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Appendix A - Sustainable Places

Perth and Kinross Council · 5 March 2025
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Perth and Kinross LDP3 2027
Draft Evidence Report Appendix A Sustainable Places 
March 2025

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Issue: Tackling the Climate and Nature Crises and Climate
Mitigation and Adaptation
Corresponding NPF4 Policy/Policies:
• National Planning Framework 4, Policy 1: Tackling the climate and
nature crises and Policy 2: Climate mitigation and adaptation.
• Other key NPF4 policy connections – As policies 1 and 2 are
‘Universal’ policies, they have key policy connections with all the
remaining NPF4 policies from 3 to 33.
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 004: Tackling the Climate and Nature Crises
(https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume
nts/TP004_TacklingTheClimateAndNatureCrises.pdf) 
Information required by the Act and NPF4 regarding the topic:
Section 15(5)(a) of The Town and Country Planning (Scotland) Act 1997, as
amended by the 2019 Planning Act: 
• The principal physical and environmental characteristics of the district.
The Policy Intent for NPF4 Policy 1 is noted as:
• To encourage, promote and facilitate development that addresses
the global climate emergency and nature crisis.
The Policy Outcomes for Policy 1 are: 
• Zero carbon, nature positive places. 
Under Policy 1 Local Development Plans must address the global climate
emergency and nature crisis by ensuring the spatial strategy will reduce
emissions and adapt to current and future risks of climate change by
promoting nature recovery and restoration in the area. 
The Policy Intent for NPF4 Policy 2 is noted as:
• To encourage, promote and facilitate development that minimises
emissions and adapts to the current and future impacts of climate
change.
The Policy Outcomes for Policy 1 are: 
• Emissions from development are minimised, and
• Our places are more resilient to climate change impacts.
With respect to Local Development Plans, Policy 2 states that the LDP
spatial strategy should be designed to reduce, minimise or avoid
greenhouse gas (GHG) emissions.  To guide development to, and create,
sustainable locations, the six spatial principles (Just Transition, Conserving
and Recycling Assets, Local Living, Compact Urban Growth, Rebalanced
Development, and Rural Revitalisation) should form the basis of the spatial
strategy.  The strategy should be informed by an understanding of the
impacts of the proposals on GHG emissions. 
LDPs are also expected to support adaptation to current and future
impacts of climate change by taking account of climate risks, guiding
development away from vulnerable areas, and enabling places to adapt to
those risks. 
The ‘Step by step guide - Evidence Reports’, contained within the Scottish
Government’s Local Development Plan Guidance (May 2023) provides

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advice on relevant evidence for the NPF4 policy topics to help planning
authorities in considering the national planning policies when preparing
their Evidence Report.  In relation to Policy 1, the Guidance advises that
the policy will be implemented by the cumulative impact of all the other
NPF4 policies, and that in particular the information listed in the Guidance
document under policies 2 (Climate mitigation and adaptation, 3
(Biodiversity), 4 (Natural places), 5 (Soils), and 6 (Forestry, woodland and
trees).  For the purposes of avoiding duplication of information, the more
specific evidence relevant to these other policies i.e. 3 to 6, will be
considered in this Evidence Report under their individual issue templates.
With respect to Policy 2, the Guidance highlights that planning authorities
should consider:
• Information on local sources of GHG emissions, where available.
• Details of opportunities for GHG sequestration and storage, either
nature based or technological, where available.
• Details of climate risks likely to affect the plan area. 
Other sources of information listed, which planning authorities may wish
to prepare or review, include any plans and strategies produced by local or
regional adaptation partnerships, and local GHG mitigation strategies or
climate change plans. 
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

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• 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, 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
• 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 Stakeholder Engagement
• Perth and Kinross Council, Appendix A to the Report to Council for the
Draft Climate Change Strategy and Action Plan
• Perth and Kinross Council, Summary of Key Issues Raised by Consultees
• Perth and Kinross Council, PKC LDP3 Big Place Conversation Results

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Summary of Evidence:
As previously highlighted, due to the universal nature of NPF4 policies 1
and 2, and their interconnectivity with all the other remaining NPF4
policies, it is not possible or practical to cover in detail the relevant climate
and nature crises objectives for each policy area under this issue. 
Therefore, not all relevant sources of data and information for these
subjects will be covered in this ‘Summary of Evidence’.  Instead, these
matters will be picked up under each of the relevant summaries for the
individual issues, to ensure they are appropriately addressed.  The
Strategic Environmental Assessment process for our LDP3 will also take a
comprehensive overview of the key facts and issues for the Perth and
Kinross Area in terms of Biodiversity, Flora and Fauna, and Climate, and
assess the likely significant impacts (both positive and negative) of
implementing our LDP3 Spatial Strategy and any reasonable alternatives. 
LDP Spatial Strategies
Part 1 of National Planning Framework 4 contains six Spatial Principles
The six spatial principles are: Just transition; Conserving and recycling
assets; Local living; Compact urban growth; Rebalanced development, and
Rural revitalisation. 
NPF4 Policy 2 asks that these principles should form the basis of an LDPs
spatial strategy to help guide development to sustainable locations and
create sustainable places.   
1 Data is released by DESNZ approximately 18 months following year end,
as such 2022 is the most recent data available.   
Perth and Kinross Local Development Plan 2 (2019)
The current LDP for the Perth and Kinross Area seeks to achieve successful,
sustainable, low-carbon, natural, resilient and connected places through its
vision, key objectives, and spatial strategies.  Strategy Maps 1 to 4 provide
the spatial representation of this.  Each of the spatial strategy themes are
supported by a set of planning policies, many of which have now been
superseded by the introduction of a National Planning Policy suite under
Part 2 of NPF4. 
Greenhouse Gas Emissions and Lifecyle Assessments
National Planning Framework 4 – lifecycle greenhouse gas emissions:
assessment findings and the ESPON – Quantitative Greenhouse Gas
Assessment tool for Spatial Planning
These information sources contain assessment methodologies to help in
developing a greater understanding of the individual components of
development proposals, and their likely positive or negative effects on
greenhouse gas (GHG) emissions.
Department of Energy Security and Net Zero (DESNZ Formerly DESNZ)
Data 20221
DESNZ data is a set of statistics which annually provides a reliable and
nationally consistent breakdown of GHG emissions estimates across the
UK.  It combines data from the UK’s GHG Inventory with data from a
number of other sources, including local energy consumption statistics, to
produce estimates at a local authority level.  DESNZ use nationally

