport appraisal will be carried out considering the cumulative impact of potential new development to inform the Proposed Plan. Retail, City, Town, and Commercial Centres • The retail forecasts of the Perth and Kinross City and Town Centre Retail study highlight there is no requirement to plan for major new retail development, but there will be a need to consider neighbourhood scale retail. Whilst there is a need to move on from retail led centres, sufficient protection should be afforded to footfall generating activities and allow for proper scrutiny of change of use proposals from town centre use(s) to ground floor residential. • The LDP will need to identify town, neighbourhood and commercial centres, and consider if Perth City Centre extents should be redefined. • Carrying out a future urban capacity and brownfield study will help identify the scale of the opportunities for town centre living and any issues which require a response in the Proposed Plan. • The settlement hierarchy in the existing LDP is largely appropriate however the Retail study 2023 does provide some guidance on what will require review in the Proposed Plan. • The Retail study provides recommended definitions to help with the interpretation of NPF4 Policy 28 Retail with reference to edge of centre sites, to small scale neighbourhood retail, and to the floorspace threshold at which an impact assessment will be required. • it is important that the growth of the Eating Out of Home sector supports existing centres which are losing some of their retail function. There is also scope to consider drive through applications on retail allocations without necessarily requiring specific allocations for drive throughs. • The clustering of non-retail uses is not an obvious issue within Perth and Kinross. Rural Development • No Local Place Plans have yet been registered so there is a potential issue in aligning the timescales for the preparation of these and the Proposed Plan.
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100 Evidence Report Issue Gaps, Uncertainties and any Key Issues raised in Evidence Tourism • A lack of up-to-date strategies and some data, particularly on recent levels of usage to inform decisions relating to visitor management. • Some data is currently only available at national level. • Difficult to understand the scale of the problems in relation to active and sustainable transport and the implications for both visitors and workers without first understanding baseline data in relation to traffic levels, wider connectivity, and origins / destinations of travel to work areas. Culture and Creativity • Statistics for turnover, employment numbers and registered businesses dates from 2021-23. More recent data is not yet available. • Age of some data on community views of their local assets, their aspirations, areas for improvement, and a vision for the future of their place e.g. Infrastructure Capacity Studies, Design Charettes, and Community Action Plans. Any updates to data within these will be reviewed as part of the LDP3 Settlement Audit work. • Difficult to know how up to date the information contained on the Your Community PK website is regarding local groups and services. • The Localities Profile template to be developed as part of the Settlement Audit work for LDP3 should allow for an up- to-date GIS based audit of existing cultural offering in a place and highlight where there is a known demand for additional or improved opportunities and facilities. Minerals • There is a need for improved data on both demand and also product flows. In the absence of data on predicted demand for minerals, a 10-year landbank cannot be accurately calculated. More engagement with the minerals industry, including industry bodies and active operators may allow us to state with more confidence whether a 10-year landbank exists. • The evidence suggests that in the Tay area, there is likely to be sufficient permitted reserves for crushed rock but that there may not be sufficient reserves of sand and gravel to meet the demand for a 10-year landbank, as required by NPF4.
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101 TABLE OF FORMAL DISPUTES TO THE EVIDENCE REPORT Evidence Report Issue Appendix Respondent Issue Disputed Sustainable Places Tackling the Climate and Nature Crises A1 Holder Planning on behalf of SSE Renewables Omission of the Onshore Wind: Policy Statement 2022. Biodiversity and Natural Places (including Landscapes) A2 Homes for Scotland Disagree with the implications for the proposed plan. Private individual • The lack of consideration to local biodiversity • The negative impact of development Soils A3 Savills on behalf of Scone Estate There should be recognition that the designation of prime agricultural land on the National Scale Land Capability for Agriculture map and the Land Capability for Agriculture (partial cover) map provides information which is ultimately broad in scope and cannot be relied upon at the local level without further specific inspections of the specific sites concerned. Forestry, Woodland and Trees A4 Private Individual The Topic Paper 007 “fails to represent the actual activities of PKC in the arena.” Historic Assets and Places A5 Private individual Concerned about whether specific heritage assets have been identified in the Topic Paper. Green Belts A6 Private Individual PKC have consistently ignored the green belt around Scone making any commitment meaningless. Homes for Scotland A green belt review must be carried out. Savills on behalf of Scone Estate PKC should take a root and branch approach to the review of the green belt and consider whether it remains relevant. Not provided Craigend requires to be properly considered on the ground and compared against the other similar settlements around Perth which have been omitted from the green belt. Brownfield, Vacant and Derelict Land, and Empty Buildings A7 Not provided Dispute the accuracy of the total brownfield / derelict area across the PKC area out with urban areas, the extent of brownfield / derelict land at Errol Airfield, and the omission of any reference to Errol Airfield. Energy, Heating and Cooling (including Infrastructure: Energy Supply Systems) A9 Holder Planning on behalf of SSE Renewables • Omission of onshore wind: policy statement 2022 from legal and National Policy Requirements and Expectations section and from Section 2.
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102 Evidence Report Issue Appendix Respondent Issue Disputed • Disagrees with the use of the Landscape Capacity Study (2010) for assessing proposals against the new LDP, as well as the potential for a spatial strategy for renewable development being included within the new LDP. Liveable Places Design, Quality and Place B1 Homes for Scotland PKC should include the additional data listed in their response, and analyse how this will influence the design, quality and place that will be created by future development. Private Individual Topic Paper 018 fails to address any of the recent historical activity and objection of the local community. Local Living and 20 Minute Neighbourhoods B2 Errol Community Council Do not consider that it is appropriate for Errol Community Council area and the Carse of Gowrie as a whole to be part of Eastern Perthshire and consider that we would be better aligned with Bridge of Earn. We do not consider that the evidence is up to date or particularly relevant. Private individual 20-minute travel fails to address community, social and family friends and family activity, and the mental wellbeing in regularly connecting with these activities. Play, Recreation and Sport (including Play Sufficiency Assessment) B4 SportScotland Disagree with the sufficiency of the list of evidence/datasets identified in Topic Paper 022. Flood Risk and Water Management (including Drainage and Water Supply Systems) B5 Private individual The Craigie Burn Flood Study must be redone using flow rate figures agreed with residents who have knowledge in this field. Private individual The topic paper does not mention 'deforestation' for development impacting both surface water and subterranean water flows, nor address the impact of proposed and existing development on subterranean aqua flows especially in the Scone area. Homes Homes C1 Private Individual Using data from a self-interested source – Homes for Scotland – distorts the report. Homes for Scotland The MATHLR is to be exceeded Note: The iLHLR set out in the Evidence Report exceeds the MATHLR so on strict interpretation, the dispute is resolved. It is acknowledged, however, that taking a broader view of Homes for Scotland’s concerns it is likely that they will be of the
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103 Evidence Report Issue Appendix Respondent Issue Disputed view that the iLHLR should be higher still than that proposed in the Evidence Report. Savills on behalf of Scone Estate • Data to be used to reflect Self and custom build demand/need • A lack of acknowledgement of the facilitatory role of housing in meeting other spatial strategy aims • The need for a balanced approach to use of NPF4 policies to ensure appropriate and increased delivery of rural housing. Infrastructure and Transportation Health Care Facilities D4 Private individual Poor quality of graphics online Productive Places Business and Industry E2 Savills on behalf of Scone Estates Want to see the Council's explicit recognition that investment in the Cross Tay Link Road (CTLR) is intended to unlock significant additional investment and the Evidence Report and LDP3 must reflect this by freeing up development opportunities in conjunction with the opening of the new road infrastructure. The restrictions created by the existing green belt designation should be addressed, this should go further than simply making the CTLR the green belt northern boundary. Retail, City, Town, and Commercial Centres E3 Lichfields on behalf of McDonalds The evidence listed within Perth and Kinross’ Topic Paper is not considered sufficient to accurately create new policy wording in the future LDP regarding drive-thru developments. Montague Evans on behalf of Loch Developments Ltd Seeks the allocation of the former BCA for mixed uses, retail, drive through and residential. Avison Young on behalf of Aldi Stores Ltd It is considered that less capacity has been identified than available and inaccurate conclusions reached about deficiencies across Perth. Aldi stores also disagree with the implications for the Proposed Plan. Rural Development E4 Savills on behalf of Scone Estate The assessment of Self and Custom Build demand/need should use broader data sources and not just rely on historic planning consents. Note: Same dispute raised under Appendix C1: Homes. Savills on behalf of Scone Estate The Council must consider data sources regarding population to support growth in rural settlements and housing clusters to revitalise rural areas with supportive planning policies and generous housing allocations.
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104 Evidence Report Issue Appendix Respondent Issue Disputed Andrew McCafferty Associates • More fine-grained analysis of up-to-date completions and land supply data is required for the rural areas • There is a need for a continued supply of new allocations in rural areas and a review of historic allocations which have not been delivered. • A more fine-grained analysis of the HLA 2023 should be undertaken to establish trends in housing completions in the rural areas Tourism E5 Savills on behalf of Scone Estate • The significance of the tourism sector to PKC must be understood and reflected in planning policy. • Significant care will be needed in designating tourism areas of growth potential or restraint without stifling opportunities which arise but cannot be readily planned for. Culture and Creativity E6 Private Individual Disagrees with evidence and datasets provided in Topic Paper 030: Culture and Creativity and the summary of implications because of the employment data being misrepresented. Savills on behalf of Scone Estate There is a lack of data included in Topic Paper 030: Culture and Creativity on the contribution of estates and significant historic and cultural locations.
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105 SUSTAINABLE PLACES
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106 SUSTAINABLE PLACES 5.2.1 The issues covered under the NPF4 theme Sustainable Places are: • Tackling the Climate and Nature Crises (including Climate Mitigation and Adaptation) • Biodiversity and Natural Places (Including Landscapes) • Soils • Forestry, Woodland and Trees • Historic Assets and Places • Green Belts • Brownfield, Vacant and Derelict Land and Empty Buildings • Coastal Development and Aquaculture • Energy, Heating and Cooling • Zero Waste 5.2.2 A full summary of the review of evidence undertaken for all issues under this NPF4 theme, including all relevant links to that evidence, and a summary of stakeholder engagement, has been provided under Appendix A to this report. To save duplication in the re-reporting of that information, the pages to follow concentrate instead on providing an overview of the identified likely implications of this evidence for the preparation of the Proposed Plan, any gaps, uncertainties or key issues in the evidence gathered, and a summary of agreements, and/or disputes related to the evidence which were received through our programme of participation and engagement reported under Section 3.
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107 ISSUE: TACKLING THE CLIMATE AND NATURE CRISES Links to Evidence: LDP SPATIAL STRATEGIES Part 1 of National Planning Framework 4 contains six Spatial Principles Perth and Kinross Local Development Plan 2 (2019) GHG EMISSIONS AND LIFECYCLE ASSESSMENTS National Planning Framework 4 – lifecycle greenhouse gas emissions: assessment findings ESPON – Quantitative Greenhouse Gas Assessment tool for Spatial Planning Department of Business, Energy, and Industrial Strategy (DESNZ) Data 2022 The Scottish Government, Climate Change (Emissions Reduction Targets) (Scotland) Act 2024 ADAPTATION AND MITIGATION, AND ACHIEVING NET ZERO AND A JUST TRANSITION A Changing Climate – Scotland and Perth and Kinross Adaptation Scotland website ARUP, Perth and Kinross Climate Risk and Opportunity Assessment Technical Report, August 2023 and Perth and Kinross Climate Change Risk and Opportunity Assessment Executive Summary, June 2023 Intergovernmental Panel on Climate Change (IPCC) PKC Climate Change Projection Maps Our Changing Nature The State of Nature Partnership, State of Nature Report 2023 Tackling the Climate and Nature Crises Scottish Government, Scottish National Adaptation Plan 2024 - 2029 The Scottish Government, Update to the Climate Change Plan 2018 – 2032: Securing a Green Recovery on a Path to Net Zero The Scottish Government, Scottish Biodiversity Strategy to 2045 – Tackling the Nature Emergency in Scotland The Scottish Government, Scottish Biodiversity Strategy Post-2020: A Statement of Intent, December 2020 Nature Scot, Climate Change and Nature Information Sheet Perth and Kinross Council, Climate Change Strategy and Action Plan, December 2021 Perth and Kinross Council Climate Action website Perth and Kinross Council, Climate Change Year 3 Annual Report, October 2023 - September 2024 Perth and Kinross Council, Consultation Draft Mobility Strategy Tactran, Regional Transport Strategy 2024-2034 James Hutton Institute (JHI), Carbon Sequestration Study of Perth and Kinross Council Area, December 2021 [Core Doc Ref: CD1] UK Climate Change Committee(UKCCC), Progress in reducing emissions in Scotland – 2023 Report to Parliament (March 2024) Vulnerability to Climate Change Risks within Perth and Kinross Scottish Index of Multiple Deprivation (2020) SEPA National Flood Risk Assessment (NFRA) Tay District Local Flood Risk Management Plan Forth District Local Flood Risk Management Plan Forth Estuary Local Flood Risk Management Plan Tay Estuary and Montrose Basin Local Flood Risk Management Plan SEPA, Scotland Wetland Inventory Perth and Kinross Council, Air Quality Webpages Scottish Household Survey (SHS) Environment Statistics 2022
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108 Scottish Household Survey (SHS) Environment Statistics 2023 Taylor McKenzie Research and Marketing Ltd., Tactran Quantitative Research, October 2023 Climate Just, Neighbourhood Flood Vulnerability Index Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • PKC Climate Change Strategy and Action Plan - There is currently not a full suite of data sources available to allow the comprehensive monitoring of some of the Key Performance Indicators identified for the different thematic areas of the Action Plan. This is due a lack of suitable data availability or up to date information not yet being available relating to some of the actions under the Business and Industry (tourism businesses and Green Certification Scheme, and % of businesses with 250+ employees or largest energy demand with carbon emissions reduction targets), Land Use (lack of or limited data on area of peatland restored, and % of local and major planning consents which contain approvals for biodiversity net gain), and Resilience (up to date RAG (Red, Amber, Green) status of flood risk management actions) themes. As the Scottish Government has not yet released the Perth and Kinross 1990 baseline for either the full suite of GHG emissions or CO2 emissions, a Perth and Kinross target figure for 2030 was estimated for these two indicators for the purposes of the Perth and Kinross Council Year 2 Climate Change Annual Report. The estimate was based on the presumption that Perth and Kinross would follow the Scottish trends between 1990 and 2005 when data first became available. • JHI, Carbon Sequestration Study of Perth and Kinross Council Area, December 2021 - Sequestration Study project report notes some uncertainty in the data defining peatland, its status, and lack of robust data on monitoring of peatland restoration sites make estimates of timescales for the restoration of these sites inappropriate at present. In terms of woodland expansion potential, the project report identifies significantly higher levels of carbon sequestration potential from the planting of Production Sitka Spruce, and lower from the expansion of Native Broadleaf (after 25 years). It is important to remember the national objective of expanding native woodlands, and policy of planting the right tree in the right place. As such, it is most likely that a mixed approach to planting will be the most appropriate one in reality. This will be explored further in due course via the Council’s Forestry and Woodland Strategy review. • Scottish Government, Local Development Plan Guidance, May 2023 - The Council currently has no data available in relation to technological sinks and stores as suggested for inclusion under the guidance.
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109 • Scotland Wetland Inventory - The Scottish Government’s Spatial Data website notes, with respect to the Scotland Wetland Inventory that the “data set has been developed by assimilating spatial data from Scottish Natural Heritage. The whole country has not yet been surveyed and as a result the data set only displays known wetlands. The wetland inventory database comprises a number of fields that include the main WFD95 wetland type, the original habitat survey information and whether the wetland polygon is within a statutory designated site. The wetland typology (WFD95) is used as the main identifying field for each polygon in the inventory database. …It is important to note that if there are no wetlands identified on the inventory this does not mean that there are no wetlands in that area. The inventory has been completed using available digital data for wetlands that have been surveyed. It is very likely that there are wetlands in Scotland that have not been surveyed or where the survey data is currently not available in a digital format suitable for GIS.” In the development of our LDP3 Spatial Strategy, and the spatial frameworks for other associated strategies and work areas e.g. the Forest and Woodland Strategy, Nature Networks, natural flood risk management, peatland restoration etc., it will therefore be important to engage with our key agencies (SEPA and Nature Scot) and other relevant stakeholders to identify, where possible, wetland areas which have not yet been surveyed or for which survey data is not available digitally. Statements of Agreement and/or Dispute: 18 responses were received on our Tackling the Climate and Nature Crises Topic Paper. Most respondents (14 out of 18) either agreed with or had no comment to make on the evidence identified through Topic Paper 004, and the summary of the implications of that evidence for the Proposed Plan provided by the Council, or they offered examples of additional sources of information which they felt should be considered. There was 1 response on the issue which the respondent wished to be treated as a formal dispute to the Evidence Report. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Tackling the Climate and Nature Crises issue in Appendix A. • Key Stakeholders: o Nature Scot, neither agreed nor disagreed o SEPA, agreed o Historic Environment Scotland, agreed o Tactran, neither agreed nor disagreed o Scottish Water, agreed • Community Councils: 2 responses, 1 agreed, and the other neither agreed nor disagreed. • Public At Large: 5 responses, 2 of which agreed, 2 neither agreed nor disagreed, the other disagreed but does not wish to register as a formal dispute.
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110 • Landowners and Agents: 5 responses, 3 of which neither agreed nor disagreed, 1 disputed the evidence but did not wish for their comments to be recorded as a formal dispute (Savills on behalf of Dupplin Estate), and 1 (Holder Planning on behalf of SSE Renewables) disputed the evidence and wish for their comments to be registered as a formal dispute due to the omission of the Onshore Wind: Policy Statement 2022. • Other Bodies: o Homes for Scotland, disagreed but does not wish to register as a formal dispute. o SSEN Transmission, agreed
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111 ISSUE: BIODIVERSITY AND NATURAL PLACES (INCLUDING LANDSCAPES) Links to Evidence: Perth and Kinross Council Corporate Plan 2022-2027 Big Place Conversation Feedback Landscape Local Landscape Areas SiteLink: National Parks SiteLink: Special Qualities of the National Scenic Areas NatureScot (2014) Wild Land Areas Map and Descriptions; NatureScot (2023) Assessing impacts on Wild Land Areas – technical guidance Naturescot (2019) Landscape Character Types Historic Environment Scotland: Gardens and Designed Landscapes Inventory Geodiversity SiteLink: GCRs, SSSIs (geodiversity and mixed) Proposed Local Geodiversity Sites Scottish Geology Trust GeoSites Project Biodiversity, Protected Areas and Species: Tayside Biodiversity Partnership (2016) Local Biodiversity Action Plan SiteLink: International and National Protected Sites Candidate Local Biodiversity Sites Scottish Government (2013) Scottish Biodiversity List NBN Atlas UK Centre for Ecology and Hydrology (2022,2023) Lochs and Climate Change Research NatureScot (2017) Loch Leven Nutrient Load and Source Apportionment Study PKC Natural Flood Management Studies [link to core docs] SEPA Water Classification Hub Nature Networks, Compensation and Enhancement: Scottish Government (2024) Scottish Biodiversity Strategy to 2045: tackling the nature emergency Strategic Biodiversity Framework Delivery Plan 2024-2030 State of Nature Partnership (2023) State of Nature Scotland Report NatureScot (2023) Nature Networks Framework Nature Scot (2024) Practitioner’s Guide to Nature Networks PKC (2024) Engagement Results PKC (2020) Forest and Woodland Strategy PKC (2022) Planning for Nature PKC (2024) National Planning Framework 4: Policy 3 Biodiversity and Development: A Guidance Note NatureScot Nature Networks Toolbox AECOM Strategic Corridors Maps AECOM Wildlife Connectivity and Opportunity Maps AECOM Eco-uplift Nature Recovery Portal NatureScot (2022) Habitat and LandCover Map of Scotland Eunis 2 Existing Nature Rich Sites and networks o Protected sites o Candidate Local Biodiversity Sites o SEPA Wetlands Inventory o Plantlife Important Plant Areas
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112 o RSPB Important Bird Areas o Ancient Woodland Inventory o Native Woodland Survey of Scotland o Forest Research (20232) GB National Forest Inventory o Buglife B Lines o SNH (1996) An Inventory of Lowland Raised Bogs in Britain o SNH (2016) Carbon and Peatland Map o Butterfly Conservation Priority Butterfly Records (in house data) Existing Restoration Projects o Riverwoods Projects o Nature Restoration Funded Projects o Northwoods Rewilding Network o Peatland Action projects o Biodiversity Villages o Wildlife Accredited Estates o Scottish Forestry Native Woodland grants o SEPA Water Environment Framework Projects. o NatureScot(2023) Mountain Woodland Restoration Sites Opportunities, Degraded Land and Constraints o Loch Leven LENS o Natural Flood Management Studies [CORE DOCS] Aberfeldy Blackford Comrie Invergowrie South Kinross o PKC (2024) Strategic Flood Management Assessment o SEPA Riparian Vegetation Planting Opportunities o SEPA Recommended Riparian Corridor o SEPA Geomorphic Risk Buffer o SEPA River Recovery Potential o SEPA Obstacles to Fish Migration o SEPA Flood Hazard Maps o SEPA (2021) River Basin Management Plan for Scotland o SEPA Water Classification Hub Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Landscape and Geodiversity - General experience of landscape such as those addressed in Policy 39 are not covered by the data sources given above. NPF4 does not contain a landscape policy, and it receives limited consideration in the Six Qualities of Successful Places. Perth and Kinross communities have a strong relationship with their surrounding landscape regardless of official designations. The importance of continuing a localised landscape policy along the lines of Policy 39 will need to be explored with communities during Proposed Plan preparation. The Place Standard Tool used during the Big Place Conversation primarily asks about access to nature and although comments were received on the value of the surrounding
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113 nature to residents, the experience of specific landscapes within and outwith settlements received less information. Further engagement on specific landscape importance to settlements will take place as part of engagement in preparation of the Proposed Plan. NPF4 Policy 11 Energy, together with Policy 1, gives significant weight to the priority of delivering renewable energy including where local landscape designations are identified. Landscapes in the Perth and Kinross area are of significant value locally and regionally. There will need to be consideration given to how effective local landscape areas are, and whether landscapes need greater protection through continuation of a separate landscape policy in LDP3. There is currently no policy which covers Geological Conservation Review (GCR) sites in NPF4 or LDP2. GCRs that are not already SSSIs, or parts excluded from designation have been reviewed as part of the Local Geodiversity Sites programme. In some instances, the entirety of the GCR (or remainder) has not met Local Geodiversity Site standard. Whether remaining GCR should be protected through policy because of its original designation will be addressed in preparation of the Proposed Plan. The Local Geodiversity Sites programme will not be complete until mid-2025. Sites will be adopted in time for the proposed Plan consultation and to be incorporated into associated work. • Protected Areas and Species - The status of protected areas is subject to the capacity of Nature Scot to complete assessments. Currently, many of these assessments are out of date, as a result not all protected areas are still of the quality of the last assessment, or the qualifying features may no longer be relevant or other valuable features may be present. Three existing protected areas have specific policies and guidance. Whether the policy regarding these areas needs to be reviewed or additional areas also addressed will depend on an analysis of whether the current summary condition assessment of these sites is reliable. The Loch Leven source apportionment study is due to be refreshed in 2025. While data is likely to be available in early 2026, the final report may not be available to fully inform the LDP3 preparation stage. As the latest assessment of the eutrophic loch feature remains “vulnerable recovering” a precautionary approach will be taken if timelines do not coincide. Protected species information and trends at a national level are not collated at Council level. Perth and Kinross are also disadvantaged by not having a records centre, although part of Kinross-shire is covered by Fife Nature as part of the Fife and Kinross vice county. The Tayside Biodiversity Partnership Local Biodiversity Action Plan (LBAP) runs until 2026. A review of the LBAP will coincide with preparation of the Proposed Plan. We will work closely with the partnership to ensure the Proposed Plan and Nature Networks are complementary to the ambitions of the forthcoming LBAP. The Local Biodiversity Sites programme will not be complete until mid-2025. Sites will be adopted in time for the Proposed Plan
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114 consultation and to be incorporated into associated work. However, this may impact the early development of Nature Networks. • Nature Networks, Compensation and Enhancement - Nature Networks are a new feature with tools only recently developed. Several potential opportunities and constraints are identified in the sources reviewed for this issue in Appendix A, but further engagement is ongoing to identify additional nature rich sites, restoration projects, local priorities and opportunities to ensure best value is delivered from the final nature network that is delivered as part of LDP3. A collaborative approach to developing nature networks is taking place in partnership with the Perth and Kinross Countryside Trust through their Perthshire Nature Connections Partnership. This is likely to run through 2025 for landscape scale Nature Networks and will be developed alongside green infrastructure and green network identification. The lack of a biodiversity metric hinders the development of an approach to ensuring that development is complying with the mitigation hierarchy and providing the expected compensation and enhancement. Interim guidance has been introduced for applicants. If the national metric is delivered as proposed in early 2025 it will be able to inform impacts and uplift opportunities on site allocations. A mechanism for offsite biodiversity compensation and enhancement. There are established principles for delivery of the mitigation hierarchy as set out in the Council’s Planning for Nature Guidance. Compensation for biodiversity or habitat loss will always be expected onsite except in limited and justified circumstances. Scottish Government guidance on NPF4 Policy 3 also expects onsite delivery of biodiversity enhancement in the first instance. In limited justified circumstances where onsite enhancement is not possible an offsite solution for securing NPF4 requirements may be required. Engagement carried out in Summer 2024 has provided an indication of the preferred direction for how offsite compensation and enhancement will be secured and is reflected in interim guidance. The engagement will inform the development of local policy for LDP3 but currently Planning Circular 4/1998 for conditions and Planning Circular 3/2012 for planning obligations present a level of uncertainty for mechanisms to secure enhancement and offsite measures where the land is not under the control of the applicant. Statements of Agreement and/or Dispute: 16 responses were received on our Biodiversity and Natural Places Topic Paper. Most respondents (11 out of 16) either agreed with or did not disagree with the evidence identified through Topic Paper 005, and the summary of the implications of that evidence for the Proposed Plan provided by the Council, although some provided some suggestions for consideration or additional comments. There were 2 responses which the respondents wished to be treated as a formal dispute to the Evidence Report, and 3 comments where the respondents indicated that they disagreed with the evidence but did not wish for their response to be treated as a formal dispute. A breakdown of those responses grouped
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115 under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Biodiversity and Natural Places issue in Appendix A. • Key Stakeholders: o Nature Scot, neither agreed nor disagreed o SEPA, disagreed but does not wish to register comments as a formal dispute. Recommends Strategic Flood Risk Assessment in the Nature Network mapping, rather than flood maps alone, and the inclusion of 2021 River Basin Management Plan for Scotland as important for nature networks. Also emphasises the importance of the water environment to nature networks and requests river corridors are established as a key principle in the identification of these networks across Perth and Kinross. o Scottish Water, agreed • Community Councils: 3 responses, 1 agreed, and the others neither agreed nor disagreed. • Public At Large: 3 responses, 1 agreed, 1 disagreed on the basis that they do not believe there is a climate or nature crisis, but did not wish for their comments to be registered as a formal dispute, and the other disputed the evidence due to the lack of consideration of local biodiversity, and the negative impact of development on it. • Landowners and Agents: 6 responses, 3 of which neither agreed nor disagreed, 2 of which agreed, and 1 which disagreed with the summary of implications of the evidence and would welcome the development of a biodiversity net gain framework, a future developer contribution policy and a biodiversity register for offsite enhancement. However, they do not wish for their comments to be registered as a formal dispute to the Evidence Report. • Other Bodies: o Homes for Scotland disputes the summary of implications of the evidence for this issue to the Proposed Plan, specifically in relation to the protection of natural assets, namely local landscapes, risks to the water environment, and removal of trees or woodland, and comments that NPF4 Policy 4 states that the plan should not restrict development from happening completely, but allows for developments which align with Policy 4 due to socio-economic benefits of building homes.