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available datasets going back to 2005 and cover territorial emissions of
Carbon Dioxide (CO2), Methane (CH4), and Nitrous Oxide (N2O).  
These estimates are compiled for local authorities based on several
sectors: Transport; Energy supply; Business; Residential; Agriculture; Waste
management; Industrial processes; Public; and Land use, land use change
and forestry (LULUCF).  As well as providing a sectoral breakdown, they
also outline those emissions thought to be within the scope of influence of
local authorities and those which are outwith.  
DESNZ data has been used in the development of the Council’s Climate
Change Strategy and Action Plan (CCSAP) and forms part of the monitoring
framework for the implementation of these documents.   Figure A1(1) to
follow illustrates the share of the overall GHG territorial emissions by
sector, with the Land Use, Transport and Agriculture sectors as the largest
emitters within the Perth and Kinross Area.  
Figure A1(1): GHG Territorial Emissions for Perth and Kinross, DESNZ 2022
However, it is worth noting that the chart at Figure A1(1) does not show
the percentage share carbon sequestration contribution arising from land
use, land use change and forestry (LULUCF) assets and activities, which was
reported in the DESNZ 2022 data as -40% (-834.4 ktCO2e).  This equates to
a LULUCF net emissions figure of -162.5 ktCO2e for the Perth and Kinross
Council Area.
In 2022, the total Perth and Kinross area wide territorial GHG emissions
was 1258.20 ktCO2e, representing a 2.9% decrease in emissions year on
year, and continuing the downward trend since 2005 (see Figure A1-2). 
This matched the overall Scottish trend.  There were increases in
Commercial emissions (19%), and domestic energy emissions (13%). 
Whilst some of this will be attributed to lasting property improvements
and behavioural change, it is also partially attributed to affordability of
energy linked to the 2022 energy and cost of living crisis.  There was a 7.9%
rise in transport emissions linked to further increases in travel and
commuting post-Covid, but it is still below 2019 transport emission levels.
While emissions in 2022 continued to decrease, we are still significantly
above the estimated trajectory needed to reach Perth and Kinross
Council’s target of 75% reduction by 2030, as currently we have achieved a
43% reduction on 1990 levels.   However, it is important to note that as the
Council’s Climate Change Action Plan was approved in December 2021,
many of the changes attributed to this Plan are likely to be modestly
reflected in the data. 
2%
4%
6%
11%
24%
21%
32%
Public Sector
Waste
Business
Domestic Energy
Transport
Agriculture
Land Use

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Figure A1(2): Perth and Kinross Area-wide Territorial GHG Emissions (kt
CO2e), DESNZ 20242
Figure A1(2) is an extract taken from the PKC Year 3 Climate Change Annual Report
As shown in Figure A1(3), since 2005, the per capita GHG emissions in
Perth and Kinross have steadily reduced, with the exception being 2021
(Covid recovery).   While this reflects the trend for Scotland for that period,
the per capita emissions for the area have continued to remain higher than
the Scottish average, which is expected for a local authority with a more
rural population like Perth and Kinross. 
2 Note: as the Scottish Government has not yet released the Perth and Kinross 1990
baseline for either the full suite of GHGs or CO2, a Perth and Kinross target figure for
2030 has been estimated for these two indicators assuming Perth and Kinross
Figure A1(3): Per Capita GHG Emissions for Perth and Kinross (tCO2e)
Figure A1(3) is an extract taken from the PKC Year 3 Climate Change Annual Report
Figure A1(4) shows a steady reduction in recorded CO2 emissions from
2005 until the Covid recovery “bump” in 2021, with a return to a 2.8%
decrease in 2022.  There have been similar decreases linked to the
commercial and domestic energy sectors, as with overall emissions. 
However, emissions levels are currently 19% higher than what is required
to be on trajectory for a 75% reduction by 2030.  
followed the Scottish trends between 1990 and 2005 when data first became
available.

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Figure A1(4): Perth and Kinross Estimated and Target CO2 Emissions
(ktCO2e)
Figure A1(4) is an extract from the PKC Year 3 Climate Change Annual Report
The Scottish Government, Climate Change (Emissions Reduction Targets)
(Scotland) Act 2024
The Bill for this Act of the Scottish Parliament was passed by the
Parliament on 5th November 2024 and received Royal Assent on 22nd
November 2024.  This legislation amends the Climate Change (Scotland)
Act 2009 to introduce limits on the amount of greenhouse gases emitted in
Scotland over a five-year period.  This change is based on
recommendations from the Independent Climate Change Committee (CCC)
and seeks to provide a more reliable framework for emissions reduction,
due to previous annual targets being vulnerable to year-to-year
fluctuations due to events such as a particularly cold winter or a global
pandemic.  
The Act allows carbon budgets to be set through secondary legislation and
changes the current deadline to finalise the next Climate Change Plan for
Scotland to allow that Plan to align with the process for setting new carbon
budgets.  Carbon budgets are an established model for the assessment of
emissions reductions, and will include emissions from international
aviation and shipping, and there will be no scope to carry over emissions
from one carbon budget to another. 
Adaptation and Mitigation, and Achieving Net Zero and a Just
Transition 
A Changing Climate – Scotland and Perth and Kinross
Adaptation Scotland website
The Adaptation Scotland website provides detailed information on
Scotland’s Climate Projections.  It tells us that our climate is changing and
that we are already seeing the impact of this change in Scotland, with the
10 warmest years on record having all occurred since 1997.  In addition to
the warming of the climate, over the past few decades we have seen
changes in rainfall patterns and rising sea-levels.  The weather is also
getting more extreme, with our hottest days getting hotter and our
wettest days getting wetter.
ARUP, Perth and Kinross Climate Risk and Opportunity Assessment
Technical Report, August 2023
The Climate Change (Scotland) Act 2009 places a legal duty on public
bodies, such as Perth and Kinross Council, to adapt to the impacts of
climate change.  Statutory climate change reporting requirements also
include a provision for public bodies to report on how they are

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contributing to national objectives for climate change adaptation and
resilience, as set out in the Scottish Climate Change Adaptation
Programme (SCCAP).  
Considering this requirement, Perth and Kinross Council commissioned
ARUP to develop our first Climate Change Risk and Opportunity
Assessment (CCROA) and risk and opportunities register, in response to the
increasing risks and impacts of current and future climate change on the
Council Area and its assets and operations.  This information is
fundamental for informing the prioritisation of climate action, investment
in adaptation, and supporting community resilience groups.  It builds on
the work already being undertaken through the Council’s Climate Action
Plan and through those community groups.
The assessment used the Met Office’s UKCP18 climate projections and
SEPA’s flood maps to understand how the climate is changing in Perth and
Kinross; these data sources, along with a literature review and stakeholder
engagement exercises, were then used to identify risks and opportunities. 
The risks were then scored to help understand the likelihood and impact,
and to inform future prioritisation of action.  The risks were categorised
into 5 different themes:
1. Health, Communities, and the Built Environment
2. Business and Industry
3. Infrastructure
4. Nature
5. Risks and Opportunities of relevance to Perth and Kinross Council
Current Impacts of Climate Change on Perth and Kinross
In terms of the current impacts of climate change in Perth and Kinross, the
assessment highlighted increasing incidences of both flash surface water
flooding in urban areas and river flooding, linked to an increase in rainfall
over Scotland in the past few decades (with an increasing proportion of
rainfall coming from heavy rainfall events).   These floods have caused
significant damage to properties, impacted multiple communities and
businesses, as well as assets.  With serious secondary impacts also
occurring, such as landslips and increased scour to bridges.  The annual
average damage of these risks is estimated at around £11.4 million within
the Tay District (Tay District Flood Risk Management, covering most of
Perth and Kinross and a small area of adjoining local authorities).   
Additionally, there has been a recent increase in temperature, with
Scotland’s 10 warmest years on record all having occurred since 1997.  The
average temperature in Scotland in the last decade (2010-2019) was
0.69oC warmer than the 1961-1990 average.  Heatwaves are becoming
more frequent and intense and can cause heat related illness and
mortality.  Temperature impacts have already been experienced within
Perth and Kinross. 
Figure A1(5) to follow shows those changes to the Perth and Kinross
climate which are already impacting the region.

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Figure A1(5): Current Changes to Perth and Kinross Climate 
Figure A1(5) is an extract from the Perth and Kinross CCROA Executive Summary
Future Impacts of Climate Change on Perth and Kinross – Precipitation
The precipitation rate anomaly, which represents the total precipitation, is
projected to vary significantly seasonally for the area.  In general, it is
projected that more precipitation will occur during the winter months with
less occurring during the summer months.  There are also spatial
differences in precipitation rate anomaly projections, with the greatest
changes in winter rainfall expected in the southern and eastern parts of
Perth and Kinross. 
Under both warming scenarios (low and high emissions), short-term
prolonged intense precipitation is expected to increase, but the increase is
much lower under the low emissions scenario compared to the high
emissions scenario.  It is anticipated that interventions to reduce the risk of 
3 RCP 8.5 is a high emissions scenario that is typically referred to as “business as
usual”.  It is considered a “worst case scenario” by the international science
community. 
flooding will be required under the low emissions scenario, as flooding is
already an issue in Perth and Kinross.  Increased temperatures lead to drier
ground, which, combined with more intense rainfall, is expected to result
in more frequent and severe surface water flooding, particularly in urban
areas. 
Future Impacts of Climate Change on Perth and Kinross – Temperature
Within Perth and Kinross winter minimum, mean and maximum
temperature are projected to increase under all scenarios.  However, the
increase in these climate variables is unevenly distributed across the local
authority, with the greatest change projected in the east and north.
Summer minimum, mean and maximum temperatures are projected to
increase in both warming scenarios in the Council Area.  All three of the
metrics show similar patterns across both the century and when
comparing emissions scenarios.  Spatially within Perth and Kinross the
degree of increase varies, showing a similar distribution to winter
temperatures.  The maximum projected temperature for the area is
37.5oC, and Perth and Kinross will also experience heatwaves more
frequently.  Figure A1(6) to follow shows the projection results for Perth
and Kinross at 25 KM grid cells.  The map shows the absolute summer
maximum projection for 2080 under RCP 8.53.   Figure A1(7) represents a
summary of climate change effects for temperature and precipitation in
summer and winter for the area.

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Figure A1(6): Maximum Summer Projection Results for Perth and Kinross
for 2080 
Figure A1(7): Summary of Climate Change Effects in Perth and Kinross for
Temperature and Precipitation (Summer and Winter)
Figures A1(6) and (7) are extracts from the Council’s Climate Change Risk and
Opportunity Assessment Executive Summary, June 2023
Future Impacts of Climate Change on Perth and Kinross – Flooding
As previously mentioned, flooding already affects the Perth and Kinross
Area, and current projections suggest that the extent and severity of
flooding is likely to get worse.  Changes to precipitation and sea level rise
will affect flooding, and increased winter precipitation is likely to increase
flooding.  In addition, despite summer precipitation being expected to
decrease, high-intensity short-term precipitation events make flash
flooding more likely, particularly during periods of higher temperatures
where run-off capacity is reduced.  The National Flood Risk Assessment
identifies approximately 9000 homes and businesses within Perth and
Kinross as being currently at risk, and this is projected to increase to
13,000 by 2080 as a result of climate change.   Figure A1(8), which has
been extracted from our CCROA Executive Summary, shows a diagram of
flooding cause and effects.

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Figure A1(8): Diagram of Cause and Effects of Flooding
Future Impacts of Climate Change on Perth and Kinross – Wind, Snowfall,
Sea Level Rise/Storm Surge
Projected changes to windspeed for the Perth and Kinross Area vary
seasonally.  Overall, windspeed is expected to increase slightly in winter by
0.1 ms-1 and decrease slightly in summer by a maximum of 0.3 ms-1.  The
southern, western, and eastern extends of the Council Area are projected
to experience the greatest change in windspeed.  
Establishing a baseline for snowfall is particularly difficult because of a lack
of reliable, consistent observed data.  However, snowfall is predicted to
decrease progressively through the century across the entire area.  The
areas where the greatest decrease is projected are in the northeast and
northwest (upland) parts of Perth and Kinross.  Figure A1(9) (also extracted
from the Council’s CROA Executive Summary) shows a summary of climate
change effects for snowfall flux and surface snow in Perth and Kinross -
both show the projected changes at RCP 8.5.   Figure A1(10) shows the
projected spatial variation of snowfall flux percentage change at RCP 8.5 in
winter.
Figure A1(9): Summary of Climate Change Effects for Snowfall

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Figure A1(10): Spatial Variation of Snowfall Flux % Change
There is currently no consensus with regards to the effects of climate
change on storm surge levels.  At present, current storm surge levels are
combined with sea level changes.  The Perth and Kinross Area does not
have open areas of coastline, but sea level rise will affect the Tay Estuary,
which will affect tidal areas such as Perth and Invergowrie. 
Climate Change in Perth and Kinross – Major Increased or Additional
Risks
Some of the impacts as a result of changes to the current climate of Perth
and Kinross, and future changes to it will be positive and present
opportunities.  However, many will in fact be negative and bring significant
risks to the area.  
The Assessment identified 52 risks in total.  Overall, flooding and its
impacts are the most pressing climate change threat for Perth and Kinross
and affects all sectors.  Flooding is already happening and will continue to
be a threat throughout the century as rainfall intensity increases.    
Heat is also likely to cause impacts for the Perth and Kinross Area during
the mid to late century as summer temperatures increase and heatwaves
become more regular and extreme.  Heat poses a risk of significant health
impacts, particularly to the most vulnerable members of our community.
Many of the risks posed to nature are classified as high impact.  Nature
across Perth and Kinross is diverse and important to both tourism and
some of the key industries.
The risks identified to the various sectors are set out below.
• Risks to Health, Communities, and the Built Environment – higher
temperatures can have direct health risks (heat stroke/heat stress),
lead to an increase in disease prevalence, cause buildings to overheat,
and result in a reduction in air quality.  Increased precipitation can
lead to flooding, which will impact people and communities, and an
increased occurrence of water damage, condensation, and damp in
homes.
• Risks to Business and Industry – possible increase in energy costs due
to additional cooling needed, and reduced productivity for employees

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during times of high temperature.  Flooding, drought (especially for
agriculture) and possible water scarcity because of precipitation
changes.  Risks to supply chains as a result of global climate impacts
causing supply problems.  Climate will impact on the transition to Net
Zero.
• Risks to Nature – species which are currently at upper temperature
limits, particularly in higher areas, may not be able to survive in the
area in the future.  Reduced snowfall is likely to have a big impact on
upland wildlife as well as hydrology within the area.   Generally,
threats are expected to both specific species and habitats from pests,
pathogens, and invasive non-native species which thrive more due to
changes in climate.
• Risks to Infrastructure – higher temperatures are likely to lead to
increased energy requirements because of an increased cooling
demand, and roads melting during times of extreme heat.  Increased
precipitation will lead to flooding, scour to bridges, and landslips – all
potentially damaging infrastructure directly.  A decrease in
precipitation could result in private water supplies drying up.
The risks identified to Council assets, operations, and net zero transition
include: 
• Risks to Council-Maintained Community Spaces from Flooding –
Some of the community spaces which PKC maintain lie within flood
risk zones, which brings the risk of potential large financial costs and
impacts on residents. 
• Risks to PKC Estates from Flooding – Potential large financial costs
and impacts on residents of social housing, Council offices, or possibly
equipment damage which could affect service operation.  There are
also five schools and HMP Perth at risk from flooding.
• Risks to Road Infrastructure from Flooding – some Council-
maintained roads lie within flood risk zones and are at risk from scour
which will result in significant repair costs.
• Risk to Housing and Housing Provision from Flooding – there will be
financial costs associated with protecting and repairing housing
affected by flooding, with associated effects of both a physical and
mental health and wellbeing nature.  There are 940 Council properties
at risk of flooding.  
• Risks to PKC Key Supply Chains – it is difficult to quantify, but
potentially significant effects on service provision and operation if
supply chains are disrupted.
• Risks to Leisure Facilities from Flooding – some leisure facilities lie
within flood zones, with potentially large associated cost and impact
on residents. 
Climate Change in Perth and Kinross – Those Most Vulnerable to Risk
Climate change does not equally impact upon people, some individuals in
our communities are more vulnerable to its effects than others. For
example: older people are more vulnerable to heat, due to specific
physiological characteristics, and would be more vulnerable if directly
exposed to flooding or the impacts of flooding.  Young children are also
vulnerable to heat, which is mainly due to their lack of ability to
understand heat dangers and their reliance on carers.  Also, the most
deprived members of our communities are often more vulnerable to
climate change because they have a lower financial ability to adapt.  
The ARUP Assessment considered this data to better understand how
these characteristics vary across the Perth and Kinross Area, and to identify
where vulnerable people were most concentrated.  Figure A1(11) on the
following page shows flood vulnerability across Perth and Kinross, taken
from the 2011 Neighbourhood Flood Vulnerability Assessment by the
Joseph Rowntree Foundation.  The vulnerability categories shown on the
map key refer to the scores across the Perth and Kinross Area, with the top