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116 ISSUE: SOILS Links to Evidence: Soil and Habitat Types/Characteristics National Soil Map of Scotland Soil map of Scotland (partial cover) | Scotland's soils (environment.gov.scot) Habitat Map of Scotland | Scotland's environment web Carbon Rich Soils, Peatland and Priority Peatland Habitat Carbon and peatland 2016 map | Scotland's soils (environment.gov.scot) James Hutton Institute (JHI) - Carbon Sequestration Study (2021) [Core Doc Ref: CD1] Peatland Action - Peat Depth, Scotland's Soils Land Capability for Agriculture Land Capability for Agriculture Map (partial cover) Soil Risk Maps Soil Risk Maps Map of Subsoil Compaction Risk (partial cover) Map of Topsoil Compaction Risk (partial cover) Map of Soil Erosion Risk (partial cover) Map of Runoff Risk (partial cover) The following datasets were considered during the topic paper consultation in relation to “land of lesser quality that is culturally or locally important” but are not included as part of the Evidence Report: Historic Environment Scotland CANMORE record on ‘agricultural cropmark’ sites – Perth and Kinross Council Perth and Kinross Council Mapped Local Community Growing Initiatives Wetlands - Scotland's Environment Web Natural Flood Management Maps Land Capability for Forestry Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that key issues in relation to carbon rich soils and prime agricultural land are underpinned and guided by existing, national datasets, as noted under the summary of evidence in Appendix A. Site surveys can support the detailed consideration of: • Carbon rich soils, peatland, and priority peatland habitat, and • Prime agricultural land This information can support the assessment of sites for potential allocation as well as part of the determination of planning applications. Several consultation responses received on Topic Paper 006: Soils have identified that site information can supplement the consideration of soils including carbon rich soils and prime agricultural land.
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117 Soil risk maps further support the consideration of development in relation to protecting existing soils as well as minimising/avoiding impacts from new development. There is no nationally consistent methodology for identifying land of lesser quality that is culturally or locally important for primary use. Following stakeholder engagement on this matter, it is not intended to proceed with designating land under this classification. Statements of Agreement and/or Dispute: 10 responses were received on our Soils Topic Paper. Most respondents (9 out of 10) either agreed with or did not disagree with the evidence identified through Topic Paper 005, and the summary of the implications of that evidence for the Proposed Plan provided by the Council, although some provided some suggestions for consideration or additional comments. There was 1 response which the respondents wished to be treated as a formal dispute to the Evidence Report. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Soils issue in Appendix A. • Key Stakeholders: o Nature Scot, neither agreed nor disagreed o Historic Environment Scotland, agreed o Scottish Water, agreed • Community Councils: 2 responses, 1 agreed, and the other neither agreed nor disagreed. • Public At Large: No comments received. • Landowners and Agents: 4 responses, 2 of which neither agreed nor disagreed, 1 of which agreed, and 1 (Savills on behalf of Scone Estate) which disputed the list of evidence/datasets reviewed under the Soils Topic Paper and the summary of implications for the Proposed Plan provided, on the basis that there should be recognition that the designation of Prime Agricultural Land on the National Scale Land Capability for Agriculture map and the Land Capability for Agriculture (partial cover) map provides information which is ultimately broad in scope and cannot be relied upon at the local level without further specific inspections of the sites concerned. • Other Bodies: 1 response was received from Homes for Scotland who neither agreed nor disagreed with the summary of evidence and/or implications for the Proposed Plan.
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118 ISSUE: FORESTRY, WOODLAND, AND TREES Links to Evidence: Perth and Kinross Council Corporate Plan 2022-2027 The UK Forestry Standard (UKFS) Scotland's Forestry Strategy 2019-2029, Scottish Government Scotland's Forestry Strategy Implementation Plan 2022-2025, Scottish Government Scottish Forestry, The Right Tree in the Right Place: Planning for Forestry and Woodlands 2020 Challenge for Scotland’s Biodiversity - A Strategy for the conservation and enhancement of biodiversity in Scotland, Scottish Government NFI Woodland Ecological Condition Assessment Methodology, Forest Research The Scottish Government's Policy on Control of Woodland Removal, Forestry Commission Scotland Scottish Water Sustainable Land Management Scottish Water Guidance on Forestry Activities near Scottish Water Assets, September 2017 National Forest Inventory (NFI), Forest Research Native Woodland Survey of Scotland (NWSS), Scottish Forestry Ancient Woodland Inventory (AWI), NatureScot The Woodland Trust Ancient Tree Inventory (ATI) Scotland's National Forests and Land Perth and Kinross Council (PKC) Interactive Heritage Map Historic Environment Scotland’s Portal Scottish Forestry Map Viewer, Scottish Forestry Public Registers, Scottish Forestry National scale Land Capability for Forestry Map Nature Scot, Carbon and Peatland Map (2016) Perth and Kinross Council Forest and Woodland Strategy (2020) JHI Carbon Sequestration Study of the Perth and Kinross Area (December 2021) [Core Doc Ref: CD1] Perth and Kinross Council Draft Climate Emergency Report and Action Plan (2019) - Public Engagement Survey Perth and Kinross Council Planning Enforcement Charter 2024 Perth and Kinross Council LDP3 Big Place Conversation Perth and Kinross Council Tay Forest National Park Bid Perth and Kinross Council Tay Forest National Park Bid - Consultation Analysis report Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Existing Forestry, Woodland and Trees within Perth and Kinross - No single dataset provides a comprehensive overview of all trees and woodland of high biodiversity value within Perth and Kinross. The Native Woodland Survey of Scotland, the Scottish Ancient Woodland Inventory, the Ancient Tree Inventory, and Tree Preservation Orders combined provides the best available information. Although smaller
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119 scale woodlands, tree belts and hedgerows may be omitted. More detail on the limitations of specific datasets is outlined below. o The National Forest Inventory (NFI) covers all forest and woodland over 0.5 Hectares, with a minimum of 20% canopy cover, or the potential to achieve it, and a minimum width of 20 metres. As such, smaller woodlands, tree belts and hedgerows may not be included, and where relevant should be picked up via more place specific studies such as our Settlement Audit work, assessment of individual site proposals, and work related to identifying habitat and nature networks. o The Ancient Woodland Inventory (AWI) is a provisional guide to the location of Ancient Woodland. It contains three main categories of woodland, all of which are likely to be of value for their biodiversity and cultural value by virtue of their antiquity. The AWI was derived from the Roy maps (c1750) and the OS 1st edition (c1860). It is not definitive and should be used with care. Nature Scot advise that when evaluating woods it is important to - examine the site on the ground, looking for archaeological, biological and other indicators of antiquity and of its current biodiversity value; examine old maps (woods not shown on the AWI, but present on the historic maps, are likely to be ancient and should be treated as such unless evidence is available to the contrary), and to seek specialist advice if in doubt. It is proposed that we will follow these additional steps in identifying ancient woodland within the Perth and Kinross Area as part of our LDP3 Spatial Strategy and the review of our Forest and Woodland Strategy. o The Ancient Tree Inventory (ATI) maps ancient, veteran, and notable trees in the UK managed by the Woodland Trust. Data is often supplied by members of the public but is verified by local recorders, as such although it is publicly available, it needs enhancement via citizen engagement. Engagement will be carried out as part of the development of our Proposed Plan and revised Forest and Woodland Strategy, and we will seek further information from the public and key stakeholders in respect of ancient trees identified on the ATI. o The Council’s Interactive Heritage Map provides information about tree groups, tree lines, and individual trees that are protected through a Tree Preservation Order (TPO), and those within a Conservation Area. TPO’s are primarily located in settlements, with less in the rural countryside areas. The Council’s TPO’s require a review to ensure the records remain up- to-date and relevant and will be prioritised as part of the development of our LDP3 Proposed Plan. • Forestry and Woodland Creation – o Whilst for the most part still relevant, the Council’s Forestry and Woodland Strategy (FWS) will require a review to ensure that it is fully aligned with the National Strategy and meets the expectations and requirements of National Planning Framework 4. It is not anticipated that this review will lead to significant changes
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120 to the existing Strategy, as much of the data used to inform its development has not really changed. However, a review will ensure any changes at a national level in terms of outcomes, priorities and policy drivers are reflected, and that it is up to date in line with the requirements of the Planning Act, particularly in relation to the protection of woodlands of high nature conservation value, their resilience to a changing climate, and the multiple benefits which they can offer. o The James Hutton Institute Carbon Sequestration Study focused on the sectors of land-based industries and natural resources, and how these can be considered when looking at the carbon resources of the area, and its potential for sequestering carbon or reducing Greenhouse Gas Emissions. In terms of woodland expansion potential, the project report identifies significantly higher levels of carbon sequestration potential from the planting of Production Sitka Spruce, and lower from the expansion of Native Broadleaf (after 25 years). It is important to remember the national objective of expanding native woodlands, and policy of planting the right tree in the right place. As such, it is most likely that a mixed approach to planting will be the most appropriate one. The project report also includes limited data on species resilience to the effects of a changing climate. It is proposed that we explore with Forestry Scotland and Forest Research the information they hold regarding species resilience to address this gap in the JHI Study. Statements of Agreement and/or Dispute: 13 responses were received on our Forestry, Woodland and Trees Topic Paper. Most respondents (10 out of 13) either agreed with or had no comment to make on the evidence identified through Topic Paper 007, and the summary of the implications of that evidence for the Proposed Plan provided by the Council, or offered suggestions regarding the interpretation of NPF4 policies, or examples of additional sources of information which they felt should be considered. There was 1 response on the issue which the respondent wished to be treated as a formal dispute to the Evidence Report, and 2 comments where the respondents indicated that they disagreed with the evidence but did not wish for their response to be treated as a formal dispute. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Forestry, Woodland and Trees issue in Appendix A. • Key Stakeholders: o Nature Scot, neither agreed nor disagreed o Historic Environment Scotland, agreed o Scottish Water, agreed • Community Councils: 2 responses, 1 agreed, and the other neither agreed nor disagreed. • Public At Large: 2 responses were received from anonymous respondents, 1 disagreed with the summary of implications provided for this issue, and the other disagreed with both the list of
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121 evidence/datasets and the summary of implications for the Proposed Plan. Neither party wished for their comments to be registered as a formal dispute to the Evidence Report. 1 response was received from a private individual who disputed the list of evidence/datasets considered and the summary of implications for the Proposed Plan provided, as in their view the topic paper failed to represent the actual activities of Perth and Kinross Council in the arena. • Landowners and Agents: 4 responses which neither agreed nor disagreed with the evidence and summary of implications. • Other Bodies: A response from SSEN Transmission agreed with the evidence considered and summary of implications provided but made suggestions regarding the interpretation of policy in practice.
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122 ISSUE: HISTORIC ASSETS AND PLACES Links to Evidence: Perth and Kinross Council Corporate Plan 2022-2027 Relevant Historic Environment Policies, Advice and Guidance Our Past, Our Future: The Strategy for Scotland's Historic Environment 2023 Historic Environment Scotland, Historic Environment Policy for Scotland (HEPS) 2019 Historic Environment Scotland, ‘Managing Change in the Historic Environment' Historic Environment Scotland, Talking About Heritage Guide (2022) Historic Environment Scotland Circular: Regulations and Procedures The Association of Local Government Archaeological Officers, Guidance for Peatland Restoration and the Historic Environment in Scotland Historic Environment Scotland, Pointing the Way to the Future Historic Environment Scotland, Green Recovery Statement for the Historic Environment Historic Environment Scotland, A Guide to Climate Change Impacts Historic Land Use Assessment Historic Environment Scotland’s Historic Land Use Assessment (HLA) Perth and Kinross Heritage Trust (PKHT) Perth City Heritage Fund (PCHF) Community Heritage Grants Scheme. Completed PKHT Projects PKHT Trails, Maps and Leaflets Information Location of Historic Assets and Places Perth and Kinross Council Interactive Heritage Map Scottish Government Transforming Planning - Permitted Development Historic Environment Scotland’s Portal - Listed Buildings Buildings at Risk Register for Scotland Perth and Kinross Council Historic Environment Record (HER) Historic Environment Scotland CANMORE record on ‘agricultural cropmark’ sites – Perth & Kinross Council Other Relevant Sources of Information Perth and Kinross Council LDP3 Big Place Conversation Perth and Kinross LDP2 Design Charettes Perth and Kinross Council Placemaking Programme Aberfeldy Square Regeneration Community Action Plans - Meigle and Ardler, Stanley, Alyth, Coupar Angus, Dunkeld and Birnam, Crieff, Blairgowrie and Rattray, Pitlochry and Moulin, Muthill and Tullibardine, Auchterarder and Aberuthven, and St. Fillans. Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: The LDP3 Spatial Strategy should reflect the priorities and principles of ‘Our Past, Our Future’ Strategy for Scotland’s Historic Environment 2023.
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123 The policies contained within the Historic Environment Policy Scotland should be taken account of and translated into the Plan’s Spatial Strategy with respect to the historic environment of Perth and Kinross. PKC will ensure there is early and continued engagement with Historic Environment Scotland with regards to the development of LDP3 Spatial Strategy, its SEA and any related historic environment appraisals or guidance documents. In reviewing the sources of evidence listed under this issue, it was identified that: • Historic Land Use Assessment (HLA) – Historic Environment Scotland’s HLA is not available for the entire Perth and Kinross Council Area. However, it does provide a picture for the most populated areas. • Conservation Area Appraisals (CAA) - At present, Conservation Area Appraisals (CAA) and guidance are available for 22 out of those 36 areas. However, this is currently a rolling review programme in place for reviewing our list of Conservation Areas which is expected to be completed during 2025-2026. • Perth and Kinross Design Charettes - Due to the period of time which has lapsed since these reports were produced, any data or statistics contained within them which has since been updated should be reviewed as part of the LDP3 Settlement Audit work. The Audit should also consider if progress has been made against the key issues and actions identified in the charettes, and how those issues and actions compare to the feedback gathered through the Big Place Conversation. Statements of Agreement and/or Dispute: 10 responses were received on our Historic Assets and Places Topic Paper 8, 1 of which came from a respondent who did not provide their name or contact details. 60% neither agreed with or nor disagreed with the evidence and a many provided examples to assess with highlighting the importance of historic assets and places. A number offered examples of additional sources of information which they felt should be considered and / or highlighted other potential implications for the Proposed Plan. 1 respondent wished for their comments to be treated as a formal dispute to the Evidence Report. A full summary of these comments, their status, and the Council’s response are provided in the table relevant table under this issue in Appendix A. A breakdown of those responses grouped under stakeholder categories is provided below. • Key Stakeholders: 2 responses, Historic Environment Scotland supplies further information in respect of Historic Environment designations and casework; buildings at risk; grants; communities; and tourism and economy relating to Perth and Kinross, which will be used to prepare the Proposed Plan. Scottish Water neither agree nor disagree with the evidence.
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124 • Community Councils: 2 responses, 1 which agreed with the list of evidence reviewed and summary of implications for the Proposed Plan, and 1 which neither agreed nor disagreed. • Public At Large: 2 responses were received from members of the public. 1 response from an individual who was concerned that some historic environment features could be seen on the map. The final response was also from an anonymous individual, they raise awareness of updates to the Managing Change guidance. Highlights importance of publicity for grants/funding and offers comments for a more realistic timetable for conservation area appraisals. They did not wish for their comments to be registered as a formal dispute. • Landowners and Agents: 2 responses neither agreed nor disagreed with the list of evidence and the summary of implications for the proposed Plan. 1 provided further comments highlighting that discretion, flexibility and a balanced approach will be needed when appraising proposed developments and emphasising that NPF4 needs to be read and applied as a whole. • Other Bodies: Perth and Kinross Heritage Trust disagree with the evidence; additional information is supplied in respect of PKHER; the ALGAO public benefit; other NPF4 policies that also reference the Historic Environment. Additional comments raise awareness of new PKHT guidance documents, and other resources to support the LDP.
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125 ISSUE: GREEN BELTS Links to Evidence: Perth and Kinross Structure Plan Written Statement, June 2003 [Core Doc ref: CD2] David Tyldesley and Associates Perth Green Belt Study, June 2000 [Core Doc ref: CD3] LDP 1 Examination Report: Policy NE5 Green Belt [Core Doc ref: CD4] LDP2 SEA – Addendum to the Environmental Report Dec 2017 LDP2 Examination Report: Policy 41 Green Belt [Core Doc ref: CD5] Perth and Kinross Local Development Plan 2, 2019 Scottish Vacant and Derelict Land Survey 2023 Nature Scot National Landscape Character Assessment LDP2 Landscape Supplementary Guidance, 2020 Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • The green belt boundary has already been reviewed though the preparation of the current LDP. It will be necessary, however, to carry out a further review in light of the new policy context and priorities set out in the NPF, including meeting the finalised housing and employment land requirements, and the spatial strategy which is identified for the new LDP. In relation to the latter, 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 Plan’s 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. Statements of Agreement and/or Dispute: 12 responses were received on our Green Belts Topic Paper, 2 of which came from respondents who did not provide their name or contact details. Just over half of respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 009: Green Belts, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and / or highlighted other potential implications for the Proposed Plan. There were 4 responses on the issue which the respondents wished to be treated as a formal dispute to the Evidence Report. A full summary of these comments, their status, and the Council’s response are provided in the table relevant table under this issue in Appendix A. A breakdown of those responses grouped under stakeholder categories is provided below.
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126 • Key Stakeholders: NatureScot, did not state whether they agreed or disagreed, but provided suggestions for regarding including consideration of nature networks and landscape character under the summary of implications section for this issue also. • Community Councils: 2 responses, 1 which agreed with the list of evidence reviewed and summary of implications for the Proposed Plan, and 1 which neither agreed nor disagreed. • Public At Large: 3 responses were received on the Green Belt Topic Paper from members of the public. 1 response from an individual who wished for their comments to be recorded as a formal dispute due to the scale of maps provided in the topic paper, their view that the Council has consistently ignored the green belt around Scone, and the failure of the evidence to identify what the village envelope scale is. Another formal dispute from an anonymous respondent has been noted on the issue on the grounds Craigend requires to be properly considered on the ground and compared against the other similar settlements around Perth which have been omitted from the green belt. The final response was also from an anonymous individual, they disagreed with the list of evidence and datasets reviewed, as they disagreed that urban areas have to be more densely populated in order to protect the green belt. They did not wish for their comments to be registered as a formal dispute. • Landowners and Agents: 2 responses neither agreed nor disagreed with the list of evidence and the summary of implications for the proposed Plan. 1 disagreed in principle (Ristol Consulting), providing further comments requesting the consideration of the application of the Housing in the Countryside Policy in the green belt review. However, they did not wish to register their comments as a formal dispute. 1 respondent (Savills on behalf of Scone Estate) made no comments on the evidence and summary of implications, but under the further comments section of the consultation questionnaire they raised a formal dispute on the grounds that the Council should take a root and branch approach to the review of the green belt and consider whether it remains relevant and consider that Scone Estate should be identified as an existing major business within the green belt boundary whenever a review is being carried out. • Other Bodies: Homes for Scotland wish to formally dispute the summary of implications of the evidence for the Proposed Plan on the grounds that a green belt review must be carried out.
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127 ISSUE: BROWNFIELD, VACANT AND DERELICT LAND, AND EMPTY BUILDINGS Links to Evidence: Scottish Vacant and Derelict Land Survey 2023 Buildings at Risk Register for Scotland Society for the Protection of Ancient Buildings Survey of Thatched Buildings in Scotland Church of Scotland Properties for Sale Perth and Kinross Housing Land Audit 2023 Perth and Kinross City and Town Centre Retail Study Perth and Kinross Local Housing Strategy Framework 2022-27 and Action Plan Perth and Kinross Council Reusing Empty Properties Perth and Kinross Council Elected Member Briefing – Vacant and Eyesore Property Taskforce Update Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Identification of Sites - Not all brownfield land and vacant buildings will be included within the Scottish Vacant and Derelict Land Survey (SVDLS), only those which meet the criteria for inclusion in the national survey. The Proposed Plan will need to use the most up to date data available given the emphasis in NPF4 Policy 9 on encouraging, promoting and facilitating the reuse of brownfield, vacant and derelict land and empty buildings, and helping reduce the need for greenfield development. Key to achieving Local Housing Strategy Action 1.3 is developing a register of potential brownfield regeneration sites. A pilot exercise has so far been undertaken for a specific area of Perth and Kinross. This considered vacant and derelict land, vacant properties, community land audit, car parks, underutilised open space, land in council ownership, land allocated for employment safeguarding in LDP2, land allocated in LDP2 and the housing land audit but not yet fulfilled, and officer identified sites. The main purpose is to identify sites for affordable housing, including small sites that could be brought forward for development immediately or considered for the longer term via the LDP review process. An initial assessment identified those sites which could be immediately discounted, for example, those which would not comply with planning policy. A full site assessment was then carried out on the remaining sites, and these were then scored to identify:
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128 o Green sites with few constraints and the potential for delivery in 1-2 years. o Amber sites with a small number of significant constraints (or many small constraints) that make feasibility less certain and where further assessment would be clarified via a planning application. o Red sites which have significant constraints, and which would need to be considered through the review of the LDP Partners, including development trusts are using the results of the pilot to engage with landowners and explore the development viability of green and some amber rated sites in more detail. The process has been reviewed and refined and will be rolled-out across the Perth and Kinross Area. This study does have the potential to amass a large amount of data. Of relevance to the preparation of the Proposed Plan will be the identification of ‘red’ sites which will require to be assessed through the LDP review process. An additional output beyond identifying land with housing potential, is a register of brownfield sites for development that are in line with current planning policy and preliminary development risks have been assessed. In this there may also be scope to include other brownfield land, for example, land with no use currently, or land with potential for ‘soft’ uses such as open space. Having an up to date and accurate record of all known brownfield land within the area will help identify the scale of the problem and any issues relating specifically to Perth and Kinross which may require a local policy response in LDP3, as well as highlighting potential sites for development. • Retail Floorspace Data - A comparison of vacancy data is not available for the smaller town centres of Aberfeldy, Alyth, Coupar Angus and Dunkeld. Statements of Agreement and/or Dispute: 11 responses were received on our Brownfield, Vacant and Derelict Land and Empty Buildings Topic Paper, 3 of which came from respondents who did not provide their name or contact details. Around half of respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 010, or the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and / or highlighted other potential implications for the Proposed Plan. 1 respondent on the issue wished for their comments to be treated as a formal dispute to the Evidence Report. A full summary of these comments, their status, and the Council’s response are provided in the table relevant table under this issue in Appendix A. A breakdown of those responses grouped under stakeholder categories is provided below. • Key Stakeholders: o Nature Scot, agreed o Historic Environment Scotland, agreed o Scottish Water, agreed • Community Councils: 2 responses, 1 agreed, and the other (Errol Community Council) disagreed with the list of evidence and
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129 summary of implications, as, in their view, there is insufficient data to determine what is considered vacant and derelict in their area, and the impacts have not been fully outlined, sufficient to allow them to understand at this stage. However, they did not wish for their response to be registered as a formal dispute to the Evidence Report. • Public At Large: 3 anonymous responses were received on Topic Paper 010, 2 of which disagreed, and 1 which agreed. 1 of those respondents who disagreed wished for their response to be registered as a formal dispute to the Evidence Report on the grounds that the accuracy of the total brownfield/derelict area across the Council Area outwith urban areas (24 Ha); the extent of brownfield/derelict land at Errol Airfield would surpass the 24 Ha over the total Perth and Kinross Council Area, and the omission of any reference to Errol Airfields – the largest brownfield site in the Council Area. The other anonymous response disagreed with the summary of implications for the Proposed Plan due to the view that vacant sites when they come up should be looked at as an opportunity to reduce existing and future flood risk within urban areas, through providing built in underground water storage to reduce surcharging from manholes in built-up areas. They did not wish their comments to be registered as a formal dispute. • Landowners and Agents: 2 responses were received, neither agreed nor disagreed with the list of evidence and the summary of implications for the Proposed Plan. • Other Bodies: Homes for Scotland disagreed with the list of evidence and summary of implications on the grounds that they are of the opinion that greater recognition should be given in the Evidence Report to the Housing Land Audit (HLA) as a source of evidence and potential for brownfield sites. If the evaluation of evidence under this issue is updated to include the HLA (it now has), the respondent does not wish to take their response forward as a formal dispute to the Evidence Report.
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130 ISSUE: COASTAL DEVELOPMENT AND AQUACULTURE Links to Evidence: Flood risk information SEPA medium future flood risk 2080 coastal flood risk mapping SEPA Flood Risk and Land Use Vulnerability Guidance Tay Flood Risk Management Plan Tay Local Flood Risk Management Plan Climate Change Master Action Plan Climate Change Risk and Opportunity Assessment Perth and Kinross Council Strategic Flood Risk Assessment (Core Doc Ref CD25) Coastal planning Mapping Coastal Erosion Disadvantage in Scotland Coastal Change Adaptation Guidance Perth Harbour Business Plan Update and Future Options Appraisal TAYplan Strategic Development Plan (SDP) 2016-2036 Coastal Classification [Core Doc. Ref CD8] Perth and Kinross Structure Plan approved June 2003, Assessment of the Coastline [Core Doc. Ref CD7] Scottish Coastal Observatory Data Big Place Conversation Summary Report Big Place Conversation Carse of Gowrie Summary Report Aquaculture information: Marine Scotland National Marine Plan Nature Scot’s Planning and Development Guidance on Marine Aquaculture SEPA’s Planning and Development Guidance on Marine Aquaculture SEPA Revised Regulatory Framework and Sector Plan GIS data from Marine Scotland on Shellfish Water Protected Areas Marine Scotland’s Planning and Locational Guidelines Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • SEPA medium future flood risk 2080 coastal flood risk mapping is the best proxy for the at-risk flood risk areas mentioned in NPF4, this is currently based on UK 2009 Climate Projections but will be updated to reflect the UK 2018 Climate Change Projections. If this updated climate change mapping is available this will be used in the site assessments for the Proposed Plan. However, whilst development in coastal areas as per the NPF4 coastal development policy should be sensitive to sea level rises/flood risk and to environmental constraints and qualities, is NPF4’s intention to propose a more restrictive precautionary approach for coastal rural areas compared to otherwise similar inland rural areas? If not, the intention would be to consider the undeveloped coastline to be isolated/unspoiled coastline, and there would be no undeveloped coastline within Perth and Kinross.
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131 NPF4 does not define the undeveloped coastline. It is unclear whether undeveloped means remote unspoiled coastline with wild land qualities, or if it is any area outwith a settlement boundary like the areas of significant constraint mentioned in SPP 2014. If it is remote and unspoiled areas then there is no undeveloped coastline as the Perth and Kinross coastline is close to large centres of population and is accessible and it is not a wild or remote unspoiled coastline, never being far from settlement, the road network and railway line, or other signs of human activity. However, if the undeveloped coastline is an area that is not urban/settled then the entire coastline along the Tay from Invergowrie to Perth on the north bank, and also along the southern bank of the Tay, apart from the small settlements themselves, would be considered to be undeveloped as per the Perth and Kinross Structure Plan 2003. If it is the latter definition, then the Proposed Plan could identify its undeveloped coast accordingly and potentially define this as either 1 kilometre inland (to align with the outer distance used by the Dynamic Coast for mapping of assets and vulnerability) or 0.5 kilometres inland (to align with the Perth and Kinross Structure Plan) from the mean high-water mark. The coastal zone could be from Perth itself as the impact of the tides affect Perth, or alternatively it could be from where the River Earn meets the Tay. Based on the Dynamic Coast web maps, and observing there are no areas at risk from coastal erosion, there does not appear to be significant concerns related to this coastline. However, Perth and Kinross Council has received funding for a Coastal Change Adaption Plan, and if it is available timeously it will inform the Proposed Plan. • The NPF4 policy framework, and Nature Scot landscape and visual guidance are likely to be sufficient for the consideration of future planning applications for shellfish farms, for finfish hatcheries and freshwater adult growth stage facilities. Together with Marine Scotland National Marine Plan 2015 and its successor, this policy context will provide appropriate policy context for marine planning. Given the limited area and local context in LDP3 a local policy is not necessary. Statements of Agreement and/or Dispute: 5 responses were received on our Coastal Development and Aquaculture Topic Paper. All of the respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 011, or the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number of responses highlighted other potential implications for the Proposed Plan or made further comments. A full summary of these comments, their status, and the Council’s response are provided in the table relevant table under this issue in Appendix A. A breakdown of those responses grouped under stakeholder categories is provided below.
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132 • Key Stakeholders: o Nature Scot, neither agreed nor disagreed with the list of evidence/datasets and summary of implications for the Proposed Plan, but did suggest that more could be included under the summary of implications section regarding climate change and biodiversity, which could also include the key policy connections set out in NPF4 for this policy and expand upon these in the context of Perth and Kinross. o Scottish Water, neither agreed nor disagreed. • Community Councils: 2 responses, 1 agreed, and the other neither agreed nor disagreed with the list of evidence and summary of implications provided. • Public At Large: No comments received. • Landowners and Agents: 1 response was received which neither agreed nor disagreed with the list of evidence and the summary of implications for the Proposed Plan. • Other Bodies: No comments received.
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133 ISSUE: ENERGY, HEATING AND COOLING (INCLUDING INFRASTRUCTURE: ENERGY SUPPLY SYSTEMS) Links to Evidence: National and Local Policy Context Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 Update to the Scottish Government Climate Change Plan 2018-2032 Draft Energy Strategy and Just Transition Plan Heat in Buildings Strategy Heat in Buildings Bill Heat Networks (Scotland) Act 2021 Perth and Kinross Council Corporate Plan (2022-2027) Perth and Kinross Council Climate Change Strategy and Action Plan Perth and Kinross Council Local Area Energy Plan (LAEP) Perth and Kinross Council Local Heat and Energy Efficiency Strategy (LHEES) Perth and Kinross Council Local Housing Strategy (2022-2027) Energy Infrastructure National Grid 'Beyond 2030' Energy Act 2023 National Energy System Operator Proposals for Local Energy system governance SSEN transmission network infrastructure SSEN Transmission network map tool SSEN Transmission Pathway to 2030 projects SSEN Transmission Plans for Central Highlands SSEN Transmission Plans for East Coast SSEN Transmission projects map SSEN distribution network infrastructure SSEN distribution embedded capacity SSEN Distribution SHEPD Long Term Development Statement SSEN Distribution SEPD Long Term Development Statement SSEN Distribution Network Future Energy Scenario (DFES) Report (2024) SSEN Distribution DFES Report (2024) for the North of Scotland SSEN Distribution Strategic Development Plans (SDPs) SSEN LENZA Tool Scottish Power Transmission Scottish Power Distribution UK Government Energy Statistics Perth and Kinross Council Map - Location of Renewable Energy Proposals SSE Renewables - Planned Upgrades SGN - Gas Network Scottish Government Hydrogen Action Plan Future Opportunities – Renewable Energy and Decarbonised Heat Perth and Kinross Council LHEES Strategy and Delivery Plan Perth and Kinross Council Green Assets Map Onshore Wind Policy Statement Hydrogen in Scotland Scottish Enterprise Hydrogen Sites Study Scottish Water Renewable Energy Opportunities Guide Perth and Kinross Council Community Projects Constraints and Environmental Considerations Perth and Kinross Landscape Guidance Perth and Kinross Council Landscape Capacity Study - Wind Nature Scot Landscape Sensitivity Study Guidance Perth and Kinross Local Development Plan (2019)
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134 Fourteenth Annual Report on the Operation of Section 72 of the Climate Change (Scotland) Act 2009 Scottish Government New Build Heat Standard Perth and Kinross Council Draft Supplementary Guidance for Renewable and Low Carbon Energy Chief Planner Letter (2024) Good Practice Principles for Community Benefits from Onshore Renewable Energy Developments Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Formal Designation of Heat Network Zones – in line with the requirements of the Heat Networks (Scotland) Act 2021 – is still to take place. • Landscape Capacity for Wind - The Council’s Landscape Capacity Study for Wind was published in 2010 and therefore does not reflect the current planning policy framework for wind proposals. The expectations around landscape impacts have shifted as per NPF4 Policy 11e(ii), whereby significant landscape impacts are to be expected at the localised level and/or provided appropriate design mitigation is included. There are no plans to update the landscape capacity study however the current draft Renewable Energy guidance is programmed to be updated in 2025 which will provide guidance to support implementation of NPF4 Policy 11, including in relation to project design and layout to mitigate landscape impacts. This will refer to NatureScot’s Landscape Sensitivity Guidance. • Pipeline Infrastructure - There are indicative plans for potential new pipeline infrastructure across Scotland including in the Perth and Kinross Area to support emerging plans around hydrogen production/transmission. Plans are at an early stage and will continue to be monitored and considered during the preparation of the Proposed Plan, where relevant. • UK Energy Governance - The development of UK energy governance arrangements will continue to be monitored and considered during the preparation of the Proposed Plan, where relevant. Statements of Agreement and/or Dispute: The Council engaged specifically with SSEN (transmission and distribution), SPEN and SGN in the preparation of the Evidence Report, and provided other key stakeholders, groups and members of the public an opportunity to provide feedback on Topic Paper 012: Energy, Heating and Cooling through our six-week engagement period. 14 responses were received on Topic Paper 012, 4 disagreed with the list of evidence/datasets reviewed, and/or the summary of implications for the Proposed Plan provided, 1 of which (Holder Planning on behalf of SSE
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135 Renewables) wished for their comments to be recorded as a formal dispute to the Evidence Report. 4 of the responses agreed, and 5 respondents neither agreed nor disagreed. A full summary of these comments, their status, and the Council’s response are provided in the table relevant table under this issue in Appendix A. A breakdown of those responses grouped under stakeholder categories is provided below. • Key Stakeholders: o Nature Scot, neither agreed nor disagreed with the list of evidence/datasets and summary of implications for the Proposed Plan and welcomed the inclusion of landscape in the topic paper. o Scottish Enterprise disagreed with the list of evidence/datasets reviewed and the summary of implications provided specifically regarding the wording under paragraph 2.35 of Topic Paper 012 in relation to the role of hydrogen in the gas grid for future home heating, highlighting the Scottish Government’s Hydrogen Action Plan which places hydrogen for home heating low on the hierarchy of uses, and specifically notes that hydrogen is not considered to play a central role in decarbonising heating. They do not wish for their response to be registered as a formal dispute to the Evidence Report. o Scottish Water, agreed. • Community Councils: 2 responses, 1 agreed, and the other neither agreed nor disagreed with the list of evidence and summary of implications provided. • Public At Large: 3 responses were received on the topic paper. 2 of which agreed with the list of evidence and summary of implications for the Proposed Plan. 1 response from a private individual disagreed on the basis that Topic Paper 012 did not consider the potential concerns over the commercial robustness of providers and the implications of failure of the enterprise. They also noted that the topic does not give sufficient focus on the rural elderly on migrating from LPG/Gas to other forms of heating, and the assistance they may need. The respondent did not wish for their comments to be registered as a formal dispute. • Landowners and Agents: 3 responses were received, 2 of which neither agreed nor disagreed with the list of evidence and summary of implications. 1 response (Holder Planning on behalf of SSE Renewables) wished for their comments to be registered as a formal dispute to the Evidence Report in relation to the omission of Onshore Wind: Policy Statement 2022 from the section in the topic paper on legal and national policy requirements and expectations, and also on the basis that the Council’s Landscape Capacity Study for Wind (2010) should carry very limited weight due to it being out of date and subsequent policy changes having occurred since its publication. They also dispute the proposed use of the 2010 study in assessing proposals against LDP3, and the potential for a spatial strategy for renewable development being included within LDP3. They note that local guidance would be helpful to provide further detail to any localised considerations, but it is not required to be enshrined within the new LDP. • Other Bodies: o Homes for Scotland disagreed with the list of evidence/datasets and the summary of implications provided. They provided an additional list of suggested evidence for inclusion and highlighted that there is no longer a need to include policies within Development Plans following the repeal of Section 72 requirements under the
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136 Fourteenth Annual Report on Section 72 of the Climate Change Act. The respondent also highlighted that energy infrastructure will have an impact on the locations suitable for accommodating housing development and therefore compatibility in relation to expansion of the national grid network will need to be considered, and that LDP3’s Spatial Strategy will need to consider both sustainable and marketable locations for new development. Furthermore, the Council will need to work with the DNO to ensure an upgrade to the network is aligned with future housing supply pipeline. Homes for Scotland did not wish to register their response as a formal dispute to the Evidence Report. o SSEN Transmission agreed with the list of evidence and summary of implications provided.
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137 ISSUE: ZERO WASTE Links to Evidence: Scotland's Zero Waste Plan Making things last: a circular economy strategy Stop, Sort, Burn, Bury - incineration in the waste hierarchy: independent review SEPA waste analysis: household waste SEPA waste analysis: waste sites and capacity SEPA Regional capacity calculations for Scottish Planning Policy (SPP) (2018 data) Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • the Perth and Kinross Waste Management Plan covers the period 2010-2025 but is likely to be updated. Statements of Agreement and/or Dispute: Two responses were received on our Zero Waste topic paper. One respondent agreed with the evidence identified through the topic paper, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. The other had no specific comments. A full summary of these comments, their status, and the Council’s response are provided in the relevant table under this issue in Appendix A. A breakdown of those responses grouped under stakeholder categories is provided below. There were no formal disputes • Key Stakeholders: Historic Environment Scotland noted the maintenance, reuse and adaptation of existing assets such as our built historic environment aligns with the policy aims for the reduction and reuse of materials in construction. • Community Councils: Earn Community Council made constructive comments on issues for the Proposed Plan to consider. .
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138 LIVEABLE PLACES
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139 LIVEABLE PLACES 5.4.1 The issues covered under the NPF4 theme Liveable Places are: • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Blue and Green Infrastructure • Play, Recreation and Sport • Flood Risk and Water Management • Health and Safety 5.4.2 A full summary of the review of evidence undertaken for all issues under this NPF4 theme, including all relevant links to that evidence, and a summary of stakeholder engagement, has been provided under Appendix B to this report. To save duplication in the re-reporting of that information, the pages to follow concentrate instead on providing an overview of the identified likely implications of this evidence for the preparation of the Proposed Plan, any gaps, uncertainties or key issues in the evidence gathered, and a summary of agreement, and/or disputes related to the evidence which were received through our programme of participation and engagement reported under Section 3.
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140 ISSUE: DESIGN, QUALITY AND PLACE Links to Evidence: Perth and Kinross Council Corporate Plan 2022-2027 LDP Spatial Strategies Scottish Government and COSLA’s Place Principle (2019) Scottish Government, Creating Places: A policy statement on architecture and place for Scotland (June 2013) Scottish Government, Designing Streets: A Policy Statement for Scotland (March 2010) Perth and Kinross Local Development Plan 2 (2019) Scottish Government NPF4: Annex D – Six Qualities of Successful Places Transport Scotland, Sustrans and SCOTS, Cycling by Design 2021 Scottish Government, Planning Advice Note 83: Master planning Perth and Kinross Placemaking Guide Supplementary Guidance (2020) Perth and Kinross Consultation Draft Mobility Strategy (2024) Perth and Kinross Mobility Strategy Draft Action Plan (2024) Scottish Household Survey (SHS) Understanding Our Local Places The Improvement Service, Place Standard Engagement Tool Perth and Kinross Council LDP3 Big Place Conversation Scottish Index of Multiple Deprivation (SIMD) Scottish Government, Scottish House Condition Survey: Local Authority Analysis 2017-2019 (February 2021) Perth and Kinross Council, Local Housing Strategy (LHS) 2022-2027 Perth and Kinross Council, LHS Action Plan 2022-2027 Perth and Kinross LDP2 Design Charettes Perth and Kinross Community Plan (Local Outcomes Improvement Plan) 2022-32 Perth and Kinross Area Local Action Plans Community Action Plans: Meigle and Ardler, Stanley, Alyth, Coupar Angus, Dunkeld and Birnam, Crieff, Blairgowrie and Rattray, Pitlochry and Moulin, Muthill and Tullibardine, Auchterarder and Aberuthven, and St. Fillans. Perth and Kinross Council Ward Profiles Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix B to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Perth and Kinross Placemaking Guide Supplementary Guidance (2020) - The guidance remains relevant, but will require a review and some minor updates, to ensure the references contained within it and the terminology used are in line with NPF4, to allow its future use alongside LDP3. • Scottish Government, Scottish House Condition Survey: Local Authority Analysis 2017-2019 (February 2021) - The survey merges three years’ worth of data (2017-2019) to achieve sufficient sample sizes and the survey analysis reports on the average figures for the three-year period. Whilst it is a useful dataset, it has already been used to develop the Council’s Local Housing Strategy and Action Plan,
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141 and as such the incorporation of the relevant priorities and spatial elements identified in those documents would be most appropriate to the development of the Proposed Plan. • Perth and Kinross LDP2 Design Charettes - Due to when they were produced, any data or statistics contained within the Design Charettes, which has since been updated, should be reviewed as part of the LDP3 Settlement Audit work. The Audit should also consider if progress has been made against the key issues and actions identified in the Charettes, and how those issues and actions compare to the feedback gathered through the Big Place Conversation. • Perth and Kinross Area – Local Action Plans (LAPs) - The LAPs contain important profiles of our localities across Perth and Kinross, particularly around their ‘Key Inequalities’. However, as they were all published in 2017 the statistical data reported within them are not the most recent available data. The list of ‘key Issues Identified’ and ‘What needs to change’ accompanying statements contained within the LAPs will be reviewed as part of our LDP3 Settlement Audit exercise but will be viewed taking account of relevant up-to- date data and information. • Perth and Kinross Council Ward Profiles - The Ward Profiles contain some data and information which is now out of date. As part of the Settlement Audit exercise for developing the Proposed Plan, they should be viewed in the light of the most up-to-date information available for the key characteristics and challenges for those places. Statements of Agreement and/or Dispute: 14 responses were received on our Design, Quality and Place Topic Paper. Most respondents (12 out of 14) either agreed with or had no comment to make on the evidence identified through Topic Paper 018, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered. There were 2 responses on the issue which the respondents wished to be treated as a formal dispute to the Evidence Report. A full summary of these comments, their status, and the Council’s response are provided in the table relevant table under this issue in Appendix B. A breakdown of those responses grouped under stakeholder categories is provided below. • Key Stakeholders: o Historic Environment Scotland agreed and further commented that they welcome the references in the topic paper to the Council’s Placemaking Guide, and the commitment to update it. o Nature Scot, neither agreed nor disagreed, but flagged the omission of the reference to the Scottish Government’s ‘Creating Places: A policy statement on architecture and place for Scotland’ being carried through from the summary of implications of evidence to the list of evidence and datasets. o Tactran Regional Transportation Partnership agreed and overall welcomed the detail set out in Topic Paper 018, and provided advice on the key transport related considerations
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142 which the Council should consider in developing our LDP3 Spatial Strategy in order to deliver connected places which are accessible for everyone. o Perth and Kinross Council Transportation and Development Team, neither agreed nor disagreed with the list of evidence and summary of implications, but did highlight the importance of Action 153 of the Council’s Mobility Strategy and Action Plan to the development of the Proposed Plan. o Scottish Water, neither agreed nor disagreed and commented that they welcome a best practice approach on water efficiency across the Plan Area, and the reference under the topic paper to the use of blue-green assets as a key design feature for new and existing developments. • Community Councils: 1 response was received which agreed with the list of evidence reviewed and summary of implications for the Proposed Plan provided, the other neither agreed nor disagreed. • Public At Large: 1 response were received on the topic paper from a private individual who wished to register their comments as a formal dispute to the Evidence Report, as in their view Topic Paper 018: Design, Quality and Place fails to address any of the recent historical development activity (namely at North Scone) and objections from the local community. • Landowners and Agents: 5 responses were received on Topic Paper 018. 1 response (A.S. Associates Ltd. Planning and Architectural Services) disagreed with the list of evidence/ datasets reviewed in relation to the upcoming Site Appraisal and Settlement Audit work mentioned in the relevant topic paper, and the lack of information on which datasets will be used to provide evidence for this area of work. However, the respondent did not wish for their comments to be registered as a formal dispute to the Evidence Report. 3 responses were received which neither agreed nor disagreed, and a further 1 response agreed with the list of evidence and summary of implications for the Proposed Plan. • Other Bodies: o Homes for Scotland disputed the list of evidence/datasets reviewed and the summary of implications provided. The points which they wish to formally dispute is that the Council should include the additional sources of information listed in their response, and analyse how this will influence the design, quality and place that will be created by future development.
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143 ISSUE: LOCAL LIVING AND 20 MINUTE NEIGHBOURHOODS Links to Evidence: Understanding Our Local Places Climate X Change and Ramboll, 20 Minute Neighbourhoods in a Scottish Context (February 2021) Scottish Government, Local Living and 20 Minute Neighbourhoods: Planning Guidance (April 2024) Perth and Kinross Council Corporate Plan 2022-2027 Perth and Kinross Local Development Plan 2 (2019) Perth and Kinross LDP2 Infrastructure Capacity Studies (2017) Scottish Index of Multiple Deprivation (2020) Perth and Kinross Council LDP3 Big Place Conversation Perth and Kinross Community Plan (Local Outcomes Improvement Plan) 2022-32 Perth and Kinross Council LDP2 Design Charettes The Perth City Plan 2015-2035 Perth and Kinross Council Placemaking Programme Invest in Perth: Smart Investing Now and for the Future Perth Cycle Network Masterplan Perth and Kinross Council Mobility Strategy and Action Plan Perth and Kinross Local Action Plans Community Action Plans - Meigle and Ardler, Stanley, Alyth, Coupar Angus, Dunkeld and Birnam, Crieff, Blairgowrie and Rattray, Pitlochry and Moulin, Muthill and Tullibardine, Auchterarder and Aberuthven, and St. Fillans. Perth and Kinross Council LDP3 Invitation to Create LPPs Perth and Kinross Council Ward Profiles (2022) Scottish Living Locally Data Portal [Core Doc Ref: CD10] The Place Principle Scottish Government and COSLA, Place Principle (2019) Location of Facilities Perth and Kinross LDP2 Infrastructure Capacity Studies (2017) Perth and Kinross Council, Map of Public Toilets and Comfort Schemes Scottish Water, Your Water, Your Life - Find My Nearest Tap Perth and Kinross Council List of Water Foutain and Refill Taps [Core Doc Ref: CD9] Sport and Leisure, Arts and Cultural Activities Perth and Kinross Council Leisure, Sport and Culture Webpage Live Active Website Perth City and Towns Website Visit Scotland Website Perth and Kinross Council Culture Strategy (2023-2028) Childcare Provision and Supporting Lifelong Learning Perth and Kinross Council Schools and Learning Webpages University of the Highlands and Islands Website Perth and Kinross Employability Network Visiting Health Services and Clinics NHS Inform Scotland’s Service Directory Social Interaction, and Support and Advice Services Your Community PK Website Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix B to this Evidence Report.
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144 Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Infrastructure Capacity Studies, Design Charette Reports, and Ward Profiles - Despite some time having elapsed since these pieces of evidence were produced, their content still provides a good source of information on the assets, facilities and services offered in our places, along with the community’s views of their local assets, their aspirations, vision for the future of their place, and areas identified for improvement. Any data or statistics contained within them which has since been updated will be reviewed as part of the LDP3 Settlement Audit work. The Audit will also consider if progress has been made against the key issues and actions identified, and how those issues and actions compare to the feedback gathered through the Big Place Conversation. LDP2 Infrastructure Capacity Studies were only carried out for the larger settlements within Perth and Kinross. However, our Settlement Audit work for LDP3 will consider all settlements across the area. • Scottish Index of Multiple Deprivation (SIMD) - SIMD data zones in rural areas tend to cover a large land area and reflect a more mixed picture of people experiencing different levels of deprivation. This means that SIMD is less helpful at identifying the smaller pockets of deprivation found in more rural areas, compared to the larger pockets found in urban areas. SIMD domain indicators can still be useful in rural areas if analysed separately from urban data zones or combined with other data. Given the rural nature of much of Perth and Kinross, it will be important to keep this limitation in mind when considering rural areas as part of our Local Living and 20 Minute Neighbourhoods analysis work. • Settlement Audits - It is planned as part of the Settlement Audit work for LDP3 to develop a Localities Profile template which will set out those factors which officers need to take account of in developing their understanding of each place and its needs to satisfy the requirements of the Planning Act, Regulations, LDP Guidance and NPF4 policies. This should also help inform work on Local Living and 20 Minute Neighbourhoods required under NPF4 Policy 15. The template has yet to be developed but will be in place prior to work beginning on the Proposed Plan. • Scottish Living Locally Data Portal (SLLDP) - The data included in the Portal utilises sources produced between 2020 and 2022. Whilst most of the facilities and services mapped are likely to still be available, public transport provision has changed significantly in recent years. The indicators of access to public transport networks and high frequency services can offer a good understanding of the connectivity available for residents but would benefit from more recent data to enhance the accuracy of assessments. The Portal utilises the same data zones as the SIMD. While they provide a helpful framework to understand access to services within
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145 urban and semi-urban settlements, the SLLDP offers limited information for rural areas. The development of 20 Minute Neighbourhood assessment methodologies will need to consider these limitations. Currently, not all the information regarding the facilities and services on offer in our communities is currently mapped in GIS. This will require to be carried out as part of our LDP3 Settlement Audit work to allow for analysis in terms of local living and 20-minute neighbourhoods to be undertaken. • Public Conveniences - Regarding the Council’s list of public toilets, there is the intention to undertake a future review of the provision of these facilities. However, there is no timeframe currently for when such a review will be carried out. Statements of Agreement and/or Dispute: A total of 17 responses were received on our Local Living and 20 Minute Neighbourhoods Topic Paper. A full summary of these comments, their status, and the Council’s response are provided in the table relevant table under this issue in Appendix B. A breakdown of those responses grouped under stakeholder categories is provided below. • Key Stakeholders: o Historic Environment Scotland agreed and further commented that they welcome the references in the topic paper to the Council’s Placemaking Guide, and the commitment to update it. o Nature Scot, neither agreed nor disagreed, but flagged the omission of the reference to the Scottish Government’s ‘Creating Places: A policy statement on architecture and place for Scotland’ being carried through from the summary of implications of evidence to the list of evidence and datasets. o Tactran Regional Transportation Partnership agreed and overall welcomed the detail set out in Topic Paper 018, and provided advice on the key transport related considerations which the Council should consider in developing our LDP3 Spatial Strategy in order to deliver connected places which are accessible for everyone. o Perth and Kinross Council Transportation and Development Team, neither agreed nor disagreed with the list of evidence and summary of implications, but did highlight the importance of Action 153 of the Council’s Mobility Strategy and Action Plan to the development of the Proposed Plan. o Scottish Water, neither agreed nor disagreed and commented that they welcome a best practice approach on water efficiency across the Plan Area, and the reference under the topic paper to the use of blue-green assets as a key design feature for new and existing developments. • Community Councils: 2 responses were received from Community Councils. One agreed with the list of evidence reviewed and summary of implications for the Proposed Plan provided, while the second Community Council wished to register their comments as a formal dispute, stating their disagreement based on their village being part of the Local Action Plan for Eastern Perthshire, which jeopardises the opportunity for their area to access facilities and services under the local living concept.
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146 • Public At Large: 2 responses were received on the topic paper. One from a private individual who wished to register their comments as a formal dispute to the Evidence Report, as in their view Topic Paper 018: Design, Quality and Place, objecting to the evidence gathered arguing that the 20-minute neighbourhood concept does not address community, social and family considerations. The second comment stated disagreement with the implementation of the ’20-minute city’ concept, but did not with for comments to be registered as a formal dispute to the Evidence Report. • Landowners and Agents: 6 responses were received on Topic Paper 019. 3 disagreed with the list of evidence / datasets and / or the implications for the Proposed Plan o 1 response (A.S. Associates Ltd. Planning and Architectural Services) disagreed with the list of evidence/ datasets reviewed in relation to the upcoming Site Appraisal and Settlement Audit work mentioned in the relevant topic paper, and the lack of information on which datasets will be used to provide evidence for this area of work. However, the respondent did not wish for their comments to be registered as a formal dispute to the Evidence Report. o 1 response (Avison Young) disagreed with the list of evidence / datasets provided, commenting on the lack of clarity regarding the implications for the plan at the topic paper stage, and the limitations of providing comments without settlements audits being made available. The respondent did not wish for their comments to be registered as a formal dispute to the Evidence Report. o 1 response (Gray Planning) disagreed with the list of evidence / datasets provided, highlighting the lack of Local Place Plans at the time of consultation. This was considered an obstacle for consultees to form their feedback. The respondent did not wish for their comments to be registered as a formal dispute to the Evidence Report. 2 responses were received which neither agreed nor disagreed, and a further 1 response agreed with the list of evidence and summary of implications for the Proposed Plan. • Other Bodies: 2 responses were received on this topic o Homes for Scotland disagreed on the summary of implications for the Proposed Plan provided. Their comments focus on the need to recognise the role that housebuilders play in the delivery of infrastructure and communities; the requirement to be flexible in the application of local living and 20 minute neighbourhood concepts; the opportunity for larger mixed use housing developments to create neighbourhoods aligned with NPF4 aspirations; the need for infrastructure and services to improve prior to considering the use of local living concepts in rural areas; and the expectation for land allocation for housing in town centres to be cognisant of viability factors and placemaking. The respondent did not wish for their comments to be registered as a formal dispute to the Evidence Report. o 1 response (Kinross-shire Civic Trust) neither agreed nor disagreed with the list of evidence / datasets and / or the implications for the Proposed Plan The Provision of Public Conveniences Section 15(2A) of The Town and Country Planning (Scotland) Act 1997, as amended requires a statement of the planning authority’s policies and proposals as to the provision of public conveniences.
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147 With regards to provision within the Perth and Kinross Council (PKC) Area, whilst the provision of public toilets is not a statutory function, it is recognised that in an area like Perth and Kinross, which benefits from a thriving tourist industry, it is preferrable to have facilities available. This has been reflected through historic committee papers and budgetary decisions throughout the years. Currently, a review of PKC run facilities and provision is being planned. In the interim, until that review has been conducted, the Council operates 7 public toilets (a mixture of attended and unattended), a further 1 is provided for public use through a community development trust, and PKC also runs a ‘Comfort Scheme’ with facilities available to the public to use at no cost at 32 partnership venues across the area. The Provision of Water Refill Locations Section 15(2B) of The Town and Country Planning (Scotland) Act 1997, as amended requires a statement of the planning authority’s policies and proposals as to the provision of water refill locations. Regarding water refill locations, Perth and Kinross Council manages and maintains a long list of water stations across the Plan Area. Most of these points are located within premises operated by the Council, such as education and community facilities, and access to them is limited to users and staff associated with these locations. Whilst the current provision is considered to cater for the needs of users of public premises, the Council will keep under review the requirement for the provision of additional water points in locations where an identified need is demonstrated.