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20% most vulnerable being classes as ‘High Risk’.  The maps are displayed
by Data Zone4.
Climate Change in Perth and Kinross – Potential Opportunities
Alongside the risks, opportunities were also identified as part of the
assessment.  These are areas where climate change might bring
improvements to the lives of the people of Perth and Kinross and beyond
and create chances for economic growth or cost savings.  The key
opportunities identified as part of the assessment were:
• Improved health and wellbeing from warmer summers and winters.
• Lower energy demand, for example in terms of winter heating
(domestic and non-domestic buildings) helping to reduce fuel poverty
and cost to organisations. 
• Longing growing seasons with the possibility of new crops and
increased agricultural productivity.
• Opportunities for PKC to reduce running costs in some areas, such as
less gritting because of warmer winters; reduced energy demand in
buildings over winter, and opportunities for more renewable energy
generation. 
However, it is important to note that the risk from climate change far
outweighs any potential opportunities. 
4 Data zones are the small area geography used by the Scottish Government to allow
statistics to be available across a number of policy areas. Data zones were initially set up
to nest within council area boundaries and to have a population of between 500 and
Figure A1(11): Flood Vulnerability within Perth and Kinross 
Perth and Kinross Climate Change Risk and Opportunity - Next Steps
The Council’s CCROA has provided us with a good understanding of how
the climate in Perth and Kinross is likely to change and what the probable
1,000 household residents. Further information on Scottish Government Data Zones can
be found here.

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risks will be, along with which of these risks would cause the most impact. 
However, it is just the first step in adapting to climate change and making
the Council Area climate resilient.  The key next steps identified in the
Assessment are:
• Share the results of the CCROA and continue to engage with key
stakeholders.
• Continue engagement with our community councils and community
resilience groups in order to strengthen resilience.
• Use the risk assessment to prioritise actions and build on existing
adaptation plans.
• Create a framework to allow the regular review of the assessment
work to ensure it remains up to date and considers any new evidence. 
This plan/framework should be appropriately integrated into current
Council governance structures. 
Intergovernmental Panel on Climate Change (IPCC)
Climate projections indicate that the changes we have already experienced
in our climate, over the last century, will continue and intensify over the
coming decades.  Ultimately, the amount of change that occurs will
depend on how successful we are in reducing GHG emissions globally.  In
2020, the Intergovernmental Panel on Climate Change (IPCC) warned that
we only have a limited period until 2030 to take the decisive and serious
action required to avert the crisis and avoid the worst impacts.  
The key long term climate change trends identified by Adaptation Scotland
for the country are:
• Average temperatures will increase across all seasons.
• Weather will remain variable and may become more variable.
• Typical summers will be warmer and drier.
• Typical winters will be milder and wetter.
• Intense, heavy rainfall events will increase in both winter and
summer.
• Sea levels will rise.
• Reduced frost and snowfall.
It is important to recognise that these changes will not be consistent across
the country, or even across a large area like Perth and Kinross.  The
impacts of these changes will depend on how quickly we can reduce GHG
emissions to a net zero position, and what action we take to adapt across
Scotland as a whole, and the Perth and Kinross Area specifically, to the
current and predicted future changes in climate.
The impacts which we are already experiencing across Perth and Kinross
and are likely to experience even further without decisive action in tackling
both the climate emergency and nature crisis, are listed below.  Please
note that the details of climate risks for specific policy areas will be
addressed in the other topic papers.  This paper provides a strategic
overview for the Council Area. 
The likely impacts for the Perth and Kinross area include:
• Loss of nature, important habitats, and species.
• Increased occurrence and severity of flooding.
• Damage to buildings and infrastructure, including our heritage
assets.
• Impacts on transport and communications infrastructure and
networks.
• Potential damage to paths and places of recreation.
• A reduction in the availability and quality of water due to rising
temperatures, and the need to meet growing domestic, agricultural,
and industrial demands.

Page 17

• Increased risk of pests and diseases impacting the natural
environment, including woodlands, wildlife, and crops.
• Potential impacts on food supply.
• Potential impacts on energy supply, security, and efficiency - leading
to power outages.
• Reduced rainfall increases the risk of wildfires.
• Impacts on stability and security of livelihoods.
• Impacts on health and wellbeing from increased temperatures,
including heat stress.
• Risks to health from changes in air quality. 
• Increased levels of poverty and poor economic growth.
Our Changing Nature
The State of Nature Partnership, State of Nature Report 2023
State of Nature Report 2023 sets out the trends for species including
plants.  The Scotland specific summary contains commentary on protected
areas, woodlands and peatland, the impacts of land use activities, and
climate change.  This includes:
• A 15% decline in species abundance.
• A 15% increase in distribution of invertebrates due to climate
change.
• 11% of species in Scotland are now classified as threatened with
extinction.
• 57% decrease in plant and lichen distributions.
These declines are measured since 1994 so do not include earlier declines
through habitat loss.  The declines (and increases) overall in some species
does not reflect that there are large differences in individual species or
species groups.  43% of terrestrial and freshwater species showed a strong
or moderate decline over the last 10 years with 36% of species showing an
increase.  Moths for example have declined 18% since 1970 with the
majority of that decline occurring over the last 10 years.  The priorities
identified in this Report include:
• Vascular plants
• Bryophytes and lichens
• Species associated with arable farmland and semi-natural grassland.
• Upland birds
• Wading birds
• Wintering waterbirds
Other concerns which were highlighted in the Report are:
• 7% contraction in red squirrel range between 1993-2016.
• Significant decline in critically endangered pine hoverfly due to
habitat loss.
• 36% of vertebrates are threatened in Scotland.
• 31% of Amphibians and reptiles are threatened UK wide.
Tackling the Climate and Nature Crises
Scottish Government, Scottish National Adaptation Plan 2024 - 2029
This is the third national adaptation plan, which was developed in response
to the third UK Climate Change Risk Assessment.  It aims to build
Scotland’s resilience to climate change through supporting communities,
businesses, public services and nature to adapt to the changing climate,
and in a way that is fair and inclusive.   It contains a long term vision and a
set of over 200 policies and actions for the next five years.  The Climate
Change (Scotland) Act 2009 includes a legal duty across the public sector to
help deliver the objectives.