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148 ISSUE: BLUE AND GREEN INFRASTRUCTURE Links to Evidence: General Scotland’s Environment Web SEPA – Environmental Data NatureScot – Open Data Hub Scottish Wildlife Trust – Open Data Hub Improvement Service – Spatial Hub Scottish Government – Spatial Data Portal Perth and Kinross Council – Open Data Perth and Kinross Council – LDP2 Webmap Scotland 2022 Landcover Map Scotland’s Wetland Inventory Scottish Index of Multiple Deprivation Audits, Policy and Strategy Perth and Kinross Council, (DRAFT) Open Space Quality Audit [Core Doc Ref:] Perth and Kinross Council, Green and Blue Infrastructure Supplementary Guidance Perth and Kinross Council, Open Space Provision for New Developments Supplementary Guidance Perth and Kinross Council Forest and Woodland Strategy Perth and Kinross Council Food Growing Strategy Perth and Kinross Council, Climate Change Projections Map Perth and Kinross Council, Perth Integrated Catchment Study Scottish Government, Surface Water Management Planning Guidance (2018) Scottish Government, Water-Resilient Places Perth and Kinross Council Mobility Strategy and Action Plan Perth and Kinross Council Active Travel Strategy Woodland Ancient Woodland Inventory Ancient Tree Inventory National Forest Inventory Native Woodland Survey of Scotland Riparian Woodland Scotland Designated and Protected Sites Cairngorms National Park Loch Lomond and the Trossachs National Park National Nature Reserves National Scenic Areas RAMSAR Sites Special Areas of Conservation Special Protection Areas Sites of Special Scientific Interests Scottish Wildlife Trust Reserves Gardens and Designed Landscapes Perth and Kinross Council. Tree Preservation Orders Perth and Kinross Council, Air Quality Management Areas Existing Greenspace Areas Perth and Kinross Council, Maintained Open Space Perth and Kinross Council, Major Parks Perth and Kinross Council, Parks Countryside Sites Perth and Kinross Council, Local Development Plan 2 Designated Open Space Ordnance Survey (OS), MasterMap Greenspace
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149 Water Environment Ordnance Survey (OS), MasterMap Water Network SEPA, Recommended Riparian Buffer SEPA, Riparian Vegetation Planting Opportunities SEPA, Obstacles to Fish Migration SEPA, Water Environment Hub SEPA – Water Classification Hub PKC (Internal Shapefile), Sustainable Urban Drainage Systems [Core Doc Ref:?] Flooding and Geomorphic Risk SEPA, Surface Water Flood Risk SEPA, River Flood Risk SEPA, Coastal Flood Risk SEPA, Geomorphic Flood Risk SEPA, Natural Flood Management Maps PKC – Strategic Flood Risk Assessment [Core Doc Ref:?] PKC – Surface Water Management Plans [Core Doc Ref:?] o Milnathort o Blairgowrie & Rattray (ongoing) o Perth (ongoing) o South Kinross (TBC) PKC – Natural Flood Management Studies[Core Doc Ref:?] o Aberfeldy o Blackford o Comrie o Invergowrie o South Kinross Active Travel Network Perth and Kinross Council, Adopted Core Paths Perth and Kinross Council, Signposted Paths Perth and Kinross Council, Rights of Way PKC (Internal Shapefile) – Future Potential Routes (for footpaths) [Core Doc Ref:?] Sustrans, National Cycle Routes Sustrans, National Cycle Network Link Sustrans – Regional cycle Routes Sustrans (Internal Shapefile) – Green Routes [Core Doc Ref:?] Ramblers, Path Network Scotland Tactran, Regional Active Travel Network PKC, Perth Cycle Network Masterplan Neighbouring Authorities Datasets: o Core Paths – Scotland o Specific Routes: - Cateran Trail - Loch Leven Heritage Trail - Crieff to Comrie (Pilgrim’s Way) - Crook of Devon to Kinross via Balado Opportunities for Intervention Perth and Kinross Local Development Pland 2 Proposals Perth and Kinross Council, Maintained Open Space Perth and Kinross Council, Grow Wild Sites PKC (Internal Shapefile) – Disused Railway Lines [Core Doc Ref:?] PKC (Internal Map) – Urban Capacity and Brownfield Study [Core Doc Ref:?] Vacant and Derelict Land Survey 2022 SEPA, Water Environment Fund Current and Potential Projects Perth and Kinross Council, Nature Restoration Fund Projects Perth and Kinross Community Groups and Projects Map
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150 Perth and Kinross Environmental Youth Groups and Projects Map Perth and Kinross Council, LDP3 Big Place Conversation Results Local Place Plans Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix B to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Open Space Quality Audit - At the time of writing the Open Space Quality Audit has not been finalised. The audit is expected to be completed in summer of 2025, with the Open Space Strategy to follow at the end of the year. • Green and Blue Infrastructure (GBI) – GBI was mapped for the Blue and Green Infrastructure Supplementary Guidance. This will be reviewed and updated to consider the information sources mentioned in this paper alongside wider public and stakeholder input. As there will be no statutory guidance documents anymore, it is considered that the mapping will need to be in the LDP Proposed Plan in some form. • Nature Networks - Both the Green Infrastructure mapping and Open Space Audit will address accessibility and connectivity. This will be supplemented by consideration of nature networks to develop green networks. Prioritisation of how green networks connect people and nature to green spaces and through settlements will be developed through discussion with key stakeholders and communities as the Plan is developed. An initial consultation on priorities for nature networks is taking place alongside the consultation on topic papers. Enhancement Delivery - Identifying and protecting blue and green infrastructure and green networks in the Local Development Plan is the first stage. This will also help development deliver opportunities and connections as part of site planning. NPF4 Policy 3 requires development to deliver enhancement for biodiversity and this may raise opportunities for the realisation of green networks both on and offsite. Offsite delivery however is limited by the current law around planning conditions and in some cases may be difficult to secure until such time that new legal mechanisms are in place. Planning Circular 4/1998: the use of conditions in planning permissions sets out 6 tests for conditions as on several occasions the Courts have laid down the general criteria for the validity of planning conditions. In addition to satisfying the Courts' criteria for validity, conditions should not be imposed unless they are necessary and effective, relevant to the development to be permitted and do not place unjustifiable burdens on applicants. This limits the scope for requiring enhancement particularly where it is offsite.
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151 Statements of Agreement and/or Dispute: 12 responses were received on our Blue and Green Infrastructure Topic Paper. Most respondents (9 out of 12) either agreed with or had no comment to make on the evidence identified through Topic Paper 022, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and/or highlighted other potential implications for the Proposed Plan. There were no responses on the Blue and Green Infrastructure issue which the respondents wished to be treated as a formal dispute to the Evidence Report. Two respondents disagreed with the sufficiency of the list of evidence, and one disagreed with the implications of the evidence for the Proposed Plan. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Blue and Green Infrastructure issue in Appendix B. • Key Stakeholders: o NatureScot, neither agreed nor disagreed. o Tactran, neither agreed nor disagreed. o Scottish Water, agreed. o SEPA, disagreed that sufficient evidence was included in the topic paper to identify blue networks but did not wish their response to be treated as a formal dispute. • Community Councils: 2 responses, 1 agreed and the other neither agreed nor disagreed. • Public at Large: 1 anonymous response from a member of the public, disagreed but did not wish to register as a formal dispute. • Landowners and Agents: 2 responses, neither of which agreed nor disagreed. • Other Bodies: o Homes for Scotland, disagreed with the summary of implications of the evidence but did not wish to register as a formal dispute. o Kinross-shire Civic Trust, neither agreed nor disagreed. o PKC Transport Planning, neither agreed nor disagreed.
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152 ISSUE: PLAY, RECREATION, AND SPORT (INCLUDING PLAY SUFFICIENCY ASSESSMENT) Links to Evidence: National / Local Policy Context Active Scotland Outcomes Framework Play Strategy for Scotland (2013) Progress Review of Play Strategy Physical Activity for Health: Scotland’s National Framework Perth and Kinross Council Corporate Plan (2022-2027) Existing Facilities SportScotland Facilities Report (2024) Perth and Kinross Council, Location of Existing Play Areas Perth and Kinross Council, Play Area Improvements Perth and Kinross Council, Leisure Centres and Swimming Pools Perth and Kinross Council, Council Decision on Leisure Assets in Perth Perth and Kinross Council, Public Consultation on the Future of Bells Sports Centre Perth and Kinross Council, Pitlochry Asset Review Council Committee Decision Perth and Kinross Council, Location of Existing Outdoor Sports Pitches PKC - Policy on Provision for Outdoor Sports (2017) Perth and Kinross Council, Major Parks Perth and Kinross Council, Open Space Areas Perth and Kinross Council, Skate Park Facilities Perth and Kinross Council, Community Sport Hub Facilities Perth and Kinross Council, Paths and Trails Perth and Kinross Council, Core Paths Perth and Kinross Council Water Safety Policy PKC Policy – Asset Management Perth and Kinross Council, Transformation Review of Leisure Assets Perth and Kinross Council, Transformation Review of Leisure Assets - Appendix Perth and Kinross Council, Transformation Review - Minute of Meeting Perth and Kinross Council, Committee Report - Perth City (2024) Perth and Kinross Council, Committee Report - Perth City (September 2024) Perth and Kinross Community Green Asset Management Plan (2017-2022) PKC Policy – Enhancing Opportunities for Play, Recreation and Sport Perth and Kinross Physical Activity and Sport Strategy (2023-2028) Play Framework for Perth and Kinross (2019-2022) Understanding Need SportScotland Facilities Planning Modelling Play Sufficiency Assessment - Regulations Play Sufficiency Assessment - Guidance Perth and Kinross Council, Play Sufficiency Assessment Perth and Kinross Council, LDP3 Big Place Conversation Perth and Kinross Council, LDP3 Big Place Conservation Results Scottish Index of Multiple Deprivation data Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix B to this Evidence Report.
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153 Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • The provision of opportunities for play, recreation and sport is an evolving process as demonstrated by the asset review across the Council area. Close collaboration with relevant partners will be key to ensuring that the next LDP incorporates the most accurate information and provides an appropriate spatial strategy and policy framework to promote opportunities for play, recreation and sport. • SportScotland Data - SportScotland Facilities Report (2024) is dependent upon feedback from key stakeholders and therefore may not be complete/accurate. This information is used alongside existing local information and datasets, including evidence presented above under ‘Existing Assets’. SportScotland Facilities Planning Modelling (2024) is based on modelling and not actual usage of facilities, and demand levels are based on national surveys. To support an accurate as possible evidence base on facilities modelling, local data held by PKC and Live Active Leisure (as operators) is used to determine existing and modelled usage. • Play Sufficiency Assessment (PSA) Limitations - The PSA does not include privately managed equipped play areas. These will be identified, assessed, and included in the PSA outputs to help address the gaps in provision and accessibility. The current Playground Strategy considers the 4-8 and 8-14 age groups. This has resulted in a data gap regarding provision of activities for children and young people out with this range. The Strategy recognises there will be children on either side of the 4-14 target age range that will use the equipment, but that younger children require more supervised facilities, such as nurseries, and older children seek other forms of play such as sporting, cycling and skating opportunities. The PSA only includes equipped playgrounds. Statements of Agreement and/or Dispute: 8 responses were received on our Play, Recreation and Sport Topic Paper. Most respondents (6 out of 8) either agreed with or had no comment to make on the evidence identified through Topic Paper 022, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered. There was 1 response on the issue which the respondent wished to be treated as a formal dispute to the Evidence Report. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Play, Recreation and Sport issue in Appendix B. • Key Stakeholders: o NatureScot, neither agreed nor disagreed.
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154 o Scottish Water, neither agreed nor disagreed o SportScotland, disputed the sufficiency of the list of evidence / datasets identified in the topic paper and wish for their comments to be registered as a formal dispute. • Community Councils: 2 responses were received, 1 agreed and the other disagreed (Earn Community Council) but did not wish their response to be treated as a formal dispute • Public at Large: 1 response, neither agreed nor disagreed. • Landowners and Agents: 2 responses, neither of which agreed nor disagreed. • Other Bodies: No comments. Assessment of Sufficiency of Play Opportunities: Part 2, Section 16D(1) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to include an assessment of the sufficiency of play opportunities in its area for children. This is delivered through the preparation of the Council’s Play Sufficiency Assessment.
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155 ISSUE: FLOOD RISK AND WATER MANAGEMENT (INCLUDING DRAINAGE AND WATER SUPPLY SYSTEMS) Links to Evidence: Flood Risk Strategic Flood Risk Assessment [Core Doc Ref: CD25] SEPA Future Flood Maps SEPA Low likelihood (Present Day) Surface Water Flood Risk Mapping Planning Information Note 4 (PIN4) SEPA Position on Development Protected by a Flood Protection Scheme SEPA Flood Risk Standing Advice for Planning Authorities (July 2024). Scottish Government Flood Resilience Strategy (December 2024) Scottish Water's Climate Adaptation Plan 2024 SEPA Flood Risk and Land Use Vulnerability Guidance Strategic Environmental Assessment: Development Plan Site Assessment Tay Flood Risk Management Plan (December 2021) Forth Flood Risk Management Plan (December 2021) Forth Estuary Flood Risk Management Plan (December 2021) Tay Estuary and Montrose Basin Flood Risk Management Plan (December 2021) Tay Local Flood Risk Management Plan (December 2022) Forth Local Flood Risk Management Plan (December 2022) Forth Estuary Local Flood Risk Management Plan (December 2022) Tay Estuary and Montrose Local Basin Flood Risk Management Plan (Interim issue May 2019) Mapping flood disadvantage in Scotland 2015 SEPA, Explanatory note on the difference between our planning guidance and the Future Flood Maps, Version 4 (November 2023) Big Place Conversation Summary Report Climate Change and Coastal Changes Dynamic Coast Webmaps (2021) Coastal Change Adaptation Guidance Climate Change Risk and Opportunity Assessment (August 2023) Climate Change Master Action Plan (August 2023) [Core Doc Ref: CD6] River Basin Management Plans for Scotland (December 2021) Recommended Riparian Corridor Layer for use in Land Use Planning (July 2024) (Core Doc Ref: CD23) Water Environment SEPA, Water Environment Hub SEPA, Water Classification Hub River Basin Management Plans for Scotland (December 2021) Drinking Water Protected Areas - Scotland River Basin District Maps Private Water Supplies SEPA information on Water Scarcity Water Scarcity in Scotland (arcgis.com) (November 2023) knowledge review on water scarcity by University of Dundee James Hutton Institute Executive Summary of Climate Trends (July 2023) CREW (Centre for Expertise for Waters) Report, Private Water Supplies and Climate Change PKC call out records to private water supplies which have previously dried up [Core Doc Ref:CD24]
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156 Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix B to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Flood Risk - Whilst if a site is within an at-risk area, the NPF4 policy approach is clear, if a site is partially within, the approach is still clear, but what is unclear until you get to the planning application stage is which areas are within the at-risk area. Also, whilst SEPA medium likelihood future flood risk 2080 river and coastal flood risk mapping is the best proxy for the at-risk flood risk areas mentioned in NPF4, this is currently based on UK 2009 Climate projections but will be updated to reflect the UK 2018 climate change projections. If this updated climate change mapping is available this will be used in site assessment for the Proposed Plan. Should the Proposed Plan promote sites where a potential flood risk is identified on part of the site, then it will be necessary to assess them using the allowances to calculate the area “at risk of flooding or in a flood risk area” and this will clarify the developable area. To address this gap during the preparation of the Call for Sites and Ideas the Council will require the developer/landowner to prepare a Flood Risk Assessment (FRA) where there is a potential risk of flooding within a site, to determine if it is suitable for allocation. Consideration of the research on mapping flooding disadvantage suggests to properly implement policy and limit the instances of development within at risk/floodplain areas, there could be an enhanced focus on member engagement on flood risk matters. One of the other reasons mentioned (of sites taking time to come forward and being based on an older FRA) is largely outwith the Local Authorities control. However, the approach taken at LDP2 site MU73: Almond Valley, whereby on this long term strategic site, the overall masterplan permission requires each phase which comes forward as a planning application to be based on a new FRA could be a way to mitigate this issue. • Water Environment - Findings of the Strategic Flood Risk Assessment (SFRA) help identify some potential opportunities to implement improvements to the water environment through natural flood management and blue green infrastructure. However, the Proposed Plan Spatial Strategy will identify and protect blue and green infrastructure assets and networks (via the Planning (Scotland) Act 2019, and subsequently NPF4); and seek to enhance and expand existing provision including new blue and/or green infrastructure. Blue and Green Infrastructure is considered in more detail in Topic Paper 021, and the related issue of this Evidence Report.
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157 • Private Water Supplies - The drought indicator method has not been developed to assess individual Private Water Supplies and is not provided at a finely grained resolution (12 Km). However, the drought indicator alongside other water scarcity mapping, and Council call out records for water scarcity, could prove a useful starting point to determine vulnerable locations. It could potentially help identify where a Private Water Supplies risk assessment procedure considering climate change related risks is required and/or where/when a planning response and mitigations may be required. Statements of Agreement and/or Dispute: 18 responses were received on our Flood Risk and Water Management Topic Paper. Over 40% of the respondents either agreed with or neither agreed nor disagreed with the evidence identified through Topic Paper 023, or the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and/or highlighted other potential implications for the Proposed Plan. 3 respondents wished their comments to be treated as a formal dispute to the Evidence Report, a further 6 indicated some disagreement with the evidence. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Flood Risk and Water Management issue in Appendix B. • Key Stakeholders: o NatureScot, neither agreed nor disagreed o Scottish Water, agreed o SEPA, disputed the draft SFRA and wish for their comments to be registered as a formal dispute due to the absence of the mapped output from the detailed studies. • Community Councils: 2 responses, both of which neither agreed nor disagreed. • Public at Large: 6 responses, 1 which agreed, 3 which disagreed but did not wish for their comments to be recorded as formal disputes, 2 which disputed the evidence and wish for their comments to be registered as a formal dispute. 1 in the grounds that they consider the Craigie Burn Flood Study must be redone using flow rate figures agreed with residents who have knowledge in this field, and one because the topic paper does not mention ‘deforestation’ for development impacting both surface water and subterranean water flows, nor address the impact of proposed and existing development on subterranean aqua flows especially in the Scone area. • Landowners and Agents: 6 responses, 1 of which agreed, 3 neither agreed nor disagreed, and 2 which disagreed but did not wish for their comments to be recorded as a formal dispute (Montague Evans on behalf of Loch Developments Ltd, and Stuart Buchanan on behalf of Cardross Asset Management Ltd)
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158 • Other Bodies: Homes for Scotland, disagreed but do not wish to register as a formal dispute.
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159 ISSUE: HEALTH AND SAFETY Links to Evidence: Perth and Kinross Local Development Plan (2019): maps shown in Appendix 3 pages 338-346 Health and Safety Executive (HSE)'s Planning Advice Web App United Kingdom Onshore Pipeline Operators’ Association Good Practice Guides Suicide Prevention Action Plan National Guidance on Action to Address Suicides at Locations of Concern Perth Air Quality Action Plan (2009) Crieff Air Quality Management Area revocation order Air Quality Annual Progress Report (2024) Perth and Kinross Local Development Plan Airfield Safeguarding Supplementary Guidance (2020) Scottish Government Planning Circular 2/2003 (revised) safeguarded aerodromes, technical sites and military explosives areas Mining Remediation Authority Planning maps Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix B to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Safeguarding Zones around major hazard sites, major accident pipelines, and airfields will need to be checked to ensure they remain appropriate. • Locations of concern for suicide risk will need to be sensitively taken into consideration when preparing the Proposed Plan. • Once published, the measures contained in the Perth Air Quality Management Plan will need to be incorporated into the Proposed Plan. Statements of Agreement and/or Dispute: 3 responses were received on our Health and Safety Topic Paper. 1 response was from The Coal Authority (now the Mining Remediation Authority) who neither agreed nor disagreed with the list of evidence and summary of implications; 1 submitted on behalf of Shell UK, one of the major hazard pipeline operators, who agreed; and the other on behalf of a Community Council who neither agreed nor disagreed. There were no responses that the respondents wished to be treated as a formal dispute to the Evidence Report. A full summary of these comments, their status, and the Council’s response is provided in the relevant table under the Health and Safety issue in Appendix B.
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160 HOMES
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161 HOMES 5.5.1 Although the ‘Homes’ issue is grouped within the Liveable Places theme of NPF4’s suite of National Planning Policies, i.e. Policy 16: Quality Homes and Policy 17: Rural Homes, given the significance of this issue to the overall development of the Proposed Plan, it was considered useful to set out the key information relating to the consideration of the evidence and engagement feedback for this subject under a separate section. 5.5.2 The pages to follow provide an overview of the identified likely implications of the collated evidence for the Homes issue for the preparation of the Proposed Plan, any gaps, uncertainties or key issues in the evidence gathered, and a summary of agreement, and/or disputes related to the evidence which were received through our programme of participation and engagement reported under Section 3. 5.5.3 In terms of the requirements of the Planning Act, in the preparation of this Evidence Report, the Council is expected to provide its views on the housing needs of the population of the Plan Area (including, in particular, the needs of persons undertaking further and higher education, older people, and disabled people); the availability of land within the area for housing (including for older people, and disabled people), and the desirability of allocating land for the purposes of resettlement. 5.5.4 The Council is also expected to provide a summary of action taken to support and promote the construction and adaptation of housing to meet the housing needs of older people and disabled people in their area, and an analysis of the extent to which the action has helped to meet those needs, and also the action taken by the Council to meet the accommodation needs of Gypsies/Travellers in the Plan Area, and an analysis of the extent to which the action has helped to meet those needs. 5.5.5 The specific requirements outlined under paragraphs 5.5.3 and 5.5.4 above have been addressed under the Homes issue to follow, after the ‘Statements of Agreement and/or Dispute’ section.
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162 ISSUE: HOMES Links to Evidence: Housing to 2040 Perth and Kinross HMP HNDA Final Report NPF4 Annex E MATHLR NPF4 Perth and Kinross MATHLR Assessment Report [Core Doc Ref: CD26] TAYplan2 Strategic Development Plan Examination Report Perth and Kinross LHS Framework 2022-27 Perth and Kinross LHS 2022-2027 Appendix: HST 2022+ Perth and Kinross LHS 2022-27 Annual Progress Report 2022/23 and 2023/24 PKC SHIP 2025/26 – 2029/30 PKC STLs Evidence Research Report Existing Housing Need in Perth and Kinross – Report commissioned by Homes for Scotland Extract from the PKC Self and Custom Build Register [Core Doc Ref: CD27] Perth and Kinross HLA – 2022 [Core Doc Ref: CD 28] and 2023 Edinburgh City Council HLA and Completions Programme 2022 p.11-13 Briefing Paper: The Barriers to Housing Delivery The Scottish Land Commission: The role of land in enabling new housing supply in rural Scotland Planning and the Housing Emergency – Delivery Plan Perth and Kinross LDP2 BPC - Results Gypsy Travellers – Double Dykes Human Rights Monitoring Report [Core Doc Ref: CD 29] Gypsy Travellers – Double Dykes Second Human Rights Monitoring Report [Core Doc Ref: CD 30] Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Short Term Lets - More analysis is needed on the impact of residential properties as holiday accommodation. Data will become available on the potential for impact from the higher Council tax levy on second homes and the STL Licencing requirements on properties moving from STLs to second homes to inform the preparation of the final LHLR in the Proposed Plan. • Gypsy/ Travellers and Travelling Showpeople - A specific instruction in NPF4 is for LDPs to allocate land for Gypsy / Travellers and Travelling Showpeople where need is identified. The Housing Needs and Demand Assessment (HNDA) concluded that over a 5- year period there would be a -2 shortfall to +4 surplus in permanent Gypsy/Traveller site pitches. This was, however, based on 2016 data and is qualified by uncertainties in estimating demand. In relation to Travelling Showpeople, the HNDA referred to the then draft 2022-27 Local Housing Strategy (LHS) which had
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163 no evidence on the needs of Travelling Showpeople to support estimating future requirements. It is acknowledged that the data relating to the accommodation needs of Gypsy / Travellers and Travelling Showpeople is in need of updating. An updated needs assessment is programmed to be carried out 2025/26 and the Council is exploring the possibility of working with neighbouring authorities on this. The updated need assessment will inform the final LHLR in the Proposed Plan. • Deliverability of Land Supply - Every year the audit is discussed with Homes for Scotland with a view to achieving consensus on individual site programming. With the changes brought about by the new planning system it was a more complicated process when discussing the 2023 HLA, especially given that the 10-year housing land pipeline is not yet in place. As a result, it was not possible to reach agreement on the programming of four sites within the 2023 audit, all of which Homes for Scotland consider constrained and should not be programmed within the 10-year period. Whilst this is far from ideal there will be further opportunities for discussion with Homes for Scotland and their members through the preparation of subsequent audits which will inform the preparation of the final LHLR in the Proposed Plan. The consideration of factors affecting delivery as used by Edinburgh City Council is still at an early stage and only some sites in the HLA have been discussed in draft form with Homes for Scotland as a pilot exercise in 2023. This highlighted that it may be appropriate to adapt the Edinburgh approach to more closely reflect some of the factors applicable in Perth and Kinross before rolling this out as a formal part of the HLA process. It is proposed that this will be carried out for future HLAs and will therefore be in place to inform the final Local Housing Land Requirement (LHLR) in the Proposed Plan. Statements of Agreement and/or Dispute: 11 responses were received on the Homes Topic Paper. Just over half of respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 020, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and / or highlighted other potential implications for the Proposed Plan. There were 3 responses on the issue which the respondents wished to be treated as a formal dispute to the Evidence Report. A full summary of these comments, their status, and the Council’s response are provided in the table relevant table under this issue in Appendix C. A breakdown of those responses grouped under stakeholder categories is provided below. • Key Stakeholders: o Tactran Regional Transportation Partnership did not specifically state in their response for their agreed or disagreed with the list of evidence considered and summary
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164 of implications provided. Under the further comments section of the engagement questionnaire they noted that it is difficult to understand the scale of the problem and the potential impact new development can have on quality homes without knowing the baseline data in relation to (traffic related) noise levels, air quality (especially in declared Air Quality Management Areas (Perth and Crieff), and accident statistics. o Scottish Water, neither agreed nor disagreed and made no comments with regard to the Homes Topic Paper. • Community Councils: 3 responses, 2 agreed and the third neither agreed nor disagreed • Public At Large: 1 response which disputed the evidence and wish for their comments to be registered as a formal dispute on the grounds that that using data from a self-interested source – Homes for Scotland – distorts the report. • Landowners and Agents: 4 responses, 2 of which neither agreed nor disagreed, 1 (Ristol Consulting) which disagreed but did not wish for their comments to be recorded as a formal dispute, and 1 (Savills on behalf of Scone Estate) which disputed the evidence and wish for their comments to be registered as a formal dispute on the grounds that: data to be used to reflect Self and custom build demand/need, a lack of acknowledgement of the facilitatory role of housing in meeting other spatial strategy aims, and the need for a balanced approach to use of NPF4 policies to ensure appropriate and increased delivery of rural housing.. • Other Bodies: Homes for Scotland wish to formally dispute the evidence and summary of implications for the Homes issue of this Evidence Report on the grounds that the MATHLR is to be exceeded. The Housing Needs of the Population of the Area Part 2, Section 16B(3) and Section 15(5)(ca) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to set out their views on the housing needs of the population of the area (including, in particular, the needs of persons undertaking further and higher education, older people, and disabled people). With respect to the Perth and Kinross Area, the Housing Needs and Demand Assessment (HNDA) calculation combines the components of housing need to create a 20-year range of housing estimates for Perth and Kinross as follows: • There is an estimated need for around 5,400 – 6,500 houses over the 20-year period of the HNDA. • Approximately 1,500 households may require housing for older people. • Up to 3,200 households may require a more accessible form of housing, 640 households may require wheelchair accessible housing. • There is a backlog demand of 50 students in education requiring accommodation. The Availability of Land for Housing Part 2, Section 16B(3) and Section 15(5)(cb) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to set out their views on the availability of land in the district for housing, including for older people, and disabled people. With respect to the Perth and Kinross Area, there is an agreed land supply for housing of nearly 17,000 units. This means that, in very simplistic
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165 terms, there is enough non-constrained housing land to last nearly 20 years at a build rate of 850 units per year (the annualised MATHLR). This is almost double the 10-year LDP period. It is acknowledged, however, that this is not a straightforward calculation and that ultimately it is the bringing forward for development of that non-constrained land supply which results in the end delivery of houses on the ground. Construction and Adaptation of Housing Part 2, Section 16B(3)(b)(i) and (ii) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to provide a summary of the action taken by them to support and promote the construction and adaptation of housing to meet the housing needs of older people and disabled people in their area, and an analysis of the extent to which the action has helped to meet those needs. With respect to the Perth and Kinross Area, the Local Housing Strategy (LHS) and Strategic Housing Investment Plan (SHIP) are the primary vehicles for the delivery of housing for specific groups which require affordable housing. The LHS Annual Progress Report discussed in the summary of evidence section sets out the achievements so far in relation to meeting the needs for affordable housing generally, and of older people and disabled people in Perth and Kinross specifically. As identified in the SHIP, the Council is committed to increasing the supply of wheelchair accessible housing and is aiming for 10% of homes built to be suitable for people with particular needs where this can be met within affordable housing development sites. Existing LDP2 Policy 22: Particular Needs Housing Accommodation supports proposals for residential developments supporting housing for particular needs such as housing for frail or elderly people, people with additional support needs, and housing for varying needs. Houses in multiple occupation are also supported where a need for such accommodation can be demonstrated. In relation to the backlog demand of 50 students in education requiring accommodation, the Draft Perth City Centre Development and Design Framework identifies the ‘University Quarter’ as one of the proposed investment areas for the City. It refers to a new vision for the University Campus ‘Quarter’ which is to provide a new framework which will deliver a new educational facility for primary / secondary / further and higher education in one campus location. This will be developed alongside other ancillary uses, but no reference is made to providing more student accommodation on site. Planning permission was granted in 2019 to convert and extend an existing retail unit in the city centre to student accommodation comprising 47 bedrooms, 30 studios and associated communal facilities but the permission has not been implemented. Further discussion will therefore be needed with the College to understand any outstanding accommodation requirements. Policy 25: Housing Mix requires that the market element of all sites with a total capacity of 20 or more provide an appropriate mix of house types and sizes and meet the needs of smaller households including older people and lower income households by providing at least 10% of their units as one- or two-bedroom homes. This is in addition to any affordable housing
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166 requirements on the site. Furthermore, ‘where there are identified clusters of households with specific housing needs within the settlement, such as housing for wheelchair users, there may be a requirement for up to 10% of the development to be designed to meet these specific identified needs or for the developer to demonstrate that the house is capable of adaptation’. There were no specific site allocations for housing for older people or disabled people in LDP2. These policies have been used in assessing planning applications since the adoption of LDP2. Policy 22 in particular has helped facilitate the development of a residential assisted living scheme for over 55s, a change in house type to allow for a specialist need bungalow to be provided on a larger scheme, assisted living units, and a 10-unit HMO aimed at providing student accommodation. Accommodation Needs for Gypsies/Travellers Part 2, Section 16B(3)(b)(i) and (ii) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to provide a summary of the action taken by them to meet the accommodation needs of Gypsies/Travellers in their area, and an analysis of the extent to which the action has helped to meet those needs. With respect to the Perth and Kinross Area, LDP Policy 21: Gypsy / Travellers’ Sites protects existing authorised sites with a presumption against their conversion to another use. The policy also supports proposals for new permanent sites and temporary short stay sites and sets out the criteria against which such proposals will be assessed. There were no specific site allocations for new Gypsy / Travellers’ sites in LDP2, although the settlement boundary of Greenacres private site was drawn to allow for expansion. Only a small number of planning applications have been submitted relating to Policy 21 during the lifetime of the Plan. Most notably permission was granted for replacement chalets on an existing Gypsy / Travellers site, and permission refused for an extension to another small existing Gypsy / Traveller site on health and safety grounds. The Local Housing Strategy (LHS) Annual Progress Report discussed in the summary of evidence section sets out the achievements so far in relation to meeting the accommodation needs of Gypsies and Travellers in Perth and Kinross. Also, as abovementioned the HNDA data relating to Gypsy / Traveller needs dates from 2016. The 2016 report indicated a need to explore provision of transit sites. As a result, the Council has committed funding to and is currently progressing a 10-pitch transit site in Perth. Although there are no plans in the current Strategic Housing Investment Plan (SHIP) for affordable homes for Gypsy / Travellers, work is progressing to establish the unmet needs of transient Gypsy / Travellers, and working with community members to have a better understanding of their accommodation needs and preferences is identified as an action in LHS. Further detail on this is set out in the Gaps or Uncertainties in Data section of the Homes issue under Appendix C.
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167 INFRASTRUCTURE AND TRANSPORTATION
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168 INFRASTRUCTURE AND TRANSPORTATION 5.6.1 The Town and Country Planning (Scotland) Act 1997, as amended by the Planning (Scotland) Act 2019 [the Act] sets out a number of requirements with regards to the content of the Evidence Report and the issue of Infrastructure and Transportation. These specific requirements are listed below and addressed under the sub-issue headings of Cemetery Provision; Communications and Digital; Education Facilities; Healthcare; Transport, and Water and Wastewater, in the pages to follow. • Part 2, Section 16B(3) and Section 15(5)(cd) - The planning authority’s views on the health needs of the population of the district and the likely effects of development and use of land on those health needs. • Part 2, Section 16B(3) and Section 15(5)(ce) - The planning authority’s views on the education needs of the population of the district and the likely effects of development and use of land on those education needs. • Part 2, Section 16B(3) and Section 15(5)(cg) - The planning authority’s views on the capacity of education services in the district. • Part 2, Section 16B(3) and Section 15(5)(d) - The planning authority’s views on the infrastructure of the district (including communications, transport and drainage systems, systems for the supply of water and energy , and health care and education facilities). • Part 2, Section 16B(3) and Section 15(5)(e) - The planning authority’s views on how that infrastructure is used.
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169 Issue: Infrastructure – Cemetery Provision Links to Evidence: Perth and Kinross Council, Existing Burial Ground Sites Perth and Kinross Council, Future Cemetery Provision Strategy (2016) SEPA Guidance on Assessing the Impacts of Cemeteries on Groundwater Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix D to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that finding suitable land for potential burial ground/cemetery provision will potentially compete with other demands on land such as housing, particularly close to existing settlements. There may be an opportunity for mixed use sites to help deliver cemetery provision alongside other appropriate land uses. The demand for additional burial/cemetery provision will need to inform the spatial strategy for the Proposed Plan to ensure suitable sites are identified, where required. Statements of Agreement and/or Dispute: 2 responses were received on our Infrastructure - Cemetery Provision Topic Paper. Both responses noted that they neither agreed nor disagreed with the list of evidence evaluated and the summary of implications for the Proposed Plan provided, and neither wished for their comments to be registered as a formal dispute to this Evidence Report. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Infrastructure – Cemetery Provision issue in Appendix D. • Key Stakeholders: No comments were received. • Community Councils: 1 response from Aberfeldy Community Council who neither agreed nor disagreed, but did highlight that the Community Council is actively exploring with the Council’s Bereavement Services a new site in Aberfeldy for additional burial provision. • Public at Large: No comments were received. • Landowners and Agents: 1 response from Gray Planning and Development Ltd. on behalf of GS Brown Construction who commented that in the context of LDP3 supporting the identification of potentially suitable sites for extended or new cemetery provision, landowners with assets suitable for a mix of land uses potentially led by housing have a key role and can offer deliverable solutions to this matter. • Other Bodies: No comments received.
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170 Issue: Infrastructure – Communications and Digital Infrastructure Links to Evidence: Ofcom ‘Connected Nations’ 2023 Scotland Report Ofcom ‘Connected Nations’ 2023 Interactive Report Dashboard Perth and Kinross Council, Public Wi-Fi Map Signal Checker – Perth and Kinross Digital Scotland, Superfast Broadband Report 2020 Digital Scotland, R100 Programme Strategy Scottish Government, A changing nation, how Scotland will thrive in a digital world Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix D to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, no data gaps have been identified. The key issues raised are: • the communications and digital infrastructure of the Proposed Plan area has shortcomings, creating competitive disadvantages for local businesses and communities; and • the Proposed Plan will need to encourage initiatives to improve digital connectivity Statements of Agreement and/or Dispute: 1 response was received on our Infrastructure - Communications and Digital Infrastructure Topic Paper. The response gave settlement-specific comments on broadband improvements and noted that they neither agreed nor disagreed with the list of evidence and the summary of implications for the Proposed Plan. There were no formal disputes. Views on the Infrastructure of the Area Under Part 2, Section 16B(3) and Section 15(5)(d)-(e) of the Planning Act 2019, in the preparation of their Evidence Report, planning authorities are required to provide their views on the infrastructure of the plan area, and how that infrastructure is used. Perth and Kinross currently have lower than the national average coverage for full fibre broadband. There is also a network of public Wi-Fi hotspots across the local authority area. Perth and Kinross are ranked 76th of 96 areas in the UK for mobile services coverage (4G/ 5G). With respect to the Perth and Kinross Area the data provided highlights current shortcomings regarding digital connectivity. This creates competitive disadvantages for local businesses and communities, presenting a clear challenge for Perth and Kinross to meet some of its corporate objectives. It will be necessary to establish positions of clear
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171 support to development proposals that enhance digital capacity while observing the principles of sustainable and desirable development.
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172 Issue: Infrastructure – Education Facilities Links to Evidence: • National Records of Scotland o Population Estimates 2022 • Perth and Kinross Council o Learning Estate Strategy 2021 o Learning Estate Management Plan 2021 o Housing Land Audits o Methodology for Calculating Pupil Product Ratio [Core Doc Ref: CD31] • Scottish Government o School Education Statistics 2024 [Core Doc Ref: CD32] o Infrastructure Investment Plan 2025-26 o Pupil Projections 2022-27 Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix D to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Infrastructure requirements, in this case, additional school roll capacity needed to accommodate new development proposals for LDP3 will be assessed by the Council by reviewing individual primary catchment areas and capacity across the relevant secondary cluster. • Forecasting pupil numbers is difficult to undertake with precision. Programming accurate housing completions, via the Housing Land Audit, is essential to planning for investment in the learning estate. Related to programming future development is estimating pupil generation from new developments. • The methodology for calculating the ‘Pupil Product Ratio’ was developed in 2008 and it is proposed this be updated to ensure this forecasting is informed by relevant data. Statements of Agreement and/or Dispute: • 3 responses were received on the Education Facilities section of our Infrastructure Topic Paper, comprising 1 Community Council, 1 Council service, and 1 external stakeholder. A full summary of these comments, their status, and the Council’s response in the relevant table under the Infrastructure – Education Facilities issue in Appendix D. • Officers from Perth and Kinross Council Property Services (Education) provided feedback on Topic Paper consultation and assisted with the preparation of the Evidence Report.
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173 • No disputes were raised. Education Services Capacity Part 2, Section 16B(3) and Section 15(5)(cg) and (e) of the Planning Act 2019, in the preparation of their Evidence Report, require planning authorities to set out their views on the capacity of education services in the plan area, and how that infrastructure is used. The Perth and Kinross Learning Estate comprises 69 primary schools, 11 secondary schools, 1 stand-alone Nursery, and 1 Additional Support Needs (ASN) school. Between 2001 and 2021, the ‘0 to 15’ age group saw the largest percentage decrease (-5.2%). Over the next 10 years, the population of Perth and Kinross is projected to decrease by 3.5% due to natural change (more deaths than births). The number of school-age children in the area is not expected to increase in population projections. • Early Years: Education and Learning Services anticipate that Early Years infrastructure can continue to accommodate children, based on population changes and housebuilding activity. • Primary Schools: latest School Estate Statistics found that some primary schools in Perth and Kinross have particularly low pupil numbers (11 schools at less than 50% of capacity) and some have high capacity (5 schools at 90-100% of capacity), however no schools are currently over-subscribed (roll greater than capacity). • Secondary Schools: latest School Estate Statistics found that secondary school pupil rolls in Perth and Kinross have increased in number since 2017, consistent with patterns across Scotland. There are 11 secondary schools in Perth and Kinross, and the School Estates Statistics found that one school has a roll less than 50% of capacity and one school has a roll 90-100% of capacity, again with no schools currently over-subscribed. • Additional Support Needs: Perth and Kinross have one specialist Additional Support Needs (ASN) school; Fairview School is a purpose-built special education school that serves children and young people aged 3 to 18 years old with profound and complex ASN. The school has a capacity of 65 pupils and operates at full capacity most years. Information on school rolls, pupil projections, and housing completions will be utilised in the preparation of Proposed LDP3. The Learning Estate Strategy, Learning Estate Management Plan, and Corporate Asset Management Plan are relevant in determining Council priorities for investment within certain catchment areas. Revisions or updates to these documents will be referenced as they become available.
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175 Issue: Infrastructure – Health Care Facilities Links to Evidence: • Public Health Scotland o Strategic Plan 2022-25 o General Practice In-hours Activity Visualisation (2024) o Health Impact Assessment guidance o NHS Dental data monitoring (2024) • NHS Inform o Pharmacy service directory o Dental service directory • NHS Scotland o North Regions Regional Asset Management Plan 2019-2029 • NHS Tayside o Director of Public Health Annual Report 2023 o Annual Audit Report 2023/24 (Audit Scotland) o Anchor Strategy 2023 o NHS Tayside new dental patients list • Perth and Kinross Health and Social Care Partnership o Integration Joint Board Strategic Commissioning Plan 2020- 25 o Joint Strategic Needs Assessment 2023 o Primary Care Premises Strategy 2023-2028 o Strategic Delivery Plan 2023-2026 o Perth and Kinross General Practice lists [CORE DOC REF] • Perth and Kinross Community Planning Partnership o Community Plan (LOIP) 2022-2032 Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix D to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Engagement with NHS Tayside and Perth and Kinross Health and Social Care Partnership through the preparation of the Evidence Report identified some uncertainties regarding healthcare premises capacity/ needs for Perth and Kinross. Improved understanding of healthcare infrastructure needs will be developed through working with health authorities in the preparation of LDP3, in terms of NPF4 Policy 18. • Funding options for new healthcare infrastructure, to be identified by the health authorities, will need to be carefully considered when preparing the new spatial strategy for Perth and Kinross, including requirements of developers (financial or in-kind). Healthcare infrastructure is not presently included in the scope of the Council’s developer contributions policy.
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176 Statements of Agreement and/or Dispute: 4 responses were received on the Health Care Facilities section of our Infrastructure Topic Paper. 1 response neither agreed nor disagreed with the list of evidence evaluated or summary of implications for the Proposed Plan provided. 1 disagreed but did not wish for their comments to be registered as a formal dispute to the Evidence Report. 1 agreed, and the other wishes to register their comments as a formal dispute. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Infrastructure – Health Care Facilities issue in Appendix D. • Key Stakeholders: A response was received from Perth and Kinross Health and Social Care Partnership (PKHSCP) on this issue. They neither agreed nor disagreed with the list of evidence reviewed or summary of implications provided. They did however make some points of clarification regarding terminology used and also figures reported for the number of GP practices within Perth and Kinross. PKHSCP also suggested some additional sources of evidence for review. • Community Councils: 1 response from Earn Community Council who agreed with the list of evidence and summary of implications and made some suggestions regarding connections with other NPF4 policies and this issue. • Public at Large: 1 response received, which the respondent wishes to register as a formal dispute to the Evidence Report based on the poor quality of graphics online. • Landowners and Agents: No comments received. • Other Bodies: Homes for Scotland disagreed with the list of evidence evaluated and made some suggestions for additional sources of evidence to include. They did not wish for their response to be registered as a formal dispute to the Evidence Report. Views on the Infrastructure of the Area Under Part 2, Section 16B(3) and Section 15(5)(d)-(e) of the Planning Act 2019, in the preparation of their Evidence Report, planning authorities are required to provide their views on the infrastructure of the plan area, and how that infrastructure is used. Key general healthcare facilities in Perth and Kinross comprise: • 23 General Practices • 36 pharmacies • 27 dental practices • 2 hospitals. With respect to the Perth and Kinross Area there are ample sources of evidence relating to the local population and the health needs in the area. Health agencies are prioritising an approach of ‘prevention’ for improving public health in which the Plan’s Spatial Strategy can align, together with Policy 23 requirements of NPF4. The availability of evidence relating to physical healthcare infrastructure and premises requirements in the Tayside Area is currently limited. Perth
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177 and Kinross Council will utilise data on primary care infrastructure as it becomes available.
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178 Issue: Infrastructure – Transportation (Including Sustainable Transport) Links to Evidence: Scottish Government National Transport Strategy 2 Transport Scotland Strategic Transport Projects Review 2 Scottish Government Climate Change Plan update 2018-2032 Transport Scotland route map to achieve a 20 per cent reduction in car kilometres by 2030 Tactran Achieving a 20% Reduction in Car-km: Options for the Tractan Region Tactran Regional Transport Strategy documents Tactran Regional Active Travel Network Tayside Bus Alliance Bus Improvements Detailed Options Appraisal Transport Scotland Active Travel Vision Transport Scotland Active Travel Framework Transport Scotland Rail Services Decarbonisation Action Plan Scottish Government National Walking Strategy PKC Mobility Strategy main issues report 2023 PKC Mobility Strategy PKC Mobility Strategy Action Plan PKC Kinross-shire Active Travel Masterplan Perth Traffic Appraisal Network Monitoring study [Core Doc Ref: CD34] Electric Vehicle Infrastructure Fund Strategy and Expansion Plan [Core Doc Ref: CD35] PKC Briefing to elected members January 2025 - Initial results of Perth parking survey Scottish Household Survey - Transport and Travel in Scotland (findings 2022) Scotland's Road Safety Framework to 2030 Sustrans Walking and Cycling Index 2023 Sustrans Hands Up Scotland Survey Datasets Transport Scotland Scottish Transport Statistics 2023 Scotland's Census 2022 Scottish Household Survey results UK Department for Transport road traffic statistics UK Department for Transport vehicle licensing statistics UK Department for Business, Energy & Industrial Strategy UK local authority and regional greenhouse gas emissions statistics, 2005 to 2022 Statista: UK working habits Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix D to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that:
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179 • Data Gaps - Some of the datasets used are aged and would benefit from more up to date information. The Council will engage with Transport Scotland or any other relevant data owners to obtain the most accurate and relevant information available for use in informing the development of the Proposed Plan. The Council will work to identify, update and address those gaps in data during the preparation of the Transport Appraisal, engaging with Transport Scotland to outline opportunities to streamline collaboration. We will ensure we gain relevant insight on journey times and delay times specific for the Perth and Kinross road network, with attention to cross boundary factors that can influence this performance and reliability metrics. The Transport Appraisal work will include the necessary measures to address gaps related to the quality, frequency and accessibility of public transport services. We expect our Public Transport Team to have fully developed the route and patronage database and will use this to support the definition of suitable areas for development that reduce the reliance on the private car and enable sustainable travel choices. • Uncertainties - The development of transport infrastructure is often dependent on a combination of funding sources. PKC’s commitment and financial contribution generally requires the use of external funding. Consequently, there is a degree of uncertainty regarding the availability of sufficient financial support at national and regional levels. This may impact the delivery of projects that, under the Infrastructure First principle, could threaten the viability of development. As illustrated in the analysis of specific modes, the key transport routes serving settlements within Perth and Kinross are also linked to areas in the neighbouring local authorities. The performance of the network, and the ability to deliver improvements to the regional infrastructure, will often depend on the ability for Perth and Kinross Council to work in coordination with other organisations. Lastly, there is significant uncertainty surrounding the wider transport industry with regards to the evolution of working and commuting patterns. While these travel behaviours appear more stable when compared to recent years, it is unclear whether the existing trends of hybrid working will remain unchanged. Variations to these arrangements can create significant changes to travel behaviour, shaping demand on specific modes. These uncertainties should be considered when appraising development opportunities at later stages of the LDP process. Statements of Agreement and/or Dispute: 10 responses were received on the Transportation (Including Sustainable Transport) section of our Infrastructure Topic Paper. 6 responses neither agreed nor disagreed with the list of evidence evaluated or summary of implications for the Proposed Plan provided. 3 agreed, and 1 disagreed but did not wish for their comments to be registered as a formal dispute to the Evidence Report.
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180 A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Infrastructure – Transportation (Including Sustainable Transport) issue in Appendix D. • Key Stakeholders: o Nature Scot, agreed. o Tactran, neither agreed nor disagreed, but made points of clarification regarding the Council’s functions as they relate to transport to be consistent with the Regional Transport Strategy to ensure LDP3 fully understands the transport and accessibility impacts of its proposals. o Perth and Kinross Council Transportation and Development Team, agreed. o Transport Scotland, provided statement of agreement in February 2025. • Community Councils: 1 response from Kenmore and District Community Council who neither agreed nor disagreed with the list of evidence and summary of implications. • Public at Large: 2 anonymous responses were received, which neither agreed nor disagreed with the evidence reviewed and summary of implications provided. • Landowners and Agents: 3 responses were received, 1 agreed, and the other 2 neither agreed nor disagreed. • Other Bodies: Homes for Scotland disagreed with the list of evidence evaluated and made some suggestions for additional sources of evidence to include. They did not wish for their response to be registered as a formal dispute to the Evidence Report. Views on the Infrastructure of the Area Under Part 2, Section 16B(3) and Section 15(5)(d)- (e) of the Planning Act 2019, in the preparation of their Evidence Report, planning authorities are required to provide their views on the infrastructure of the plan area, and how that infrastructure is used. With respect to the Perth and Kinross Area, there are varying degrees of provision for specific travel modes. Road Travel The road network accounts for a total of 2,785 Km, including 270 Km of trunk roads. Most main settlements within Perth and Kinross are served by the trunk road network. The A9 connects Perth to Glasgow to the Southwest, passing through Auchterarder, and Inverness to the North, skirting a series of small settlements such as Luncarty, Bankfoot, Dunkeld and Pitlochry. The A85 is the main link between Perth and Crieff to the West and serves other settlements including Methven and Comrie. The M90 travels North to South between Perth and Edinburgh, and it serves the town of Kinross as well as the settlements of Bridge of Earn, Glenfarg and Milnathort. The A90 connects Perth to the Carse of Gowrie and Dundee to the East, passing near the settlements of St. Madoes, Inchture and Invergowrie. Some areas within Perth and Kinross are served by routes of strategic importance that are not part of the trunk road network. This is the case of the A93 and A94, connecting Perth to settlements to the North-East including Blairgowrie and Rattray, Scone, Coupar Angus and Alyth. Further
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181 West, the A827 connects the A9 with Aberfeldy and other settlements near Loch Tay. The condition of the road network is broadly consistent with the figures seen for Scotland, however the percentage of A roads requiring repairs in Perth and Kinross (7%) is significantly higher than the national average (4%). The Council is responsible for the maintenance of local roads, while Transport Scotland, via maintenance partners, oversee the condition of the trunk road network. An analysis of permanent traffic counts shows most road sections experiencing variations (increase or decrease) of under 10% in daily flow between 2018 and 2023. Within the trunk road network, these larger variations were registered along the A9 north of the city of Perth. With regards to journey times and reliability, data from the Scottish Household Survey suggests that road users in Perth and Kinross experience fewer delays in their journeys when compared to the average for Scotland. This is likely related to the predominance of rural areas within the territory of the Council. Road safety figures show a slight increase in the number of incidents, following a sustained decrease since the late 1970s. The number of casualties also presents moderate growth since 2020 but remains below the figures seen in the early 2010s. Active Travel The local network of active travel infrastructure includes 2,042 Km of core paths and over 200 Km of National Cycle Network routes. There are several improvements projects that include the expansion, optimisation and maintenance of the network. These enhancements target both rural and urban areas, with examples such as Green Routes looking to improve the network in rural roads, and School Exclusion Zones improving the active travel environment for students accessing educational premises. The Council is also involved in the delivery of behavioural change campaigns, encouraging the uptake of active travel for the public at large and for specific groups such as school pupils and the elderly. In addition to Perth and Kinross Council’s efforts, the Regional Transport Partnership is working on improvements to the infrastructure for walking and cycling in the area. The Regional Active Travel Network proposes enhancements to a set of routes across different local authorities, with 21 of the 39 being located within Perth and Kinross. Public Transport The public transport network in Perth and Kinross includes robust geographic coverage for buses, with a more disperse presence of rail networks. The majority of settlements have some form of public transport available. However, it is unclear whether local communities enjoy easy access to these services, with conveniently located stops, and whether the frequency of bus routes is sufficient to offer a suitable alternative to the private car. At the time of writing this chapter, the Public Transport team is collating route and passenger data and is expected to provide a more accurate understanding of the quality of the provision. In addition to local and intercity bus services, there are several Community Transport initiatives. These operate independently and, while the Council
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182 helps in their delivery, their viability depends on patronage levels and the availability of funding from external sources. The Council also supports a Demand Responsive Transport service between Kinloch Rannoch and Pitlochry, which has recently been expanded to serve Aberfeldy. Perth and Kinross Council is part of the Tayside Bus Alliance. This group is currently working on a programme of improvements to route design, frequency, infrastructure and marketing to increase the quality of service and encourage modal shift. 4 routes within Perth have been included in the preliminary assessment and will now be considered for the Strategic Business Case stage. Rail services are available through a total of 7 stations across the territory of the Council. These are located on two main routes, one connecting Perth to Stirling, Glasgow and Aberdeen and the second one travelling north to Inverness and south towards Fife and Edinburgh. Of the larger settlements, only Perth, Auchterarder and Pitlochry have railway station. This restricts the role of the rail as an alternative to the private car. Data from the Scottish Household Survey highlights low levels of public transport usage in Perth and Kinross. Regular users (a minimum of 2 times per week) of buses (7%) and train (1%) are significantly below national figures for Scotland (c. 15% and 4% respectively). The access domain within the SIMD also highlights connectivity issues between households and facilities and services of regular use. A comparison between average journey times for cars and public transport shows significant differences. For Perth and Kinross as a whole, these regular trips take 2.46 times longer when using public transport. While some of these gaps can be understood because of the distance to services in rural areas, some data zones within larger settlements also show significant discrepancies. An example of this is Burghmuir and Oakbank, within Perth City, which experiences journey times 3.3 longer when using public transport. This is the worst value for the whole of Perth and Kinross, despite being in a relatively dense area. Travel Behaviour The combination of infrastructure and geographies influence trends in travel behaviour for Perth and Kinross. The Scottish Household Survey shows high levels of car usage, around 9 percentage points higher than the national average. Travel to work metrics also suggest low levels of usage for public transport options, with buses and rail being the preferred option for 1 and 2 percent of commuters, respectively (compared to 9 and 4% for Scotland). However, walking appears to be a more popular mode of travel to work, preferred by 18% of commuters in the region compared to 13% for the whole of Scotland. There are also interesting findings for pupils travelling to school. The Hands Up Scotland Survey shows walking is consistently amongst the most popular modes of travel to school for primary and secondary pupils. The more granular data confirms this is the case for both age groups. However, there are significant differences in travel choices for pupils of each school type. For example, primary school pupils are much more likely to be driven to school (24.2% on average for the 2008-2023 period) compared to pupils attending secondary schools (11.8%). In line with this evolution in travel patterns by age group, the use of Park and Stride facilities is significantly more common in primary school pupils (10.8%) than in secondary schools (2.9%). The most significant change in travel choices for pupils relates to the use of buses. This is a relatively unlikely option for primary school pupils (7.7% on average between 2008 and 2023), but becomes the most popular travel
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183 mode for pupils travelling to secondary schools (44.4%). Conversely, cycling goes from being the mode of choice for 5.8% of primary school pupils to being preferred by only 1.2% of pupils attending secondary schools.