Page 18

The Plan’s vision ‘is for a resilient, inclusive and well-adapted Scotland as
the climate continues to change.’  The next five-year period is regarded as
critical to putting the country on the right path to achieving that vision. 
The Adaptation Plan also continue five outcomes and 23 objectives, which
are:
1. Nature Connects across our lands, settlements, coasts and seas,
through – nature-based solutions; landscape scale solutions;
development planning; nature networks; marine, coastal and the
blue economy, and natural carbon stores and sinks.
2. Communities are creating climate-resilient, healthy and equitable
place, through – regional and place-based collaborations; locally-
led adaptation; community resilience; new and existing buildings;
culture and historic environment, and coastal communities.
3. Public Services and Infrastructure are collaborating in effective and
inclusive adaptation action, through – public body duties and
capacity; public service and infrastructure resilience; Scotland’s
water resources, and transport system.
4. Economy, Business and industry are adapting and realising
opportunities in Scotland’s Just Transition, through – business
understanding of climate risk; support for farming, forestry, fishing
and aquaculture sectors; innovation opportunities, and economic
development and supply chains.
5. International Action i.e. Scotland’s internation role supports
climate justice and enhanced global action, through – supporting
vulnerable communities globally; international advocacy, and
knowledge advocacy.
Development Planning is regarded in the Adaptation Plan as a key lever in
helping places to adapt to current and future climate risks.  
The Scottish Government, Update to the Climate Change Plan 2018 –
2032: Securing a Green Recovery on a Path to Net Zero
This document updates the 2018 Climate Change Plan and includes new
ambitious targets to help end Scotland’s contribution to climate change by
2045.  The update provides a ‘Route Map to 2032’ with actions and targets
for each of the different sectors.  Those which are of particular relevance
to LDP3 are:
• 18,000 Ha of new woodlands created annually from 2024/25
onwards.
• 250,000 Ha of degraded peatland to be restored by 2030 at a rate of
20,000 Ha per annum, leading up to then.
• Renewable energy generation (Scotland) accounts for 50% of our
energy demand across electricity, heat, and transport by 2030.
• 21% of our land will be covered by forests by 2032.
• All public sector buildings are net zero by 2038.
• Net Zero Scotland by 2045.
With respect to the Land Use, Land Use Change and Forestry (LULUCF)
sector, the update recognises our landscape and natural environment as
our greatest assets, they not only contribute massively to our economy
and society, but also, how we use them is also seen as important too, to
our collective health and wellbeing. 
The two key pillars of LULUCF in Scotland are regarded as forestry and
peatland.  The expansion of Scotland’s forests and woodlands will help
contribute to a reduction in GHG emissions, as well as generate an
important commercial natural resource, improve biodiversity, and provide
spaces and places for people to enjoy.

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Peatlands form 20% of Scotland’s land cover.  In good condition they can
perform the role of a “carbon sink” by actively removing and storing
carbon from the atmosphere.  They also support habitats and species and
help to improve water quality and manage flood risk.  When degraded,
these peatlands can no longer perform these functions, but rather emit
more carbon than they can remove.   
Please note, the sections of the Evidence Report which look specifically at
the issues of Soils and Forestry, Woodland, and Trees explore in more
detail the relevant data and information in respect of peatland, and
woodland creation for the Perth and Kinross Area.  
The Scottish Government, Scottish Biodiversity Strategy to 2045 –
Tackling the Nature Emergency in Scotland and Scottish Biodiversity
Strategy Post-2020: A Statement of Intent, December 2020
There is an international consensus that urgent and transformative action
is needed to jointly address the twin crises of biodiversity loss and climate
change.  The loss of species and degradation of our natural environment
presents a real threat to human life on earth.  The Scottish Government’s
Biodiversity Strategy provides a framework for that response and makes it
clear that the ecological crisis is an emergency that requires urgent action. 
The National Biodiversity Strategy sets out a clear ambition for Scotland to
be ‘Nature Positive’ by 2030, and for biodiversity across the country to be
restored and regenerated by 2045.  In pursuit of the Strategy’s Vision, a set
of detailed Outcomes (to be achieved through actions in a number of
Delivery Plans) have been identified under 4 themes.  The Strategy also
identified 6 Objectives which have helped to shape the development of
actions.  These Objectives are:
1. Accelerate restoration and regeneration.
2. Protect nature on land and at sea, across and beyond protected
areas.
3. Embed nature-positive farming, fishing, and forestry.
4. Protect and support the recovery of vulnerable and important
species and habitats.
5. Invest in Nature; and
6. Take action on the indirect drivers of biodiversity loss.
The December 2020 ‘Scottish Biodiversity Strategy Post-2020: A Statement
of Intent’ established the direction for the new biodiversity strategy in
response to the increased urgency for action in tackling the twin climate
change and biodiversity loss challenges.  One of the key priorities identified
in the Statement was that:
‘We will extend the area protected for nature in Scotland to at least 30%
of our land area by 2030…’.
Nature Scot Climate Change and Nature Information Sheet 
This information sheet reiterates the link between climate and nature, and
highlights that a ‘nature-rich future is our best response to the climate
emergency.’  The sheet continues that as the planet is already ‘locked into
a lot of change’ we still need to adapt to that change alongside our efforts
in reducing emissions.  The delivery of nature-based solutions can help to
protect and enhance habitats; increase biodiversity; reduce net emissions
through capturing and storing CO2 from the atmosphere; reduce the
severity of floods, heatwaves, rising sea levels and storms.   The
enhancement and expansion of Scotland’s nature can also have added
benefits for people’s health and wellbeing and can support local
economies and food production and supply.

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Perth and Kinross Council Climate Change Strategy and Action Plan,
December 2021 and Climate Action website
In December 2021 the Council adopted its first PKC Climate Change
Strategy and Action Plan (CCSAP).  It was produced in response to the UK
Parliament and Scottish Government’s environment and climate
emergency declaration statements in Spring 2019.  The purpose of the
CCSAP is to turn the intent of the Council’s support for these emergency
declarations into practice.  It sets out the next steps and an initial route
map to take us to a net zero carbon and climate resilient Perth and Kinross.  
Public engagement work was carried out on the Draft Strategy and Action
Plan during 2020 and 2021 to help shape the final documents.  The results
of this exercise have also been provided on the Council’s dedicated Climate
Action website and are explored in more detail later under the Stakeholder
Engagement section of this paper.  
The Strategy sets out the legislative framework, including national targets;
outlines key emissions trends; establishes six overarching principles to
shape the long-term approach to climate change for the area (See Figure
A1(12) to follow), and contains 27 Council Commitments which are needed
to achieve the outcomes. 
Figure A1(12): PKC’s Six Overarching Climate Change Strategy Principles
The Action Plan is then divided into 8 thematic areas: Transport; Buildings
and Energy; Business and Industry; Waste and Circular Economy; Land Use
(incorporating LULUCF); Climate Resilience; Education and Engagement,
and Governance.  For each of these thematic areas or sectors, it provides
details on - existing action to date within the area; a list of key themes for
each sector and related actions; a Road Map to deliver these actions; key
challenges and opportunities, and corresponding Key Performance
Indicators (KPIs) to help measure progress.   
Originally, 146 Actions were identified in the Council’s Climate Action Plan,
spread across the 8 themes.  That number has since risen to approximately
204, because of new actions being identified through the Council’s 8
internal Climate Change Working Groups, which are made up of officers
from different teams across various Council services, who are tasked with
the delivery of the actions, often in partnership with other stakeholders. 
The groups regularly review their list of actions to ensure they remain
1. Achieving Net Zero aligned with the Paris Agreement and the
Scottish Government Targets, with the ambition of achieving them
sooner.
2. Building a more resilient Perth and Kinross.
3. Ensuring climate action is fair and benefits all and we deliver a
green recovery from Covid-19.
4. Enhancing biodiversity to help avoid an ecological emergency.
5. Engaging and empowering young people to take action on climate
change.
6. Empowering our communities and businesses to take climate
action in line with the Perth and Kinross Offer.

Page 21

appropriate.  To date, a number of the actions have already been or are
close to being delivered, and progress against these actions is regularly
monitored.   A more detailed summary of this progress is provided under
the review of the Council’s Climate Change Year 3 Annual Report to follow.     
Perth and Kinross Council, Climate Change Year 3 Annual Report, October
2023 - September 2024
The Council also produces a Climate Change Annual Report to provide an
update on progress on the implementation of the Strategy and Action Plan. 
The most recent report covers the period October 2023 to September
2024 and confirms that at that time 65% of the Climate Change KPIs
showed positive change.  However, the Report does note that whilst our
performance data highlights that we are trending in the right direction,
there is a need to accelerate the pace of action to remain aligned with the
Paris Agreement and national targets.       
The progress status of the Council’s identified 204 Actions, as of
September 2024, is shown in Figure A1(13) to follow.  There has been an
improvement on September 2023 progress, with 9 actions moving out of
the red category and 19 additional actions being completed.  It is
important to note that a large portion of the actions are on-going or long
multi-year actions which would not be expected to have reached a
complete status.  The ‘Removed Actions’ in the chart are mainly actions
that this year have been consolidated into other actions in order to ensure
consistency in what is classified as a strategic or supporting action across
all the themes. 
Figure A1(13): Full PKC Climate Change Action Plan Action RAG Status,
September 2024
Figure A1(13) is an extract from the PKC Year 3 Climate Change Annual Report
To ensure the most important actions are prioritised, the Council
designated 25 top priority actions.  These focus on achieving area-wide
emissions reduction, the Council’s emissions reduction, and building
resilience to climate change.  Figure A1(14) highlights the overall progress
of these top priority actions. 
74, 36%
55, 27%
25, 12%
28, 14%
22, 11%
A G R Complete Removed

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Figure A1(14): Top 25 Priority Actions RAG Status 
Figure A1(14) is an extract from the PKC Year 3 Climate Change Annual Report
The Annual Report identifies several cross-cutting challenges or barriers to
the wider programme delivery, including:
• Shifting and uncertainty of government targets and the associated
regulatory requirements with an impact on the ability to align work
and convince others to act.
• The need to identify and unlock funding opportunities to ensure
future targets are achieved, in an uncertain funding landscape.  This
often requires the Council to have developed projects to a ‘shovel
ready’ stage prior to bidding and often only cover capital costs.  This
positively has started to change recently in recent funding schemes
from IUK and others. 
• Resource and skills gaps within both the Council and wider supply
chain to be able to upscale at pace to meet Net Zero targets.
• Challenges in recruitment and retention of internal staff with the
required skills, knowledge and experience has been time consuming
and led to delivery delays. 
• Data timelines and availability Is a challenge to understand the
effectiveness of our actions and make appropriate adjustments. 
Several of the key datasets have 1–2-year compilation windows.
• How to accelerate our pace of action and increase our scale of
impact to meet the necessary targets, whilst dealing with the above
challenges.
Perth and Kinross Council, Consultation Draft Mobility Strategy, and
Tactran, Regional Transport Strategy 2024-2034
The Council’s recently published Draft Mobility Strategy sets out the
Council's vision for managing and developing the transport network across
the area.  It considers all modes of transport for the movement of goods
and people, across our urban and rural areas, to help achieve the national
targets and outcomes established under the National Transport Strategy 2
(NTS2), and the key issues and action targets identified under Tactran’s
Regional Transport Strategy 2024-2034.  
The Regional Transport Strategy’s (RTS) key outcome ‘To Take Climate
Action’ seeks to:
• Increase the share of EV and low emission vehicle use through
promoting Ultra Low Emission Vehicle (ULEV) adoption.
• Reduce car kilometres driven in line with the national reduction
target of 20% by 2030 (compared to 2019 levels).
Actions identified under the RTS outcomes ‘Increase the levels of walking
and cycling in the least affluent SIMD data zones’, and ‘Reduce transport
emissions in declared air quality management areas’, could also potentially
contribute to climate change mitigation and adaptation.  
The Council’s Draft Mobility Strategy responds to the climate change
agenda and changes in how people travel.  It also considers emerging
10, 40%
11, 44%
4, 16%
Green Amber Complete

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technologies, digital services, housing, inclusion, poverty, health, climate
adaptation, economic growth, air quality, and placemaking.  It contains 11
Transport Planning Objectives.  
In response to the NTS2 priority and RTS outcome on taking climate action,
and recognising the impact emissions from the transport sector have on
the area’s greenhouse gas emissions levels, along with the need to future
proof transport infrastructure against the impacts of a changing climate,
the Draft Mobility Strategy identifies 2 objectives:
• To reduce CO2 emissions produced by transport across Perth and
Kinross, by reducing car kilometres, decarbonising motorised
transport, and increasing the share of everyday journeys of people
and goods by sustainable and active travel modes. 
• To improve climate resilience across Perth and Kinross’s transport
network by reducing the impacts caused by extreme weather events.
The Draft Strategy’s accompanying Action Plan also identifies a number of
strategic actions linked to its ‘Sustainable Transport’, ‘Organisation,
Planning and Regulations’, ‘Innovation and Future Mobility’, and ‘Road
Network’ themes, which, when delivered, will contribute to efforts in
tackling climate change across Perth and Kinross.
James Hutton Institute, Carbon Sequestration Study of Perth and Kinross
Council Area, December 2021
The Council commissioned the James Hutton Institute (JHI) to undertake a
Carbon Sequestration Study of the Perth and Kinross Council Area.  The
study’s concluding report was submitted to the Council in December 2021. 
The project focussed 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 or reducing GHG
emissions.  
UK Climate Change Committee (UKCCC), Progress in reducing emissions in
Scotland – 2023 Report to Parliament (March 2024)
The UKCCC’s March 2024 Report monitors Scotland’s progress in reducing
emissions and assesses the policies in place for delivering future reductions
in emissions.  The Report states in its Executive Summary that the Scottish
Government is failing to meet the ambitious national climate goals. 
Annual emissions targets have been missed repeatedly, and the
publication of Scotland’s Draft Climate Change Plan has been delayed from
its 2023 publication date.   As such, there is a lack of a comprehensive
delivery strategy for meeting future emissions targets and progress against
actions is continuing to fall short of legal requirements. 
Whilst the Report acknowledges “some early signs of good progress”,
urgent and significant action is thought to be needed to turn Scotland’s
targets into effective delivery and achieve the necessary levels of
emissions reductions at the earliest date possible.   With respect to the
development of our LDP3 Proposed Plan, this means that we require to
ensure our Forestry and Woodland Strategy is up to date to support the
Perth and Kinross Area’s contribution to the national targets for new
woodland creation, and that we identify and protect the area’s most
valuable soils, including those areas of peatland with restoration potential.