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184 Issue: Infrastructure – Waste Water Treatment and Water Supply Links to Evidence: Scottish Water, The Development Plan Process: A Guide to Considering Water and Waste Water Services SEPA, Policy and Supporting Guidance on Provision of Waste Water Drainage in Settlements (2006) Scottish Water Wastewater and Water Supply Strategic Asset Capacities [Core Doc Ref: CD6] Scottish Water Current Investment Programmes Scottish Water Drainage and Water Supply Network Spatial Data (will be requested to inform the Proposed Plan, and SEA site assessment) Scottish Water, Climate Change Adaptation Plan Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix D to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue and engagement with stakeholders, it was noted that Scottish Water reiterated their commitment to not restrict development, and Perth and Kinross Council will continue to engage with them during the preparation of our Proposed Plan, to inform them of likely areas of development. With due communication and agreement on delivery timeline and phasing, future residential developments can be presumed to receive access to public water and wastewater services. For industrial uses, we will engage with Scottish Water directly to identify potential stress points in the available capacity, and the need to deliver suitable infrastructure. Statements of Agreement and/or Dispute: 1 response was received from Scottish Water on our Infrastructure Wastewater Treatment and Water Supply Topic Paper. They did not disagree with the overall content and evidence reviewed within the Topic Paper, but requested some alternative wording relating to water and wastewater, and highlighted that they can provide additional spatial data for use in the assessment of site proposals for inclusion in the Proposed Plan. Scottish Water does not wish to raise a formal dispute. A full summary of Scottish Water’s comments, their status, and the Council’s response is provided in the relevant table under the Infrastructure – Waste Water Treatment and Water Supply issue in Appendix D. Views on the Infrastructure of the Area Under Part 2, Section 16B(3) and Section 15(5)(d)-(e) of the Planning Act 2019, in the preparation of their Evidence Report, planning authorities are required to provide their views on the infrastructure of the plan area, and how that infrastructure is used. With respect to the Perth and Kinross Area, the provision of water supply and wastewater services needs to be understood within a wider context.
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185 The network managed by Scottish Water relies on a series of water and wastewater treatment works that draw service areas beyond the territory of the Council. Consequently, water services should be considered a cross- boundary matter that requires continuous coordination with Scottish Water, SEPA and neighbouring local authorities. This is particularly relevant in the case of water supply, with treatment works often covering large areas across different local authorities. With regards to the level of capacity available in Perth and Kinross, the local network is served by a total of 13 water treatment works. Following Scottish Water calculations, nine of these locations are considered to offer sufficient capacity for the projected levels of development, with the following four outlined for potential future investment: • Kirkmichael • Killicrankie • Lintrathen • Lomond Hills 68 of the 85 waste water treatment works serving the territory of Perth and Kinross are considered for future investment. The growth project for Perth City have already started, and the improvements to Burrelton works are approaching sign off at the time of writing. 3 further growth projects are planned for Blairgowrie, Stanley and Meigle, with delivery estimated for 2026, 2027 and 2029, respectively. A table summarising the status of capacity for water and waste water works, and maps showing service areas associated with them, are shown in the Perth and Kinross Water and Waste Water Infrastructure document.
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186 PRODUCTIVE PLACES
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187 PRODUCTIVE PLACES 5.6.1 The issues covered under the NPF4 theme Productive Places are: • Community Wealth Building • Business and Industry • Retail, City, Town, and Commercial Centres • Rural Development • Tourism • Culture and Creativity • Minerals 5.6.2 A full summary of the review of evidence undertaken for all issues under this NPF4 theme, including all relevant links to that evidence, and a summary of stakeholder engagement, has been provided under Appendix E to this report. To save duplication in the re-reporting of that information, the pages to follow concentrate instead on providing an overview of the identified likely implications of this evidence for the preparation of the Proposed Plan, any gaps, uncertainties or key issues in the evidence gathered, and a summary of agreement, and/or disputes related to the evidence which were received through our programme of participation and engagement reported under Section 3. 5.6.3 As previously outlined under paragraph 5.5.2, as NPF4 Policy 17 deals with both residential and non-residential development in rural areas, only the ‘Homes’ element of that policy was reported under the Homes issue section, and the full summary for this entire issue is provided under this theme for completeness.
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188 ISSUE: COMMUNITY WEALTH BUILDING Links to Evidence: Register of community asset transfers Perth and Kinross Community Plan: Local Outcomes Improvement Plan 2022 to 2032 Eastern Perthshire Local Action Plan Highland and Strathtay Local Action Plan Kinross-shire, Almond and Earn Local Action Plan Strathearn and Strathallan Local Action Plan Perth City Local Action Plan Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix E to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • The Proposed Plan will need to take account of any updates that may be made to the Perth and Kinross Community Plan (Local Outcomes Improvement Plan) and the Locality Action Plans. These will need to be embedded into the Proposed Plan. • It will also need to consider the contents of any registered Local Place Plans, and whether they have implications for community wealth building in the area because there is a link between community asset transfer opportunities and Local Place Plans. Statements of Agreement and/or Dispute: Five responses were received on our Community Wealth Building topic paper. Most respondents either agreed with or had no comment to make on the evidence identified through the topic paper, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. Neutral comments were received from Historic Environment Scotland. Homes for Scotland stated their disagreement with the implications for the Proposed Plan, but did not wish to register their comments as a formal dispute. Two planning consultants (Gray Planning & Development, and Savills) made constructive comments on issues for the Proposed Plan to consider. Earn Community Council recommended that the outcomes of the Big Place Conversation should inform the Proposed Plan’s consideration of community wealth building; and that the Local Action Plans require updating.
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189 ISSUE: BUSINESS AND INDUSTRY Links to Evidence: National Economic Strategies/Analysis Levelling Up the United Kingdom Scotland's National Strategy for Economic Transformation Scottish Index of Multiple Deprivation Scottish Vacant and Derelict Land Survey 2023 Town and Country Planning (Masterplan Consent Areas) (Scotland) Regulations 2024 which come into force on 5 December 2024 Regional Economic Strategies Tay Cities Region Economic Strategy 2019-2039 Tay Cities Region Deal Local Economic/Place Strategies Perth and Kinross Economic Wellbeing Plan 2020-2028 Draft City Centre Design and Development Framework (2024) Perth City Plan 3: Perth 2040 our agenda for change Local Analysis Employment Land Audit 2022 (The 2024 audit will not be available for the Evidence Report stage) Local Living and 20-minute Neighbourhood Analysis and Settlement Audit work (will be prepared prior to preparation of Proposed Plan) An Urban Capacity and Brownfield Study (will be completed prior to preparation of Proposed Plan) Perth and Kinross Council Employment Land Matrices [Core Doc Ref: CD37] LDP2 categorisation of two types of employment land, core and general (review may be completed prior to preparation of Proposed Plan, if these two categories are continued in LDP3 policy) Perth and Kinross Council Employment Land and Property Market Analysis December 2022 Perth and Kinross Council, LDP3 Big Place Conversation Summary Report Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix E to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Quantitative Analysis of Business and Industrial Land Strategy - Summary of the potential Proposed Plan employment land requirement: o 48 Hectares for the anticipated take up over 2025-2037 period o Add 30 Hectares for unanticipated larger industrial user/s o Add between 25-30% for flexibility This suggests a potential minimum total of 100 Hectares of effective employment land) may be an appropriate employment land requirement for LDP3. However, should the 2024 Employment Land Audit when it is completed to inform the Proposed Plan indicate a significant change in the average take up of employment land, this amount should be reevaluated accordingly.
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190 • Qualitative Analysis of Business and Industrial Land Strategy (Viability/Deliverability) - To help address identified viability and deliverability issues, LDP3 will need to consider further opportunities for mixed uses allocations where appropriate and ensure there is appropriate cross funding between housing and employment uses. This approach would also support the 20- minute neighbourhood, local living policy. Also to ensure cross funded serviced sites are oven ready consideration should be given to defining serviced employment land in the LDP so that there is a consistency in the quality of the cross funded employment land delivered. In terms of qualitative assessment, when completed, the SVDLS, and the Urban Capacity and Brownfield Study will provide an effective review of capacity and potential of development sites and vacant properties. The key strategy is to retain employment land in the good locations and consider reallocating to other/mixed uses where existing business sites are underused or unsuitable. After the identification of potential LDP allocations, or alternative uses for existing allocations, there will be SEA site assessment of all sites. In terms of delivering Perth & Kinross’ market potential - including the industrial property projections suggested in the Perth and Kinross Council Employment Land and Property Market Analysis December 2022 - and creating capacity for mobile and unanticipated projects will require more of the land supply to move beyond allocation into servicing and marketing. The Proposed Plan will consider any potential new employment land sites, whether any existing ones should be deallocated, and where mixed-use allocations could improve deliverability and viability of employment land and/or address local living objectives • Qualitative Analysis of Business and Industrial Land Strategy (Inclusive Economic Growth) - In a Perth and Kinross context, there are significant limitations to using the Scottish Index of Multiple Deprivation (SIMD) data to inform our employment land strategy as rural deprivation is dispersed, and the rural population accounts for nearly half of the Perth and Kinross population. In terms of generating economic prosperity for all people and places, and reducing poverty, the SIMD highlights the importance of the Proposed Plan identifying sufficient employment land within Perth, and Blairgowrie and Rattray. However, their position within the settlement hierarchy, and the market demand within them, supports this approach too. It is considered that the Proposed Plan strategy should where possible provide employment land provision within the following settlements (which are tiered settlement locations from the LDP2): o Perth Core Area. o The 3 Regional Centres (Crieff, Kinross/Milnathort, and Blairgowrie/Rattray). o And the Local Centres (Pitlochry, Dunkeld and Birnam, Aberfeldy, Auchterarder, Alyth, and Coupar Angus). o Also, further locations to meet market demands, and other policy objectives, such as reuse of brownfield land, and 20
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191 minute neighbourhood/local living aims and objectives should be considered. To identify where future business and industry may provide the most benefit there is a current gap in evidence in terms of the settlement audit work which when completed will help inform work on Local Living and 20 Minute Neighbourhoods required under NPF4 Policy 15. The template has yet to be developed but will be in place prior to work beginning on the Proposed Plan and will consider the range of employment opportunities, and availability of LDP employment land. These settlement audits will be informed by results of our LDP3 Big Place Conversation exercise (using the Place Standard Tool) which are being collated to produce summaries for each of the localities. The Big Place Conversation summaries will be considered through our future Settlement Audit work. Perth and Kinross Council Employment land matrices utilise a ‘balanced scorecard’ approach to determine the sites most likely to require Council intervention and their relative attributes. When updating these assessments, there was not always enough consideration of active travel links, an area of increased emphasis in national policy. Also, since they were prepared, there is an increased emphasis on generating economic prosperity for all people and places. Future updates of these matrices should consider those aspects carefully. Informing these matrices, analysis of the spatial distribution of existing serviced employment land, Perth and Kinross Council employment property records, together with consideration of the 20-minute neighbourhood and settlement audit analysis will help identify priorities. Tactran notes that it is difficult to understand the scale of the problem and the potential impact new development can have on business and industry without knowing the baseline data in relation to, for example, traffic levels (including congestion and journey times), wider connectivity and origins and destinations of the relevant travel to work areas as well as average travel to work times. As such, Tactran suggest any audit should consider those parameters. PKC will be carrying out a transport appraisal after the Evidence Report stage to inform the Proposed Plan, this will consider the cumulative impact of potential new development. Whilst it is unclear how the methodology once agreed with Transport Scotland will consider potential impacts on existing business and industry it will at a broad level consider how development could affect the communities involved. This work considering LDP employment land allocations and their relative priority for public sector intervention will inform the LDP review, help with delivery of LDP sites, and will inform Perth & Kinross Council’s Investment Property Strategy, its Commercial land and property portfolio, and Commercial Property Investment Programme. It will also assist in maintaining the Perth and Kinross Council Corporate plan performance indicator for the area of immediately available serviced business land to an appropriate
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192 level. Updating Employment land matrices will help prioritise public sector intervention and hopefully help deliver constrained sites. Statements of Agreement and/or Dispute: 9 responses were received on our Business and Industry Topic Paper. 6 respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 026, or the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and/or highlighted other potential implications for the Proposed Plan. There was 1 response on the issue which the respondent wished to be treated as a formal dispute to the Evidence Report. There were also 2 further responses where there was a disagreement, but they did not register a formal dispute. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Business and Industry issue in Appendix E. • Key Stakeholders: o Tactran, neither agreed nor disagreed o Scottish Water, neither agreed nor disagreed • Community Councils: 2 responses, 1 agreed and the other neither agreed nor disagreed. • Public at Large: No comments received. • Landowners and Agents: 4 responses, 1 of which agreed, 1 neither agreed nor disagreed, 1 disagreed but did not wish for their comments to be recorded as a formal dispute (Stuart Buchanan on behalf of Cardross Asset Management Ltd) and 1 (Savills on behalf of Scone Estate) disputed the evidence and wish for their comments to be registered as a formal dispute as they want to see the Council's explicit recognition that investment in the Cross Tay Link Road (CTLR) is intended to unlock significant additional investment and the Evidence Report and LDP3 must reflect this by freeing up development opportunities in conjunction with the opening of the new road infrastructure. • Other Bodies: Homes for Scotland, disagreed but do not wish to register as a formal dispute.
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193 ISSUE: RETAIL, CITY, TOWN AND COMMERCIAL CENTRES Links to Evidence: Place Audits, Assessments and Strategies Understanding Scotland’s Places Scottish Vacant and Derelict Land Audit (Proposed Plan will use the most up to date data) Local Living and 20 Minute Neighbourhood Analysis and Settlement Audit work (which will be carried out to support the preparation of the Proposed Plan) An Urban Capacity and Brownfield Study (which will be carried out to support the preparation of the Proposed Plan) City Centre Design and Development Framework (draft currently being used to engage stakeholders, expected to return to committee Spring 2025 for approval) Perth City Centre Customer and Occupier Demand Study Perth and Kinross City and Town Centre Retail Study (city, town centre, and neighbourhood reviews) Perth and Kinross Council, LDP3 Big Place Conversation Summary Report Retail and Leisure Sector Guidance and Capacity Perth and Kinross City and Town Centre Retail study (retail capacity conclusions and policy consideration, and market context and trends) Scottish Government, Diet and Healthy Weight: Out of Home Action Plan Food Standards Scotland, The Out of Home Environment Permitted Development Rights The Town and Country Planning (General Permitted Development and Use Classes) (Scotland) Miscellaneous Amendment Order 2023 Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix E to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Retail Development - Considering the retail forecasts of the Perth and Kinross City and Town Centre Retail study, there is no requirement to plan for major new retail development, but there will be a need to consider neighbourhood scale retail. Also, whilst there is a need to move on from retail led centres, the Proposed Plan should afford sufficient protection for footfall generating activities and allow for proper scrutiny of change of use proposals from town centre use(s) to ground floor residential. This is something which should be considered further when preparing the Proposed Plan. • Identification of Town, Neighbourhood, and Commercial, Centres - There will be a need for the LDP to identify the town centres, neighbourhood centres, and commercial centres (the network of centres reflecting the principles of 20-minute neighbourhood). There will also be a need to consider if Perth City Centre and the
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194 town centre extents should be redefined, or whether a policy approach will be sufficient. • Opportunities for Town Centre Living - There is a need to consider the opportunities for town centre living. Carrying out a future urban capacity and brownfield study will help identify the scale of the opportunities and any issues which require a response in the Proposed Plan. It will help in identifying suitable conversion and new build opportunities for residential development within the centres. This study will identify longer term red sites with some constraints associated to them, which may or may not be supported, and these should be considered through LDP review, and through SEA site appraisal. The settlement hierarchy in the existing LDP2 is largely appropriate however the Perth and Kinross City and Town Centre Retail study 2023 does provide some guidance on what will require review in the Proposed Plan. This concerns whether Coupar Angus should be redefined as a neighbourhood centre and also requires defining neighbourhood centres in a more comprehensive way. The retail study suggests some additional neighbourhood centres within Perth, whilst future local living and 20-minute neighbourhood analysis and settlement audit work to support the Proposed Plan, may identify the need to identify further neighbourhood centres. • Definition of Retail Scales - The Perth and Kinross City and Town Centre Retail study provides recommended definitions to help with the interpretation of NPF4 Policy 28 Retail policy reference to edge of centre sites, to small scale neighbourhood retail, and to the floorspace threshold at which an impact assessment will be required. These are matters which it is generally too early to consider and will be considered at the Proposed Plan stage. However, since the Proposed Plan will need to consider opportunities for neighbourhood scale retail, it might be useful to be aware that the study suggests this should be defined as comprising no more than 500 sqm gross in total, with individual retail units measuring no more than 200 sqm gross. These controls would ensure development principally serves local retail needs and is consistent with the principles of 20- minute neighbourhoods. • Eating Out of Home – As this sector continues to grow, it is important that this growth sector supports existing centres which are losing some of their retail function. In terms of future food and drink development opportunities, these will be directed to existing centres as per NPF4 Policy 27. The evidence from the Perth and Kinross City and Town Centre Retail study, the availability of existing drive through provision, and the recent planning permissions granted for drive through provision at Broxden in Perth suggests that it is unlikely that the Proposed Plan will need to allocate any new sites for drive-through restaurants. This analysis is informed by NPF4 Policy 27 City, Town, Local and Commercial Centres, which identifies drive throughs are only appropriate where they would not negatively impact on the principles of local living or sustainable travel. There is also scope to consider drive through
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195 applications on retail allocations without necessarily requiring specific allocations for drive throughs. • Clustering of Non-Retail Uses - In terms of the NPF4 consideration of potential clustering of hot food takeaways, high-interest money lending, and betting shops, Perth City Centre area does have multiple fast-food take-aways and some (but not high numbers) betting shops. This reflects the nature and function of a city centre and is not problematic. The food and beverage overview within the Perth and Kinross City and Town Centre Retail study does not note any problematic clustering of takeaway provision. Therefore, clustering of these non-retail uses is not an obvious issue within Perth and Kinross. Statements of Agreement and/or Dispute: 9 responses were received on our Retail, City, Town and Commercial Centres Topic Paper. Two thirds of the respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 027, or the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and/or highlighted other potential implications for the Proposed Plan. There were 3 responses on the issue which the respondents wished to be treated as a formal dispute to the Evidence Report. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Retail, City, Town and Commercial Centres issue in Appendix E. • Key Stakeholders: o Nature Scot, neither agreed nor disagreed o Historic Environment Scotland, agreed o Scottish Water, neither agreed nor disagreed • Community Councils: 2 responses were received, 1 agreed and the other neither agreed nor disagreed. • Public at Large: 1 response received which neither agreed nor disagreed. • Landowners and Agents: 3 responses, all disputed the evidence and wish for their comments to be registered as a formal dispute. 1 (Lichfields on behalf of McDonalds) dispute as the evidence in the Topic Paper is not considered sufficient to accurately create new policy working in the future LDP regarding drive-thru developments, 1 (Montague Evans on behalf of Loch Developments Ltd) seek the allocation of the former BCA for mixed uses, retail, drive through and residential, and 1 (Avison Young on behalf of Aldi Stores Ltd) dispute as it is considered that less capacity has been identified than available and inaccurate conclusions have been reached about deficiencies across Perth. Aldi stores also disagree with the implications for the Proposed Plan. • Other Bodies: No comments received.
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196 ISSUE: RURAL DEVELOPMENT Links to Evidence: Scottish Government Urban Rural 6-fold Classification 2020 Perth and Kinross Housing Land Audit 2023 NPF4 and Rural Planning – RTPI Scotland Thinkpiece Understanding Scottish Places Scottish Agritourism Growth Tracker 2022 Tay Cities Region Economic Strategy 2019-2039 Perth and Kinross Economic Wellbeing Plan 2020-2028 NRS Small area population estimates for Scotland 2021 The James Hutton Institute: Population projections and an introduction to economic-demographic foresight for Scotland’s sparsely populated areas (2018-43) Scottish Government Advisory Group: Place-based policy approaches to population challenges – Lessons for Scotland A Scotland for the future: opportunities and challenges of Scotland’s changing population Perth and Kinross Local Housing Strategy Framework 2022-27 and Action Plan Tay Forest National Park Evidence Report Tayside and Central Scotland Regional Transport Strategy 2024-2034 Perth and Kinross Mobility Strategy Aberfeldy and surrounding area Community Housing Needs Survey July 2022 Comrie area Community Housing and Business Needs Survey Report Nov 2022 Highland Area Local Plan 2000 [Core Doc Ref: CD38] Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix E to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Local Place Plans - Whilst the Council has received some expressions of interest from community bodies, no LPPs have yet been registered. There is, therefore, a potential issue in aligning the timescales for the preparation of LPPs and the Proposed Plan. Work is programmed to begin in early 2025 on preparing the Proposed Plan. Realistically, therefore, LPPs will need be registered by Spring 2025 if they are to have the best opportunity to influence the Plan. It is not known, however, how realistic this timescale will be for community bodies. Statements of Agreement and/or Dispute: 12 responses were received on our Rural Development Topic Paper. Just over half of respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 028, and the summary of the implications of that evidence for the Proposed Plan provided by the
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197 Council. A number offered examples of additional sources of information which they felt should be considered and / or highlighted other potential implications for the Proposed Plan. There were 3 responses on the issue which the respondents wished to be treated as a formal dispute to the Evidence Report. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Rural Development issue in Appendix E. • Key Stakeholders: o NatureScot, did not state whether they neither agreed or disagreed. o Tactran, did not state whether they neither agreed or disagreed. o Scottish Water, neither agreed nor disagreed. • Community Councils: 2 responses, 1 agreed and the other neither agreed nor disagreed. • Public at Large: 1 response, which neither agreed nor disagreed • Landowners and Agents: 5 responses, 1 of which neither agreed nor disagreed, 1 disagreed but did not wish for their comments to be recorded as a formal dispute (Ristol Consulting), and 3 disputed the evidence and wish for their comments to be registered as a formal dispute. 1 (Savills on behalf of Scone Estate) on the grounds that the assessment of Self and Custom Build demand/need should use broader data sources and not just rely on historic planning consents, 1 (also Savills on behalf of Scone Estate) on the grounds that the Council must consider data sources regarding population to support growth in rural settlements and housing clusters to revitalise rural areas with supportive planning policies and generous housing allocations, and 1 (Andrew McCafferty Associates) on the grounds that more fine-grained analysis is required and there is a need for a continued supply of new allocations in rural areas. • Other Bodies: Homes for Scotland, disagreed but do not wish to register as a formal dispute. Allocation of Land for Resettlement Purposes Part 2, Section 16B(3) and Section 15(5)(cc) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to set out their views on the desirability of allocating land for the purposes of resettlement. A significant proportion of Perth and Kinross is identified as Remote Rural under the Scottish Government’s 6-fold Urban-Rural Classification. There are also several areas within Perth and Kinross where there has been a significant decline in population. This is particularly prominent in the most remote areas of Highland Perthshire. There are no specific areas, however, which stand out as being suitable for, or where it would be particularly appropriate to, allocate land for the purposes of resettlement as part of the spatial strategy in the Proposed Plan.
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198 ISSUE: TOURISM Links to Evidence: Visit Scotland’s Insight on Tourism in Perthshire Perth and Kinross STEAM Tourism Economic Impacts Report and Summary for 2012-2023 [Core Doc Ref: CD39] Scotland Outlook 2030 Responsible Tourism for a Sustainable Future Historic Environment Scotland: Responsible Tourism Framework – Transforming Heritage Tourism, 2023 Scottish Agritourism – A Strategy for Sustainable Growth Tay Cities Region Deal Tay Cities Region Tourism Strategy 2019-2024 Tay Cities Region Economic Strategy 2019-2039 Perth and Kinross Economic Wellbeing Plan 2020-2028 Perthshire Tourism Action Plan 2021-2025 Visit Scotland Visitor Management Plan Visitor Management in Rural Areas Report to Environment and Infrastructure Committee 28 Oct 2020 Short-term Let Control Area: Proposals for Consultation Report to Environment, Infrastructure and Economic Development Committee 31 May 2023 Scottish Tourism Alliance Recovery of Scotland’s Tourism Sector Key Findings ASSC Survey: The Impact of Scottish Government Regulations on Business Tay Forest National Park Evidence Report and map of draft indicative boundary Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix A to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • Age of Data - Lack of up-to-date data is an issue. For example, both the Tay Cities Region Tourism Strategy 2019-2024 and the Perthshire Tourism Strategy have either reached or are nearing the end of the time periods they were prepared to cover. A new economic plan for Perth and Kinross is currently being developed and this will help inform the preparation of the Proposed Plan. The Report on Visitor Management in Rural Areas dates from October 2020 although some of the findings were reiterated during the Big Place Conversation consultation, for example, the impact of large visitor numbers on popular destinations. It will be important that any decisions relating to visitor management considers more recent levels of usage. • Availability of Data at the Perth and Kinross Level - A significant amount of data is available from the Scotland Visitor Survey 2023, for example on attitudes towards responsible tourism,
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199 accommodation used by visitors, planning and booking behaviours, accessible and inclusive tourism, types of visitors, and how they travel. Also available is data on visitor interests and activities including, culture and heritage tourism, cycling tourism, food and drink tourism, motorhomes etc tourism, outdoor activities tourism, and wellness tourism. At present, however, this data is only available at a Scotland-wide level. • Data on Active and Sustainable Transport - Tactran highlight that there are problems in relation to active and sustainable transport and the implications both for visitors and hospitality workers. It remains difficult, however, to understand the scale of the problem, and the potential impact new development can have on tourism and culture, without understanding for example the baseline data in relation to traffic levels, wider connectivity and origins and destinations of the relevant travel to work areas. Data problems are (i) origins / destinations / length of stay / purpose of visit, and (ii) origins / destinations of workers. Statements of Agreement and/or Dispute: 10 responses were received on our Tourism Topic Paper, 1 of which came from respondents who did not provide their name or contact details. The majority of respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 029, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and / or highlighted other potential implications for the Proposed Plan. There was 1 response on the issue which the respondent wished to be treated as a formal dispute to the Evidence Report. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Tourism issue in Appendix E. • Key Stakeholders: o Nature Scot did not state whether they neither agreed nor disagreed. o Historic Environment Scotland, agreed. o Tactran, did not state whether they neither agreed nor disagreed o Scottish Water, agreed. • Community Councils: 3 responses, 1 agreed and the other 2 neither agreed nor disagreed. • Public at Large: 1 response received from someone who did not provide their name or contact details, they neither agreed nor disagreed. • Landowners and Agents: 2 responses, 1 of which neither agreed nor disagreed, and the other (Savills on behalf of Scone Estate) disputed the evidence and wish for their comments to be registered as a formal dispute on the grounds that the significance of the tourism sector to PKC must be understood and reflected in planning policy. • Other Bodies: No comments received.