Page 24

Vulnerability to Climate Change Risks within Perth and Kinross
Scottish Index of Multiple Deprivation (2020)
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 186 (4%) are
within the 15% most deprived; 3 out of 186 (2%) are within the 10% most
deprived areas, and 44 out 186 (%) are within the 20% least deprived areas
in Scotland.  The most deprived areas in Perth and Kinross can be found in
Perth (Muirton, and Hillyland, Tulloch and Inveralmond), and Blairgowrie
East (Rattray).
Map A1(1): SIMD Map for the Perth and Kinross Council Area (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 and the Tay Estuary and
Montrose Basin Local Flood Risk Management Plan
In 2018 the SEPA National Flood Risk Assessment (NFRA) identified 21
Potentially Vulnerable Areas (PVAs) within, overlapping or immediately
adjoining the Perth and Kinross Council (PKC) Area.  The PVAs of relevance
to the PKC Area are: Aberfeldy, Alyth, Auchtermuchty, Bankfoot, Blackford,
Blair Atholl, Blairgowrie and Rattray, Bridge of Earn, Comrie, Coupar Angus,
Cowdenbeth, Dalwhinnie, Dundee, Broughty Ferry and Invergowrie,
Dunkeld and Birnam, Hillfoot villages, Kinross, Milnathort and Glenrothes,
Luncarty and Stanley, Perth and Almondbank, Pitlochry, and Scone. 
Flooding in Scotland is managed through 14 local plan districts which are
based on river catchments.  Perth and Kinross Council is the lead authority
for the Tay District as well as being involved in 3 other surrounding districts
– the Forth, Forth Estuary, and the Tay Estuary and Montrose Basin.  The
Local Flood Risk Management Plans (FRMPs) for these districts
supplement, and are consistent with SEPA’s plans, but also set out the
responsibilities, timescales, local coordination, and funding arrangements
for the implementation of the selected actions.   The main focus of the
local FRMPs is to manage flood risk in PVAs, where specific actions apply in
addition to the general actions.  
In 2021, there were 22 Flood Risk Management Target Areas within Perth
and Kinross at: Blair Atholl, Spittalfield, Weem, Aberfeldy, Almondbank,
Alyth, Bankfoot, Blackford, Blairgowrie and Rattray, Bridge of Earn, Comrie,
Coupar Angus, Dunkeld and Birnam, Invergowrie, Kinross, Luncarty,
Methven, Perth, Pitlochry, Scone, Dalguise, and Milnathort.

Page 25

Map A1(2): SEPA Flood Risk Management Target Areas and PVAs (2020)
Areas within Perth and Kinross identified as having high potential for
floodplain storage (Current SEPA 1:200 year flood outline) are at: Kinross
and Milnathort, Blackford and Greenloaning, Dunning, Crieff, Madderty
and Balgowan, Bridge of Earn, Perth, Huntingtower, Ruthvenfield, Scone,
Luncarty, Errol Station, Inchture, Rait, Grange, Spittalfield, Dalguise,
Dowally, Guay and Kindalachan, Ballinluig, Logierait, Blair Atholl, Tummel
Bridge, Aberfeldy, Weem Village, Meikleour, Coupar Angus, Kettins,
Meigle, Alyth, Blairgowrie and Rattray.
The Scotland Wetland Inventory
Wetlands are a natural water-storage feature on the landscape.  The
Scotland Wetland Inventory is a database of wetlands in Scotland created
by SEPA using data from Nature Scot.  The Inventory indicates that there is
approximately 293.1 Km2 of wetlands in the Perth and Kinross Area, the
majority of which are located in the northern half of the area.  
Map A1(3): SEPA Scotland Wetland Inventory
Perth and Kinross Council Air Quality Webpages
The Council measures the air quality of the area at more than 80 locations
using specialist equipment, including 4 automatic air quality monitoring
stations.  By law, PKC must assess the presence of 8 pollutants, and the
levels we measure are set at a level to protect the public’s health.  
Recent assessments show that PKC’s air quality meets the Scottish
Government’s objectives for 5 of these pollutants, which do not require to
be monitored.  However, for the other 3 pollutants (Nitrogen Oxide (NO2),
Particulate Matter (PM10), and Fine Particulate Matter (PM2.5) assessments

Page 26

show that they exceed or may likely exceed the Scottish Government’s
objectives at a few isolated locations.  As such, the Council must monitor
more detailed levels of these pollutants. 
Where monitoring indicates that levels of a particular pollutant will exceed
the objective level set by National Air Quality (Scotland) Regulations in any
given year, the area in question should be designated as an Air Quality
Management Area (AQMA).  There are currently 2 AQMAs in Perth and
Kinross: Perth City and Crieff High Street, which were originally declared
due to levels of road traffic pollutants (NO2 and PM10) being found to be
above the air quality objectives.
As a result of measures implemented over recent years, improvements in
the air quality have already been seen within both AQMAs.  Pollutions
levels within the Crieff AQMA have remained within objectives for several
years.  Levels in Perth are also below the objective in the majority of
locations. 
Scottish Household Survey (SHS) Environment Statistics 2022 and Scottish
Household Survey (SHS) Environment Statistics 2023
The SHS is an annual survey of the general population in Scotland and has
been carried out since 1999.  The survey aims to collect reliable and up to
date information on a number of topics, including neighbourhoods and
environment, via a random sampling of people in private residences.  The
most recent publication is the 2023 SHS.
The SHS Neighbourhoods data provides a picture of how residents rate
their neighbourhoods as a place to live.  In 2023, the data reports that the
percentage residents of Perth and Kinross who rated their neighbourhood
as very/fairly good was 95%, which is the same as the Scotland figure.  64%
of residents ranked their neighbourhood as very good; 30% as fairly good;
4% as fairly poor, and 1% as very poor.  These percentages are fairly similar
to the Scotland figures for each of the rankings, which are 95%, 55%, 40%,
4% and 1% respectively.  The percentages for the Perth and Kinross Area
have also remained similar throughout the years since the first survey
undertaken in 1999.  
The SHS Environment Survey was first carried out in 2013 and as such does
not report year on year data for as far back as 1999.  The survey asked
residents their perceptions about climate change as a problem, and further
queried the percentage of adults perceiving that problem to be immediate
and urgent by various classifications or profile information.  The
comparative results of the survey for the Perth and Kinross Area for both
2013 and 2023 are as follows: 
• % of adults in Perth and Kinross perceived climate change as an
immediate and urgent problem:
o 74% in 2023 (74% for Scotland as a whole).
o 46% in 2013 (46% for Scotland as a whole).
• % of adults perceived climate change as more of a problem for the
future:
o 14% in 2023 (11% for Scotland as a whole).
o 22% in 2013 (25% for Scotland as a whole).
• % of adults perceived climate change as not really a problem:
o 0% in 2023 (3% for Scotland as a whole).
o 9% in 2013 (7% for Scotland as a whole).
• % of adults were still not convinced that climate change is
happening:
o 6% in 2023 (6% for Scotland as a whole).
o 17% in 2013 (13% for Scotland as a whole).