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200 ISSUE: CULTURE AND CREATIVITY Links to Evidence: Perth and Kinross Council Corporate Plan 2022-2027 The Scottish Government's Creative Industries Policy Growth Sector Briefing – Creative Industries, Office of the Chief Economic Adviser, 14 March 2024 The Scottish Government Growth Sector Statistics, 14 March 2024 Tay Cities Region Deal Tay Cities Regional Economic Strategy 2019-2039 Tay Cities Deal Heads of Terms Agreement Tay Cities Region Tourism Strategy 2019-2024 Visit Scotland Insight on Tourism in Perthshire 2023 Scotland Visitor Survey 2023 - Domestic and International Perth and Kinross Council Culture Strategy 2023-2028 Perth and Kinross Council Gaelic Culture and Heritage Webpages Perth College University of Highlands and Islands Gaelic Society of Perth Learn Gaelic in Perth and Kinross Webpage Scotland’s Creative Learning Plan, Creative Scotland Perth and Kinross LDP2 Infrastructure Capacity Studies Historic Environment Scotland – Local Development Plan Evidence – Perth and Kinross Council Historic Environment Scotland: Responsible Tourism Framework – Transforming Heritage Tourism, 2023 Your Community PK Website Perth City and Towns Website Perth and Kinross Council Events in Perth and Kinross Webpage Perth and Kinross LDP2 Design Charettes Aberfeldy Square Regeneration Proposal Meigle and Ardler Community Action Plan Stanley Community Action Plan Alyth Community Action Plan Coupar Angus Community Action Plan Dunkeld and Birnam Community Action Plan Crieff Community Action Plan Blairgowrie and Rattray Community Action Plan Pitlochry and Moulin Community Action Plan Muthill and Tullibardine Community Action Plan Auchterarder and Aberuthven Community Action Plan St. Fillans Community Action Plan Perth and Kinross Council LDP3 Big Place Conversation Perth and Kinross Council Tay Forest National Park Bid Perth and Kinross Council Tay Forest National Park Bid - Consultation Analysis report Perth and Kinross Council, LDP3 Evidence Report Topic Papers Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix E to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that:
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201 • Growth Sector Briefing – Creative Industries, Office of the Chief Economic Adviser, 14 March 2024 and The Scottish Government Growth Sector Statistics, 14 March 2024 - The Scottish Government’s March 2024 Growth Sector Local Authority Area Statistics for the Perth and Kinross Council Area reports data from 2021, 2022 and 2023 for turnover, employment numbers and registered businesses figures, respectively. More recent data is not yet available, but any updates available at the time of developing our Proposed Plan will be used to inform the Plan. • Perth and Kinross LDP2 Infrastructure Capacity Studies, LDP2 Design Charettes, Aberfeldy Square Regeneration Proposal, and Community Action Plans (CAPs) - Despite some time having elapsed since our Design Charette reports were produced, their content still provides a good source of information on the community’s views of their local assets, their aspirations, areas for improvement, and a vision for the future of their place. Any data or statistics contained within them which has since been updated will be reviewed as part of the LDP3 Settlement Audit work. The Audit will also consider if progress has been made against the key issues and actions identified in the charettes, and how those issues and actions compare to the feedback gathered through the Big Place Conversation. • Your Community PK Website - There is a note on the website’s homepage to highlight that the site is currently undergoing development. It is difficult to know how up to date the information contained on the site is regarding local groups and services. • Number and Range of Venues and Facilities - It is planned as part of the Settlement Audit work for LDP3 to develop a Localities Profile template which will set out those factors which officers need to take account of in developing their understanding of each place and its needs to satisfy the requirements of the Planning Act, Regulations, LDP Guidance and NPF4 policies. This should allow for an up-to-date GIS based audit of existing cultural offering in a place and highlight where there is a known demand for additional or improved opportunities and facilities. The template has yet to be developed but will be in place prior to work beginning on the Proposed Plan. Statements of Agreement and/or Dispute: 8 responses were received on our Culture and Creativity Topic Paper, 2 of which came from respondents who did not provide their name or contact details. Most respondents (6 out of 8) either agreed with or had no comment to make on the evidence identified through Topic Paper 030, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered. There were 2 responses on the issue which the respondents wished to be treated as a formal dispute to the Evidence Report. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Culture and Creativity issue in Appendix E.
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202 • Key Stakeholders: o Historic Environment Scotland, agreed. o Scottish Water, neither agreed nor disagreed. • Community Councils: 1 response, disagreed (with the evidence and datasets identified) but did not wish for their comments to be recorded as a formal dispute (Errol Community Council). • Public at Large: 1 response (private individual), disputed the evidence and wish for their comments to be registered as a formal dispute due to the implications of the misrepresented employment data. • Landowners and Agents: 2 responses, 1 neither agreed nor disagreed, and the other (Savills on behalf of Scone Estates) disputed the evidence and wish for their comments to be registered as a formal dispute on the grounds that there is a lack of data included in Topic Paper 030: Culture and Creativity on the contribution of estates and significant historic and cultural locations to the cultural life of Perth and Kinross. • Other Bodies: No comments were received. Number and Range of Venues and Facilities: Part 2, Section 16(B)(3) and Section 15(5)(ch) of the Planning Act (2019) requires that, as part of the preparation of their Evidence Report, that planning authorities set out their views on the desirability of maintaining an appropriate number and range of cultural venues and facilities (including in particular, but not limited to, live music venues). Within the Perth and Kinross Area there are examples are where support has been shown to support cultural venues and facilities most notable the Perth and Kinross Culture Strategy 2023-2028 which includes support for maintaining venues, supporting festivals and local culture across the area. The venues are across Perth and Kinross with some having international status include Perth Theatre and Concert Hall, Perth Museum and Pitlochry Festival Theatre. The Perth Museum is an example of direct support from the Council, opening in 2024 and housing the Stone of Destiny and supporting revitalisation of the city centre. There is also support for those wanting to enter the cultural environment, with Perth College (part of the University of the Highlands and Islands (UHI)) having 650 culture and creative industry students. Considering the specific requirement in the Act the Proposed Plan will need to consider what can be put in place to support the Council’s desire to support culture and creativity.
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203 ISSUE: MINERALS Links to Evidence: Results of 2019 Aggregate Minerals Survey for Scotland (September 2023) A preliminary geological assessment of Craiglea Quarry, Logiealmond, Perthshire (2022): Decarbonisation & Resource Management Programme Open Report OR/22/042 - https://nora.nerc.ac.uk/id/eprint/535694/1/OR22042_BGS_report_Craigle a_Quarry_Slate.pdf Summary of Evidence and Implications for the Proposed Plan: A full summary of the evidence considered under this issue, including a summary of implications of that evidence for the Proposed Plan has been provided in Appendix E to this Evidence Report. Any Gaps, Uncertainties or Key Issues Raised through the Evidence: In reviewing the sources of evidence listed under this issue, it was identified that: • NPF4 sets out a requirement that the Local Development Plan should always support a landbank of construction aggregates of at least 10-years in the relevant market areas. • A methodology for calculating the 10-year landbank might be produced to improve consistency across Local Development Plans in Scotland. • The Proposed Plan will not be able to precisely calculate whether a 10-year landbank exists without improved data on demand and product flows. It is proposed to close this evidence gap by carrying out more engagement with the minerals industry, including industry bodies and active operators. A local aggregates survey is likely to be necessary. • It is likely that a local aggregates survey undertaken with local site owners and operators will be necessary. While good data exists in respect of permitted reserves and previous rates of extraction, there are likely to be data gaps around predicting future demand for minerals, and understanding planned future operations at minerals sites, including any sites that are currently dormant. • Aggregate Minerals Survey for Scotland 2020-23 - Data in respect of this survey was returned in 2024, and is expected to be published shortly, the outcome will be considered as part of the preparation of the Proposed Plan. This data will be useful in providing a more up-to-date picture of activities. Caution will be used in drawing trends from this data however, because for the calendar years 2020 and 2021 quarries and their customers were operating under varying degrees of COVID-19 pandemic restrictions. • Analysis of the 2019 Aggregate mineral survey suggests that in the Tay area, there are sufficient permitted reserves for crushed rock but that there may not be sufficient reserves of sand and gravel to meet the demand for a 10-year landbank, as required by NPF4.
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204 Statements of Agreement and/or Dispute: 3 responses were received on our Minerals Topic Paper, 1 of which came from a respondent who did not provide their name or contact details. All respondents agreed with the evidence identified through Topic Paper 031, and none had comments on the summary of the implications of that evidence for the Proposed Plan provided by the Council. There were no responses on the issue which the respondent wished to be treated as a formal dispute to the Evidence Report. A breakdown of those responses grouped under stakeholder categories is provided below, and a full summary of these comments, their status, and the Council’s response in the relevant table under the Minerals issue in Appendix E. • Key Stakeholders: o Historic Environment Scotland, agreed. • Community Councils: 1 response, agreed • Public at Large: 1 anonymous response which agreed.
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205 6 Summary of Key Issues for the LDP3 Spatial Strategy SUMMARY OF MAIN ISSUES BY THEME AND KEY POLICY CONNECTIONS 6.1.1 The pages to follow outline the key issues identified through the review of the evidence for this Evidence Report with implications for the development of our Proposed Local Development Plan 3. Where relevant, any key policy connections with other NPF4 policies have been highlighted and reflected upon. This is important because the individual policies within NPF4’s National Planning Policy suite should be read as a whole and applied accordingly, and it is crucial to understand the interconnected nature of the policies, and where policy synergies and conflicts may arise in the development of our LDP3 Spatial Strategy.
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206 Sustainable Places Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Climate and Nature Crises • LDP3 must address the global climate emergency and nature crisis through its Spatial Strategy. • The Spatial Strategy developed for LDP3, should be an integrated one, bringing together cross-cutting priorities to achieve sustainable development, rather than compromising between environmental, social, and economic objectives. The Strategic Environmental Assessment (SEA) for LDP3 will help the Plan strike a balance between these different objectives, identifying and directing the right development to the most appropriate and sustainable locations. • When preparing LDP3 a spatial strategy we will seek to achieve sustainable development which can help to safeguard those in the Perth and Kinross Area who are most vulnerable to the effects of climate change, by avoiding outcomes which would unintentionally increase their vulnerability. • It is suggested that Greenhouse gas emissions lifecycle assessments are undertaken when preparing the Proposed Plan. However, this is a new field of expertise which local authorities will need to develop a greater understanding of. • It is also important that we take an ecosystem’s services approach to developing LDP3’s Spatial Strategy. This can best be achieved through the SEA for LDP3. • NPF4 Policy 1 will be implemented through the collective impact of all the other national planning policies. • LDP3 Strategic Environmental Assessment (SEA) Biodiversity and Natural Places • Settlement Audits, our Big Place Conversation results and further discussions with stakeholders and communities will help shape how and where development will take place with a view to protecting existing important landscapes. This will extend to consideration of the need for a local policy on landscape. • Requirement for a review of protected area condition including studies and stakeholder input to address site specific requirements • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Soils • Forestry, Woodland and Trees, and the review of our Forest and Woodland Strategy • Perth Green Belt Review
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207 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections and also to consider the continuation of, or addition of new, local policies to protect and enhance the most vulnerable protected areas. • Development of draft nature networks has a potentially significant role to play in how development is brought forward including the location and site specific requirements to both protect and deliver nature networks. • Coastal Development • Energy, Heating and Cooling • Design, Quality and Place • Blue and Green Infrastructure • Play, Recreation and Sport • Flood Risk and Water Management • Rural Development • Tourism • LDP3 Settlement Audits and Site Assessments • LDP3 SEA and Habitats Regulations Appraisal. Soils The Proposed Plan… • and selection/assessment of sites will be informed by existing data on carbon rich soils, peatland, and priority peatland habitat (Class 1,2,3,5 soils). • will assess any proposals in relation to the Carbon and Peatland map, taking into account the soil mitigation hierarchy set out in NPF4 Policy 5 in addition to biodiversity enhancement requirements set out under Policy 3b. • will carefully consider the implications on Prime Agricultural Land (PAL) and will avoid/minimise any loss of PAL in accordance with NPF4 Policy 5 and the associated mitigation hierarchy. • NPF4 Policy 5 seeks to ensure development proposals protect soil from damage including from sealing, erosion, and/or compaction. These issues may influence site specific developer requirements/considerations including for development allocations. • Site surveys can support the detailed consideration of carbon rich soils, peatland, and priority peatland habitat, and prime agricultural land. This information can support the assessment of sites for • Tackling the Climate and Nature Crises (Including Climate Change Mitigation and Adaptation) • Biodiversity and Natural Places • Forestry, Woodland and Trees, including the review of our Forest and Woodland Strategy • Historic Assets and Places • Energy, Heating and Cooling • Blue and Green Infrastructure (including Strategic Green Networks) • Rural Development • Landscape Scale Restoration Projects • LDP3 SEA
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208 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections potential allocation as well as part of the determination of planning applications. • There is no nationally consistent methodology for identifying land of lesser quality that is culturally or locally important for primary use. Following stakeholder engagement on this matter, it is not intended to proceed with designating land under this classification. • There is no nationally consistent methodology for identifying land of lesser quality that is culturally or locally important for primary use. Following stakeholder engagement on this matter, it is not intended to proceed with designating land under this classification. Forestry, Woodland and Trees • By considering existing forestry, woodland, and trees assets, and identifying potential opportunities for enhancement and expansion via our LDP3 Spatial Strategy, we can help tackle the twin climate and nature crises. • No single dataset provides a comprehensive overview of all trees and woodland of high biodiversity value. The Native Woodland Survey of Scotland, the Scottish Ancient Woodland Inventory, the Ancient Tree Inventory, and Tree Preservation Orders combined provides the best available information. Whilst smaller woodlands, tree belts and hedgerows will be picked up via place specific studies to follow. • Through the development of our Proposed Plan, site selection should seek to avoid pure woodland sites and consideration will be given to applying Tree Preservation Orders to sites with significant trees or groups of trees. • In terms of economic potential, the Land Capability for Forestry Map dataset considers the potential across Scotland to grow trees. When comparing our spatial data, the planting of trees to date corresponds well with potential tree areas identified under the National scale Land Capability for Forestry Map. • Tackling the Climate and Nature Crises (Including Climate Change Mitigation and Adaptation) • Biodiversity and Natural Places (including Landscapes and Nature Networks) • Soils • Historic Assets and Places • Perth Green Belt Review • Energy, Heating and Cooling • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Blue and Green Infrastructure (including Strategic Green Network) • Play, Recreation and Sport • Flood Risk and Water Management • Infrastructure – Waste Water Treatment and Water Supply • Health and Safety • Tourism • Forest and Woodland Strategy Review
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209 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections • The Council will review our Forestry and Woodland Strategy (FWS) to ensure it is fully aligned with the National Strategy and National Planning Framework 4. • This FWS review is unlikely to lead to significant changes, however there may be scope to further focus and refine our spatial framework, to further expand, protect and enhance forests and woodlands, including increasing their resilience to the effects of a changing climate; helping reverse biodiversity loss, and at the same time delivering multiple benefits (environmental, economic, and health and wellbeing). • The Council will require to liaise with Scottish Water in the case of any potential development sites which are located within a ground or surface water protected area, to help identify appropriate mitigation or precautionary measures. • LDP3 SEA • LDP3 Settlement Audits and Site Assessments Historic Assets and Places • Historic environment related data sources provide us with information on the location, type, and status of our heritage assets within Perth and Kinross and allow us to identify, protect, and where appropriate enhance valued historic assets and places across the area in line with Historic Environment Policy for Scotland and NPF4 Policy 7: Historic assets and places. • The LDP3 Spatial Strategy should reflect the priorities and principles of ‘Our Past, Our Future’ Strategy for Scotland’s Historic Environment 2023. • The policies contained within the Historic Environment Policy Scotland should be taken account of and translated into the Plan’s Spatial Strategy with respect to the historic environment of Perth and Kinross. • PKC will ensure there is early and continued engagement with Historic Environment Scotland with regards to the development of LDP3 Spatial Strategy, its SEA and any related historic environment appraisals or guidance documents. • Tackling the Climate and Nature Crises (Including Climate Change Mitigation and Adaptation) • Biodiversity and Natural Places (including Landscapes and Nature Networks) • Soils • Perth Green Belt Review • Energy, Heating and Cooling • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Blue and Green Infrastructure (including Strategic Green Network) • Play, Recreation and Sport • Flood Risk and Water Management
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210 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections • Infrastructure – Communications and Digital • Community Wealth Building • City, Town, Local and Commercial Centres • Rural Development • Tourism • Culture and Creativity • Forest and Woodland Strategy Review • LDP3 SEA • LDP3 Settlement Audits and Site Assessments Green Belt • Requirement for a review to inform Proposed Plan. • The LDP3 Spatial Strategy will need to consider whether there is need to release from the Perth Green Belt any areas of land for planned growth. This will be informed by, amongst other things, the finalised Local Housing Land Requirement and Employment Land Strategy for the Proposed Plan which will in turn be informed by the NPF4 Spatial Principles. Of particular relevance will be the principles of local living, compact urban growth, rebalanced development, rural revitalisation, the delivery of a just transition approach to climate change, nature networks and landscape character. • Tackling the Climate and Nature Crises (Including Climate Change Mitigation and Adaptation) • Biodiversity and Natural Places (including Landscapes and Nature Networks) • Perth Green Belt Review • Energy, Heating and Cooling • Sustainable Transport • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Homes • Blue and Green Infrastructure (including Strategic Green Network) • Play, Recreation and Sport • Flood Risk and Water Management • Infrastructure – Communications and Digital • Business and Industry
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211 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections • Rural Development • Retail • Tourism • Perth and Kinross Council Housing Land Audit • Perth and Kinross Council Employment Land Audit • LDP3 SEA • LDP3 Settlement Audits and Site Assessments Brownfield, Vacant and Derelict Land and Empty Buildings • Overall proportion of brownfield land in PKC low, which is positive in terms of visual and environmental impact but means contribution of such sites towards meeting overall land requirements could be limited. • Key localised impacts to consider in developing a spatial strategy are - the impact on the percentage of the population living near to derelict land, especially the 11.5% living within less than 500m of derelict land; significant increase in retail vacancies in some town centres especially in Blairgowrie and Auchterarder. • In preparing the Spatial Strategy for the Proposed Plan there will also be linkages to other topics including: o Biodiversity in terms of the contribution brownfield land can make to nature recovery and can in some instances be a better use of land than development. o Blue Green Infrastructure networks and the potential of some brownfield sites to establish nature-based solutions, for example, for surface water management. o Flood risk and the potential to bring brownfield land to uses that support the management of increasing flood risk from climate change. • Tackling the Climate and Nature Crises (Including Climate Change Mitigation and Adaptation) • Biodiversity and Natural Places (including Landscapes and Nature Networks) • Historic Assets and Places • Perth Green Belt Review • Zero Waste • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Homes • Blue and Green Infrastructure • Play, Recreation and Sport • Flood Risk and Water Management • Business and Industry • City, Town, Local and Commercial Centres • Rural Development
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212 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections o Design, Quality and Place and the role that the development can have in improving the quality of an area where brownfield or derelict land or buildings are having a negative impact on health and wellbeing. o City, town, local and commercial centres and the increasing number of vacant units which some centres are experiencing. • Retail • Tourism • Culture and Creativity • Perth and Kinross Council Housing Land Audit • Perth and Kinross Council Employment Land Audit • LDP3 SEA • LDP3 Settlement Audits and Site Assessments • Urban Capacity Studies linked to Local Housing Strategy and Strategic Housing Investment Programme Coastal Development and Aquaculture • With regard to Perth Harbour, if the revision order is approved, and the harbour is closed for commercial traffic the Proposed Plan will consider the regeneration and leisure opportunities, alongside the constraints, which includes flood risk. • The Proposed Plan will accord with NPF4, refer to future flood maps, and use the SEA Site Assessment template to assess risk for all proposals being considered for potential LDP3 allocation. • Based on the Dynamic Coast web maps, and observing there are no areas at risk from coastal erosion, there does not appear to be significant concerns relating to the coastline. • LDP3 will need to identify any areas of undeveloped coastline to ensure that NPF4 Policy 10: Coastal Development can be implemented. However, NPF4 does not define the undeveloped coastline. It is unclear whether undeveloped means remote unspoiled coastline with wild land qualities, or if it is any area outwith a settlement boundary. It is currently unclear whether Perth and Kinross will have any areas of undeveloped coastline. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Biodiversity and Natural Places (including Landscapes and Nature Networks) • Energy, Heating and Cooling • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Blue and Green Infrastructure • Play, Recreation and Sport • Flood Risk and Water Management • Business and Industry • Rural Development
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213 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections • The NPF4 policy framework, and Nature Scot (formerly SNH) landscape and visual guidance are likely to be sufficient for the consideration of future planning applications for shellfish farms, for finfish hatcheries and freshwater adult growth stage facilities. Together with Marine Scotland National Marine Plan 2015 and its successor, this policy context will provide appropriate policy context for marine planning. Given the limited area and local context, a local policy is not considered necessary. • Tourism • LDP3 SEA and Site Assessments • Strategic Flood Risk Assessment (?) Energy, Heating and Cooling To meet NPF4 requirement of LDP’s to realise full potential for electricity and heat from renewable, low carbon and zero emission sources, the Proposed Plan will require to identify a range of opportunities for energy development, and future opportunities for renewable energy and decarbonised heat, and will do so whilst: • Considering energy infrastructure and future capacity/demand, including: o The ability to connect to the existing network (including any planned upgrades) which is a key consideration when preparing an infrastructure-first approach. o The utility network, including SSEN Transmission and Distribution datasets on network capacity, whilst noting there are early-stage indicative plans for potential new pipeline infrastructure across Scotland including in the Council Area to support emerging plans around hydrogen production/transmission. • Considering the various national and local plans and strategies covering energy, renewable energy, heat networks, climate action, and energy demands. o Noting that the formal designation of Heat Network Zones, in line with the requirements of the Heat Networks (Scotland) Act 2021, is still to take place, and LDPs should consider the area’s Local Heat and Energy Efficiency Strategy (LHEES) and take into • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Biodiversity and Natural Places (Including Landscapes and Nature Networks) • Forestry, Woodland and Trees, including the review of our Forest and Woodland Strategy • Soils • Historic Assets and Places • Perth Green Belt Review • Infrastructure First • Community Wealth Building • LDP3 SEA • LHEES and Heat Network Zones
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214 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections account areas of heat network potential and any designated Heat Network Zones (HNZ). • Identifying and being informed by several environmental and other considerations including: o Designations namely Biodiversity and Natural Places (Landscape), Soils, Forestry, Woodland and Trees, and Historic Asset designations o Key landscape features from Landscape Capacity for Wind (2010) e.g. Highland Boundary Fault, and important viewpoints/tourist routes. However, expectations around landscape have shifted, and the Council’s capacity study for Wind, does not reflect the current planning policy framework for wind proposals. There are no plans to update the landscape capacity study however draft Renewable Energy guidance update programmed in 2025 will provide project design and layout guidance to mitigate landscape impacts and will reference NatureScot’s Landscape Sensitivity Guidance. o Cumulative effects from existing operational/consented energy schemes Zero Waste • The Proposed Plan spatial strategy and policy will need to be informed by NPF4 Policy 12 Zero waste’s support for waste infrastructure and facilities. • The Proposed Plan will need to consider whether to retain some locally important Zero Waste policy wording and whether to incorporate the LDP2 Supplementary Guidance • The Proposed Plan will need to assess whether any locations for new waste management infrastructure require to be identified to support the circular economy, consistent with NPF4 Policy 12 Zero waste. • There will be no need for the Proposed Plan to consider areas of search or sites for new landfill sites and energy from waste sites. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Brownfield, Vacant and Derelict Land and Empty Buildings • Energy, Heating and Cooling • Infrastructure First • Community Wealth Building • Minerals • Circular Economy
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215 Liveable Places Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Design, Quality and Place • A wealth of information and evidence exists regarding physical, social, cultural, economic, and environmental aspects, to help us understand the existing key characteristics of our Plan Area, as well as the connections and interactions between our places, and the needs and ambitions of our communities. • The current Perth and Kinross LDP2 brings those different matters together to provide a good basis of understanding of the local context and characteristics of the area, and what constitutes high quality successful places within the context of Perth and Kinross o Under its spatial strategies o And in its accompanying supplementary guidance, particularly on placemaking and our various Conservation Area Appraisals • Bringing the NPF4 Annex D - Six Qualities of Successful Places through in the LDP’s Settlement Audit and Site Appraisal templates should ensure all elements are given the appropriate level of consideration prior to any site proposals being allocated in the Plan • In developing our LDP3 Spatial Strategy we will consider which locations, sites or groups of sites might benefit from the production of a masterplan and will identify this in the Proposed Plan via the site- specific requirements for those proposals. • NPF4 Policy 14: Design Quality and Place will be implemented through the collective impact of all the other national planning policies. • LDP3 SEA, Settlement Audits and Site Assessments • Conservation Area Appraisals Review • Review of our Placemaking Guide • Identification of masterplan locations Local Living and 20 Minute Neighbourhoods • The next stages of the Development Plan process will include the update of datasets to provide a more accurate picture of facilities and services. • A methodology for the assessment of local living and 20-minute neighbourhood interventions will be developed. This will combine the need for development to be adequately placed and the role that new proposals can play in the delivery of additional infrastructure for local communities. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Sustainable Transport • Design, Quality and Place, including possible masterplans • Infrastructure First • Homes
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216 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections • The selection of sites for development will include an evaluation of sustainable travel options. Infrastructure for walking and cycling and public transport services will be assessed to identify existing provision or enhancement opportunities. • The location of housing and employment land will consider the potential for commuting trip generation and will aim to identify reduction or mitigation opportunities. • The location of healthcare and educational facilities will be assessed, aiming to support the accessibility for residents and visitors, and promoting well integrated places • Feedback from community consultation exercises, including our Big Place Conversation and Local Place Plans, will be incorporated to identify key gaps in the provision of local facilities and inform future development. • Utilise masterplans and design briefs to encourage developments to follow the principles of local living. • Blue and Green Infrastructure, including Strategic Green Networks and our Open Space Audit and Strategy • Play, Recreation and Sport, including our Play Sufficiency Assessment • Community Wealth Building • City, Town, Local and Commercial Centres • Retail • Perth and Kinross Council Housing Land Audit • Perth and Kinross Council Employment Land Audit • Perth and Kinross Council Mobility Strategy • LDP3 SEA, Settlement Audits and Site Assessments Blue and Green Infrastructure • The Spatial Strategy should seek to safeguard open space through further engagement with communities and ongoing audit work to identify valued open spaces for designation in LDP3. • Improving access to natural spaces through interventions in priority locations where the Open Space Strategy and settlement audits identify poor quantity, quality, and/or accessibility to public open spaces. • Delivering ecosystem services through Blue Green Infrastructure (BGI) enhancements identified in the opportunity mapping to improve multi-functionality of greenspaces. • Implementing nature-based solutions to projected climate change impacts by considering the Climate Change Risks and Opportunities Assessment, Strategic Flood Risk Assessment, Surface Water Management Plans, and Natural Flood Management Studies. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Identification of nature-based solutions • Biodiversity and Natural Places (Including Landscapes and Nature Networks) • Soils • Forestry, Woodland and Trees • Historic Assets and Places (Including Conservation Area Appraisals) • Perth Green Belt Review • Sustainable Transport • Design, Quality and Place, including potential masterplan locations
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217 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Opportunity mapping will provide an evidence-base for where and how BGI design can mitigate local impacts. • 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. Cross-boundary strategic green networks will be explored with neighbouring authorities. • Focus on delivery through site specific developer requirements for on-site or off-site contributions. For large-scale developments, these requirements will be further detailed through site masterplanning processes. As well as delivery through development, opportunities may be realised through other means such as public sector programmes and infrastructure investment. • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Homes • Strategic Green Networks and our Open Space Audit and Strategy • Play, Recreation and Sport, including our Play Sufficiency Assessment • Flood Risk and Water Management, including Strategic Flood Risk Assessment and Natural Flood Risk Management solutions • City, Town, Local and Commercial Centres • Rural Development • LDP3 SEA, Settlement Audits and Site Assessments Play, Recreation and Sport The Proposed Plan should seek to: • Address play provision in low density settlements (<50 dwellings). • Increase playground provision for children aged 4-8. Currently only 39% of dwellings in settlements meet the 400m accessibility standard for this age group. • Establish a prioritisation of new play, recreation and sport opportunities for the demographics reported to have the lowest levels of activity: females, young people aged 12-17, and those living in the most deprived areas. • Target development of new facilities in rural hubs in areas experiencing or expecting significant growth (e.g. Auchterarder and Kinross) • Address demand pressures for new football and rugby pitch provision in Perth. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Biodiversity and Natural Places (Including Landscapes and Nature Networks) • Forestry, Woodland and Trees • Historic Assets and Places • Perth Green Belt Review • Sustainable Transport • Design, Quality and Place, including potential masterplan locations • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Homes
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218 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections • Facilitate development of sports halls: Only 42% of the population can walk to a sports hall within 20 minutes. 60% of which are living in the 10% most deprived areas. Average build date of sports halls is 1980 - the national average is 1990. • Facilitate development of sports pitches: Only 35% of the population is within a 20-minute walk of a pitch. 50% of which are from the 10% most deprived areas. • Improve multi-functionality of open spaces through the provision of new opportunities to address current and future requirements. • Blue and Green Infrastructure • Strategic Green Networks and our Open Space Audit and Strategy • Flood Risk and Water Management • Health and Safety • City, Town, Local and Commercial Centres • Rural Development • Culture and Creativity • LDP3 SEA, Settlement Audits and Site Assessments Flood Risk and Water Management • The Strategic Flood Risk Assessment will support the Proposed Plan, helping to understand the spatial implications of NPF4 Policy 22: Flood Risk and Water Management by promoting avoidance as a first principle and reducing the vulnerability of existing and future development to flooding. • The Proposed Plan will accord with NPF4, refer to future flood maps, and use the SEA Site Assessment template to assess risk for all proposals being considered for potential LDP3 allocation. • Resilience will also be supported by managing the need to bring previously used sites in built up areas into positive use (dependent on the vulnerability assessment) and planning for adaptation measures. • In terms of Private Water Supplies, NPF4 presumes against these unless they will be sourced from a sustainable water source that is resilient to periods of water scarcity. Drought indicator mapping, alongside other water scarcity mapping, and Council call out records for water scarcity, could prove a useful starting point to determine vulnerable locations in the Proposed Plan. It could potentially help identify where a Private Water Supplies risk assessment procedure considering climate change related risks is required and/or where/when a planning response and mitigations may be required. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Identification of nature-based solutions • Biodiversity and Natural Places (Including Landscapes and Nature Networks) • Forestry, Woodland and Trees • Perth Green Belt Review • Design, Quality and Place • Infrastructure First • Homes • Blue and Green Infrastructure • Strategic Flood Risk Assessment • Health and Safety • Business and Industry • LDP3 SEA, Settlement Audits and Site Assessments
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219 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Health and Safety • For the Proposed Plan, it will be necessary to consider whether the content of the Supplementary Guidance will need to be incorporated into a locally tailored policy on Air Quality to complement the National Planning Framework policies. • The Council has a responsibility to monitor and improve air quality and while it is recognised that air quality now forms part of NPF4 Policy 23 Health and safety, there may be an ongoing role for a locally tailored policy or planning guidance to address local air quality issues, including in the Perth Air Quality Management Plan, and relating to our monitoring requirements. • The Perth Air Quality Management Plan has recently been reviewed and is expected to be published later in 2025. The Proposed Plan will need to address the actions set out in the revised plan. This may include: o gathering evidence on whether there is a need to address pollution from stoves and boilers in the air quality management area o examining whether emissions from vehicles can be reduced through encouraging low car developments o although the Air Quality Management Plan is not expected to introduce a need for a Low Emissions Zone in Perth, this issue was last considered in 2020 and may have been raised again in consultation so may require examination again in the future • The Crieff Air Quality Management Area was revoked in 2024 following a review, and the Proposed Plan will need to reflect those changes • Licensed airfields are already safeguarded as described earlier so the Proposed Plan need not duplicate this. However, the five unlicensed airfields are safeguarded by the Local Development Plan policy and associated Supplementary Guidance. This means that the Proposed Plan will require to continue the designation of a safeguarding zone • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Forestry, Woodland and Trees • Energy, Heating and Cooling • Zero Waste • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Homes • Blue and Green Infrastructure • Play, Recreation and Sport • Flood Risk and Water Management, including our Strategic Flood Risk Assessment • Infrastructure – Communications and Digital • Business and Industry • City, Town, Local and Commercial Centres • Retail • Culture and Creativity • Minerals • LDP3 SEA, Settlement Audits and Site Assessments
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220 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections around each unlicensed airfield. The Proposed Plan will also need to consider whether the contents of the Airfield Safeguarding Supplementary Guidance will need to be incorporated into Local Development Plan policy or remain as planning guidance. • The Local Development Plan will need to maintain an awareness of the areas of the Plan that are at risk of being affected by coal mining. It will need to consider whether it should contain a Local Development Plan policy specifically addressing unstable land (including areas where development is at risk of being affected by coal mining)
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221 Homes Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Homes • Propose an indicative Local Housing Land Requirement (iLHLR) for Perth and Kinross Council of 8,700 over 10-year plan period. • Considers options for meeting the iLHLR including the review of existing LDP allocations and identification of new sites. • Proposed Plan Spatial Strategy will need to take account of NPF policies on Brownfield etc, Local Living and 20 Minute Neighbourhoods, Infrastructure First, and Rural Development, and consider the future role of settlement boundaries (as there is no mention of these in NPF4). • In addition to the existing suite of LDP housing policies, the Proposed Plan policy framework will need to consider how best to plan for: increasing the 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. • Increased emphasis in NPF4 on delivery through the LDP Delivery Programme. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Perth Green Belt Review • Brownfield, Vacant and Derelict Land and Empty Buildings • Sustainable Transport • Energy, Heating and Cooling • Zero Waste • Design, Quality and Place, including potential masterplan locations • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Blue and Green Infrastructure • Play, Recreation and Sport • Flood Risk and Water Management, including our Strategic Flood Risk Assessment • Health and Safety • City, Town, Local and Commercial Centres • Housing Land Audit • LDP3 SEA, Settlement Audits and Site Assessments • LDP Delivery Programme
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222 Infrastructure and Transportation Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Cemetery Provision • Propose an indicative Local Housing Land Requirement (iLHLR) for Perth and Kinross Council of 8,700 over 10-year plan period. • Considers options for meeting the iLHLR including the review of existing LDP allocations and identification of new sites. • Proposed Plan Spatial Strategy will need to take particular account of NPF policies on Brownfield etc, Local Living and 20 Minute Neighbourhoods, Infrastructure First, and Rural Development, and consider the future role of settlement boundaries (as there is no mention of these in NPF4). • In addition to the existing suite of LDP housing policies, the Proposed Plan policy framework will need to consider how best to plan for: increasing the 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. • Increased emphasis in NPF4 on delivery through the LDP Delivery Programme. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Perth Green Belt Review • Brownfield, Vacant and Derelict Land and Empty Buildings • Sustainable Transport • Energy, Heating and Cooling • Zero Waste • Design, Quality and Place, including potential masterplan locations • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Blue and Green Infrastructure • Play, Recreation and Sport • Flood Risk and Water Management, including our Strategic Flood Risk Assessment • Health and Safety • City, Town, Local and Commercial Centres • Housing Land Audit • LDP3 SEA, Settlement Audits and Site Assessments • LDP Delivery Programme
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223 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Communication and Digital • The communications and digital infrastructure of the area has some shortcomings, which may result in competitive disadvantages for local businesses and communities, therefore the Proposed Plan will need to encourage initiatives to improve digital connectivity (in line with NPF4 Policy 24). • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Natural Places • Perth Green Belt Review • Zero Waste • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Health and Safety • Community Wealth Building • Business and Industry • City, Town, Local and Commercial Centres • Rural Development Education Facilities • It is unlikely that the developer contributions policy will be expanded to cover early years and secondary education, unless specific site requirements result in a need within a specific catchment. Housing Land Audit data and planning approvals will assist the Council in forecasting capacity needs in local primary schools to inform site allocations and developer contribution requirements. • It is proposed that the study prepared in 2008 to calculate the Pupil Product Ratio is refreshed for LDP3 to assist contributions methodology. • Infrastructure First • Homes • Local Living and 20 Minute Neighbourhoods • City, Town, Local and Commercial Centres
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224 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Health Care Facilities • Placemaking and creating ‘healthy’ places is a focus of NPF4 Policy 23. LDPs should create healthier places and proposals that incorporate this will be supported. • Co-location of complementary services is encouraged in NPF4 Policy 23, in partnership with NHS Tayside and Perth and Kinross Health and Social Care Partnership. • The Council relies upon evidence from NHS Tayside and the Perth and Kinross Health and Social Care Partnership to demonstrate infrastructure needs in the area. Aspects of this evidence is not available publicly at present. The Council is working with both bodies to inform infrastructure needs because of new development in the Proposed Plan, as well as supplementary policies that support health (NPF4 Policy 23). • Infrastructure First • Health and Safety • Sustainable Transport • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Homes • Play, Recreation and Sport Transportation (Including Sustainable Transport) • Perth and Kinross Council will commission an adequate and proportionate Transport Appraisal to inform the policy content of the new LDP. It is understood that Transport Scotland will publish an updated Development Planning Transport Appraisal Guidance during 2025. We will aim to integrate this new guidance into our appraisal. The Council will work in the commission of a suitable traffic model that can support the assessment of the LDP and inform land use allocations. • The content of the Council’s Mobility Strategy and Tactran’s Regional Transport Strategy will also be incorporated into the Proposed Plan. Special consideration will be given to the expectation for future development to take sufficient action to reduce reliance on the private car and to enable sustainable travel behaviour. • The Local Development Plan is required to prioritise future development sites that can be accessed by sustainable transport modes. The Plan’s Spatial Strategy will also reflect the objectives of the sustainable investment hierarchy. Accessibility by a range of • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Natural Places • Energy, Heating and Cooling • Zero Waste • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Blue Green Infrastructure • Homes • Health and Safety • Community Wealth Building • Business and Industry • City, Town, Local and Commercial Centres
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225 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections transport modes is required and to reduce car-dominance where possible, with particular cognisance of the rural highland areas within Perth and Kinross. • The local and regional transport strategies, as well as an appropriate and effective transport appraisal, will inform the Local Development Plan, including evidence of transport capacities, and an appraisal of the spatial strategy on the transport network. • Through the next stages of LDP3, we will ensure there is consistent collaboration with a range of internal and external partners. As described in our Mobility Strategy, successful transport networks rely on the cooperation between mobility, planning and digital services, and with the support of other actors both within and outside the council. This will aim to deliver decisions that enable optimal performance across the three domains within the Triple Access Planning (physical mobility, spatial proximity and digital connectivity) • Rural Development • Perth and Kinross Transport Appraisal • Mobility Strategy Action Plan • Regional Transport Strategy Waste Water Treatment and Water Supply • Information on Scottish Water assets will allow the Council to consider if development should be planned in locations where there is existing or programmed capacity in the water and wastewater systems. However, the Proposed Plan Spatial Strategy will also be fully informed by the SEA work, and the 20-minute neighbourhood and local living analysis and the Settlement Audit work, to ensure development is focussed on the most sustainable locations. • Scottish Water are funded to provide increased capacity at Part 4 assets, such as water and wastewater treatment works, to meet the growth needs. There may be a timing consideration, and there will be consideration about overall sustainability, and trying to direct to where there is capacity where appropriate, however, sites will not ultimately be constrained by current capacity at the wastewater or water asset. • During the LDP preparation process, we will continue to engage with Scottish Water to inform them of likely areas of development. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Forestry, Woodland and Trees • Infrastructure First • Local Living and 20 Minute Neighbourhoods • Flood Risk and Water Management • Homes • Rural Development • Business and Industry • Health and Safety • LDP3 SEA, Settlement Audit and Site Assessments
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226 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Scottish Water has reiterated their commitment to not restrict development. With due communication and agreement on delivery timeline and phasing, future residential developments can be presumed to receive access to public water and wastewater services.
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227 Productive Places Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Community Wealth Building • NPF4 Policy 25 requires LDPs to be aligned with any strategy for community wealth building for the area. • The extent to which the Proposed Plan should support or compel local community wealth building initiatives is something that will need to be considered, considering deliverability issues. • The Proposed Plan will also need to have regard to the Council’s asset register and particularly whether there have been any community asset transfer requests. • The call for ideas and sites stage of the Proposed Plan will need to assess the potential for community wealth building as one of several factors taken into account as part of the process for identifying, assessing and selecting sites for development proposals. • Brownfield, Vacant and Derelict Land and Empty Buildings • Local Living and 20 Minute Neighbourhoods • Business and Industry Business and Industry • There is a generous amount of marketable employment land supply in the current Local Development Plan of around 290 Hectares. • Taking account of historic take up of employment land, a large unanticipated industrial user, and a need for generous flexibility, suggests a potential minimum 100 Hectare employment land requirement will be necessary in the Proposed Plan. • 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. • Delivering Perth and Kinross’ market potential will require more of the land supply to move beyond allocation into servicing and marketing. • The Proposed Plan will consider any potential new employment land sites, whether any existing ones should be deallocated, and where mixed-use allocations could improve deliverability and viability of employment land and/or address local living objectives. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Sustainable Transport • Design, Quality and Place, including potential identification of masterplan locations • Health and Safety • Infrastructure - Communications and Digital • Community Wealth Building • City, Town, Local and Commercial Centres • Rural Development • Employment Land Audit • LDP3 SEA, Settlement Audits and Site Assessments
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228 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections • To identify where future business and industry may provide the most benefit there is a current gap in evidence in terms of the Settlement Audit work which when completed will help inform work on Local Living and 20 Minute Neighbourhoods. • Perth and Kinross Council Employment land matrices utilise a ‘balanced scorecard’ approach to determine the sites most likely to require Council intervention and their relative attributes. These matrices will be updated with increased consideration of active travel, and on generating economic prosperity for all people and places. Retail and City, Town, Local and Commercial Centres • NPF4 retail policy has marked a considerable shift in the policy framework for retail, with a greater focus on a plan led approach, unless the proposal is in a town centre, or is a neighbourhood scale or a rurally appropriate proposal. • NPF4 requires a plan led approach whereby a retail study identifies any deficiencies in retail provision in terms of quality and quantity so that appropriate allocation can be made for any needs. • Analysis of the Perth and Kinross City and Town Centre Retail study in February 2023, and consideration of its retail forecasts indicates there should be no requirement to plan for major new retail development. However, there will be a need to consider neighbourhood scale retail. • Coupar Angus should potentially be redefined as a neighbourhood centre, and neighbourhood centres should be identified in a more comprehensive way in the Proposed Plan. • The evidence all points to a need to move on from retail led city and town centres towards more multi-purpose destinations in their offer, use and experience. There is a need to consider the opportunities for town centre living. • It is unlikely that the Proposed Plan will need to allocate any new sites for drive-through restaurants. This analysis is informed by • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Historic Assets and Places • Brownfield, Vacant and Derelict Land and Empty Buildings • Sustainable Transport • Design, Quality and Place, including potential identification of masterplan locations • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Homes • Blue and Green Infrastructure • Play, Recreation and Sport • Health and Safety • Community Wealth Building • Business and Industry • Retail
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229 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections existing provision/permissions, and NPF4 Policy 27: City, Town, Local and Commercial centres, which identifies drive throughs are only appropriate where they would not negatively impact on the principles of local living or sustainable travel. There is scope to consider drive through applications on retail allocations without necessarily requiring specific allocations for drive throughs. • LDP3 SEA, Settlement Audits and Site Assessments Rural Development • There is a need for an appropriate 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. • Considering the specific requirement in the Act the Proposed Plan will need to consider the issue of resettlement and whether it is an appropriate tool in Perth and Kinross, either by the allocation of specific sites or areas, or through an appropriate local policy framework • The Proposed Plan will need to consider whether a more flexible and/ or innovative approach to housing delivery, particularly affordable housing, and increasing the resilience of rural areas would be appropriate considering the support in NPF4. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Biodiversity and Natural Places (Including Landscapes and Nature Networks) • Soils • Historic Assets and Places • Perth Green Belt Review • Brownfield, Vacant and Derelict Land and Empty Buildings • Coastal Development • Sustainable Transport • Design, Quality and Place, including potential identification of masterplan locations • Local Living and 20 Minute Neighbourhoods • Infrastructure First • Homes • Blue and Green Infrastructure • Play, Recreation and Sport • Flood Risk and Water Management, including our Strategic Flood Risk Assessment
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230 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections • Business and Industry • City, Town, Local and Commercial Centres • Retail • Tourism • Culture and Creativity • Minerals • LDP3 SEA, Settlement Audits and Site Assessments Tourism • Proposed Plan will need to strike a balance between supporting the recovery and future growth of the sector against the existing and potential for adverse impacts on local communities and the environment of accommodating that recovery and growth. • A further challenge will be to create sustainable tourism within the required commitments in NPF4 to tackling the climate and nature crises. • NPF4 requires LDPs to identify both suitable locations for development and areas of pressure. Within rural areas existing and future opportunities are likely to be more dispersed and may be more difficult to plan for. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Biodiversity and Natural Places (Including Landscapes and Nature Networks) • Soils • Historic Assets and Places • Coastal Development • Sustainable Transport • Design, Quality and Place • Infrastructure First • Homes • Health and Safety • Blue and Green Infrastructure • Play, Recreation and Sport • Business and Industry • City, Town, Local and Commercial Centres • Retail • Rural Development • Culture and Creativity • LDP3 SEA, Settlement Audits and Site Assessments
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231 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Culture and Creativity • It is crucial that the development of our LDP3 Spatial Strategy reflects the importance of this sector through protecting existing cultural and creative workspaces and venues/places/spaces and supporting new opportunities to help support the sector’s growth. • There is recognition of the potential of this sector to grow and realise greater opportunities for the benefit of the region of a whole, not only for the quality of life of residents, but to enhance the tourism offer and increase visitor spend. • It is important that in developing our LDP3 Spatial Strategy that we support the Region’s seven key business sectors, including its tourism ‘connector themes’ of Creative Industries, Food and Drink, and Outdoor Adventures, to ensure that land use planning plays its role in facilitating the strengthening of these sectors via: o protecting existing facilities and venues o identifying and supporting opportunities for new proposals, and the o delivery of specific projects and actions identified for them, within the framework of national planning policies and guidance • In developing our LDP3 Spatial Strategy it is important to understand the cultural and creative offer within Perth and Kinross, to allow us to identify and support the maintenance of an appropriate number and range of cultural venues and facilities as per Section 15(5) of the Planning Act, and recognise and support opportunities for jobs and investment in the creative sector, culture, heritage and the arts for the Perth and Kinross Area and our communities, in line with NPF4 Policy 31: Culture and Creativity. Our LDP3 Settlement Audit work will consider in more detail the venues and facilities available in a place and their role in placemaking, local living, wellbeing, the economy and tourism. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Biodiversity and Natural Places (Including Landscapes and Nature Networks) • Historic Assets and Places • Brownfield, Vacant and Derelict Land and Empty Buildings • Zero Waste • Sustainable Transport • Design, Quality and Place • Local Living and 20 Minute Neighbourhoods • Health and Safety • Blue and Green Infrastructure • Play, Recreation and Sport • Infrastructure - Communication and Digital • Community Wealth Building • Business and Industry • City, Town, Local and Commercial Centres • Retail • Rural Development • Tourism
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232 Policy Reference Key Issues for LDP3 Spatial Strategy Key Policy and Other Connections Minerals • NPF4 sets out a requirement that the Local Development Plan should always support a landbank of construction aggregates of at least 10-years in the relevant market areas. • The Proposed Plan will not be able to precisely calculate whether a 10-year landbank exists without improved data on demand and product flows. It is proposed to close this evidence gap by carrying out more engagement with the minerals industry, including industry bodies and active operators. A local aggregates survey is likely to be necessary. • Analysis of the 2019 Aggregate mineral survey suggests that in the Tay area, there are sufficient permitted reserves for crushed rock but that there may not be sufficient reserves of sand and gravel to meet the demand for a 10-year landbank, as required by NPF4. • Tackling the Climate and Nature Crises (Including Climate Mitigation and Adaptation) • Biodiversity and Natural Places (Including Landscapes and Nature Networks) • Historic Assets and Places • Zero Waste • Infrastructure First • Health and Safety
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233 7 Links to Strategic Environmental Assessment Requirement for SEA: Perth and Kinross Local Development Plan 3 7.1.1 The Environmental Assessment (Scotland) Act 2005 requires qualifying plans, programmes, and strategies (PPS), developed by public bodies, to be subject to Strategic Environmental Assessment (SEA). As the Perth and Kinross Local Development Plan 3 (LDP3) deals with the subject of town and country planning or land use and is likely to result in significant environmental effects (both positive and negative), it classified as a qualifying plan under Section 5(3)(a) of the 2005 Act, and therefore SEA requires to be undertaken. As such, Perth and Kinross Council has chosen not to carry out SEA Screening for LDP3, but rather to proceed straight to Scoping stage. This Scoping Report is the record of that process. Benefits of SEA 7.2.1 The purpose of carrying out SEA is to help gauge the potential impact of a public plan on the environment and to identify ways to minimise any likely negative effects if those effects are anticipated to be significant. The SEA process has the potential to make a real and valuable contribution to the plan preparation process through ensuring that any likely environmental impacts of the Plan’s strategy, policies and proposals are fully understood, and any significant environmental effects are addressed. Carrying out SEA for LDP3 will also help ensure that the environment is given the same level of consideration in the Plan as social and economic factors. 7.2.2 Part 2, Section 16B of the 2019 Planning Act, requires planning authorities to compile an evidence report before preparing a local development plan. The evidence report should set out the planning authority’s views on the range of matters which are listed under Section 15(5) of the Act. These matters relate to, but are not limited to, the main physical, cultural, economic, social, built heritage and environmental characteristics of the area; the use of land; details about the size, composition, health status and distribution of the area’s population; the population’s housing and education needs and the availability of land to meet those needs, as well as the likely effects of the use and development of land on those needs; the health needs of the population and how they might be impacted upon as a result of the use and development of land; the infrastructure of the area and how it is used, and any change which the planning authority think might happen in relation to the list of matters under Section 15(5). 7.2.3 Due to many of the data requirements for this LDP3 Evidence Report overlapping with the data gathering requirements for the SEA Environmental Baseline being provided as part of the SEA Scoping Report, it was considered a more efficient approach to combine the data gathering for both processes to provide a holistic overview of the current state of the environment of Perth and
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234 Kinross, and ultimately a better Plan which has been thoroughly considered in respect of the likely significant effects of its implementation. 7.2.4 A separate SEA Scoping Report has been produced by the Council for LDP3 which will address the requirements under the 2005 Environmental Assessment (Scotland) Act. Despite the overlap in information between the two evidence gathering processes, it is not intended to repeat the information in this Evidence Report in full in the Scoping Report but rather highlight those key baseline facts which are of relevance to the SEA for the Perth and Kinross Local Development Plan 3. Next Steps 7.3.1 The next step in the SEA process is to submit the Scoping Report to the 3 Consultation Authorities (Historic Environment Scotland, Nature Scot, and SEPA) who will consider the proposed scope and level of detail to be included in the environmental assessment of LDP3, and the consultation period for the SEA Environmental Assessment and Proposed LDP3. The Consultation Authorities will then provide their views on these matters to the Council, which we will consider in the development of our environmental assessment. The Scoping Report will also be submitted alongside the LDP3 Evidence Report to the DPEA for the ‘Gate Check’ process.
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235 8 Local Place Plans INVITATION TO PREPARE LOCAL PLACE PLANS 8.1.1 In October 2023, Perth and Kinross Council emailed an invitation to all Community Councils highlighting the opportunity for Community Councils (and constituted Community Bodies) to express an interest in preparing a Local Place Plan for their area. This invitation was issued in accordance with Section 15A(a) of the Town and Country Planning (Scotland) Act 1997 as amended. 8.1.2 The proposed timeline for Local Place Plans to inform the next Local Development Plan was included in the invitation, and also in our Development Plan Scheme. 8.1.3 The timeline set out that we plan to start preparation of the Proposed Local Development Plan in early 2025 so that Local Place Plans that are registered before the start of its preparation would therefore have most opportunity to be considered when preparing the Local Development Plan. 8.1.4 To date, no Local Place Plans have been received, however 6 Community Bodies have committed to preparing a Local Place Plan (representing the first 6 areas on the following list), and there have been expressions of interest from a further 9 groups. 8.1.5 Expressions of interest for Local Place Plans were received for the following areas: • Aberfeldy and surrounding area, led by Aberfeldy Development Trust • Blairgowrie and Rattray, led by Blairgowrie & Rattray Development Trust • Braco and Greenloaning, led by Ardoch Development Trust • Errol, Errol Station, Grange and surrounding areas, led by Errol Community Council • Fossoway Community Council Area, led by Fossoway Community Development Trust and Community Council • Scone Community Council area • Alyth area, led by Alyth Development Trust • Cleish and Blairadam Community Council area • Comrie Community Council area • Crieff Community Trust area • Earn Community Council area • Glenlyon and Loch Tay Community Council area • Kettins Community Council area • Kinross area • Meigle and Ardler Community Council area ASSISTANCE PROVIDED TO LOCAL COMMUNITIES 8.2.1 The support offered by Perth and Kinross Council to assist Community Councils and Community Bodies to prepare Local Pace Plans included: • Online resources in the form of a dedicated Local Place Plans page on the Council’s website Local Place Plans - Perth & Kinross Council, and • In-person assistance in the form of presentation and Q and A sessions at the annual Planning Users Forum, and the Community Council Forum.
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236 8.2.2 The website includes an introduction to Local Place Plans and a resources section with links to guidance and assistance to help Community Councils and Community Bodies decide whether a Local Place Plan would be for them. 8.2.3 There is a link to our Guidance and Assistance Note that contains links to information, guidance and tools to help develop a Local Place Plan. This note includes links to the matters to which the Community Council or Community Body must have regard when preparing a Local Place Plan and includes a link to information on how they can ensure that their Local Place Plans meet the specific requirements set out in the Scottish Government Planning Circular 1/2022: Local Place Plans. 8.2.4 The website also includes a link to an online enquiry form that Community Councils and Community Bodies may use to notify the Council if they are interested in preparing a Local Place Plan or would like advice relating to them. 8.2.5 Once the first Local Place Plan is received for registration, the Council will add a Register of Local Place Plans to the dedicated Local Place Plans webpage on the main Perth and Kinross Council website. This will meet the requirements of the Act and the Circular.
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237 9 Approval of Evidence Report APPROVAL PROCESS AND NEXT STEPS 9.1.1 Before a planning authority can submit their Evidence Report to the Gate Check process for assessment, the Planning Act requires that it is approved by Full Council. The Development Plans Team has prepared this Draft Proposed Evidence Report and accompanying Committee Report for the consideration and approval at a meeting of Perth and Kinross Council (Full Council) scheduled for 5th March 2025. 9.1.2 Following that meeting, and providing our Proposed Evidence Report receives approval, the Evidence Report will then be submitted to the Scottish Government’s Planning and Environmental Appeals Division (DPEA) at the end of March 2025 to undergo the Gate Check process by a Scottish Ministers appointed ‘Reporter’. 9.1.3 If, following the assessment of the Evidence Report, the ‘Reporter’ finds it to contain sufficient information to allow Perth and Kinross Council to prepare our Proposed Local Development Plan 3, we will proceed to that next plan preparation stage. 9.1.4 If the ‘Reporter’ does not find the Evidence Report to contain sufficient information, they will prepare a report setting out the reasons for not being so satisfied, and any recommendations for improving the Evidence Report, and send that report to both the planning authority and the Scottish Ministers. On receipt of that report, planning authorities are expected to revise their Evidence Report and resubmit to the Scottish Ministers.