Page 27

• % of adults thought none of the above:
o 1% in 2023 (1% for Scotland as a whole).
o 3% in 2013 (3% for Scotland as a whole).
• % of adults responded that they don’t know:
o 4% in 2023 (5% for Scotland as a whole).
o 4% in 2013 (7% for Scotland as a whole).
The change in percentages in just under a 10-year period shows that
people appear to generally be more aware of climate change and are
increasingly concerned about the impacts and risks that it brings.
The SHS Environment Survey also asked adult residents whether they
agreed with a number of different statements relating to the environment,
the most recent year of survey results based on these statements is 2022. 
The first statement was: ‘It’s not worth me doing things to help the
environment if others don’t do the same.’   The response for adults within
the Perth and Kinross Area was:
• 5% strongly agree (4% of Scotland as a whole).
• 15% tend to agree (8% of Scotland as a whole).
• 11% neither agree nor disagree (10% of Scotland as a whole).
• 39% tend to disagree (24% of Scotland as a whole).
• 31% strongly disagree (48% of Scotland as a whole).
• 0% don’t know (3% of Scotland as a whole).
• 0% have no opinion (3% of Scotland as a whole). 
Another statement which adult residents were asked whether they agree
with or not was: ‘I don’t believe my behaviour and everyday lifestyle
contribute to climate change.’  In 2022: 
• 1% of adults in Perth and Kinross strongly agreed with this statement
(4% Scotland figure).
• 11% tend to agree (same as Scotland figure).
• 14% neither agree nor disagree (12% Scotland figure).
• 40% tend to disagree (27% Scotland figure).
• 34% strongly disagree (39% Scotland figure).
• 0% don’t know (3% of Scotland figure), and 
• 0% has no opinion (4% Scotland figure).
The percentage figure for adult residents who strongly disagree with the
statement has gone up by 14% since the first time this question was asked
in the survey in 2015.   For the rest of the rankings, the percentages have
gone down, which is a positive trend in relation to residents who agreed
with the statement.
Taylor McKenzie Research and Marketing Ltd., Tactran Quantitative
Research, October 2023
In the development of their updated Regional Transport Strategy (RTS),
Tactran commissioned Taylor McKenzie to conduct representative market
research of the publics’ view on the proposed approach to the Draft RTS,
and the impacts that may arise because of this approach, and any
alternative options that should be included.   The research outputs were
then used to: determine how the developing RTS will respond to the
necessary scale of change; identify types of measures and/or places for the
RTS to focus its policy support, and also inform Councillors and other
decision makers of the likely implications of the policy options under
consideration as part of the Draft Strategy.  
In terms of transport usage across the Tactran region, the survey results
summarised that:
• There is a visible correlation between affluence and transport usage.

Page 28

• Bus usage increases as affluence decreases, and the more affluent
the area, the less likely a resident is to use a bus.
• The car is the most popular transport mode, with access to cars
increasing with affluence.  However, despite lower access to cars in
SIMD Quintile 1 (most deprived), those who do currently use a car
are amongst the more likely to state that they could not use public
transport. 
In response to questions regarding ‘Climate Change Attitudes’ the research
found that across the residents, attitudes were varied but consistent:
• Overall, 85% believe they personally have a duty to help tackle
climate change, and 80% see climate change as an immediate and
urgent problem. 
• There was a correlation between levels of affluence and attitudes
about climate change.  Those living in affluent areas are more likely
to agree that climate change exists, it needs addressed urgently, that
they have a personal duty to address it, and can help address it. 
• 19% of respondents believe that climate change is more of a future
problem (and 7% are not convinced climate change is actually
happening, while 4% think it is not really a problem).
• Generally, those in lower SIMD areas are less likely to agree,
however there are some regional differences.  Dundee stands out as
being the most likely area to agree climate change is happening and
agree with the statements in the survey about tackling it, the Perth
and Kinross area was less so. 
• 74% agree that it is primarily the government’s responsibility to
combat climate change. 
Participants were asked about their willingness to change travel.  In
response: 
• Overall, 53% of the sample surveyed agreed that they would be
willing to change how they travel to help in achieving climate
change targets.  This was higher than changing when they travel
(41%) or where they travel (39%).  This willingness is significantly
higher in Dundee compared to other areas, and especially higher
than average within the least deprived SIMD quintile.  A willingness
to change was lowest within Perth and Kinross.
• 50% of the urban sample would be willing to change how they
travel to help in reducing air pollutants that can negatively impact
on health – willingness was higher in Dundee (69%) and those in
higher affluence areas.
• The urban sample was overall slightly more motivated to make
changes based on ‘assisting reducing air pollutants that can
negatively affect health’ over ‘assisting in the climate change
targets.’
• Overall, 42% of residents think that the transport provision in their
area is currently sufficient to enable them to make the required
changes to how they travel.
In respect of questions regarding the ‘Use of Resources’ there was high
levels of agreement amongst the residents that resources should be
used for locations and trips where the most kilometres are driven
(72%), and to help the most vulnerable in society to help them access
jobs, training and services (health care/shops) (86%). 
Survey participants were also asked about the Scottish Government’s
National Transport Strategy 2’s 4 key objectives of: Take Climate
Action, Reduce Inequalities, Improve Health and Wellbeing, and
Support Inclusive Economic Growth.  Of the objectives, ‘Improving
Health and Wellbeing’ was viewed as the biggest priority (and
consistently the main priority across SIMD groups), and ‘Take Climate
Action’ was 3rd out of the 4.  In the Perth and Kinross Area, respondents
ranked ‘Take Climate Action’ as the least important objective.   The

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level of priority taking climate action is given generally rose alongside
affluence and was the least prioritised by those in SIMD Quintile 1.

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Summary of Implications for the Proposed Plan:
LDP Spatial Strategies
Part 1 of National Planning Framework 4 contains six Spatial Principles
NPF4 asks that we plan our future places in line with these six overarching
spatial principles so that our places work for everyone.  
Through applying this approach, the spatial strategy developed for LDP3
should be an integrated one, bringing together cross-cutting priorities in
order to achieve sustainable development, rather than having to
compromise between environmental, social, and economic objectives.  The
Strategic Environmental Assessment (SEA) for LDP3 will also help the Plan
strike a balance between these different objectives, identifying and
directing the right development to the most appropriate and sustainable
locations.  
Gaps, Uncertainties or Key Issues Raised: NPF4 Policy 1 states that LDPs
must address the global climate emergency and nature crisis via their
spatial strategies.  As previously noted, Policy 1 will be implemented
through the collective impact of all the other national planning policies. 
Further detailed and relevant data and information gaps and uncertainties
can be found, in particular, under the corresponding sections of the
following ‘Issues’ in this Evidence Report, and their related background
Topic Papers: Biodiversity and Natural Places; Soils, Forestry, Woodlands
and Trees; Brownfield, Vacant and Derelict Land, and Empty Buildings;
Coastal Development and Aquaculture; Energy, Heating and Cooling
(including Infrastructure: Energy Supply Systems); Zero Waste; Local Living
and 20 Minute Neighbourhoods; Green and Blue Infrastructure; Flood Risk
and Water Management, and Infrastructure. 
Perth and Kinross Local Development Plan 2 (2019)
When starting any Local Development Plan review, it is important to
recognise that we are not starting from scratch.  A wealth of information
and evidence already 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
under its spatial strategies to help create successful, sustainable, low-
carbon, natural and resilient, and connected places.  
It is also necessary to monitor how successful the implementation of LDP2
has been to date to understand if the existing spatial strategies are fit for
purpose and which aspects of those strategies can be carried forward into
our Proposed LDP3.  However, this should be viewed within the context of
the changes to national planning policy under the 2019 Planning Act and
NPF4, and updates to the Council’s Corporate as well as Community
Planning plans and strategies.
Greenhouse Gas Emissions and Lifecyle Assessments
National Planning Framework 4 – lifecycle greenhouse gas emissions:
assessment findings and the ESPON – Quantitative Greenhouse Gas
Assessment tool for Spatial Planning
Under NPF4 Policy 2, LDP spatial strategies are expected to be informed by
an understanding of impacts of the Plan’s proposals on GHG emissions.

Page 31

These tools should assist the Council in better understanding the likely
effects of different proposals on GHG emissions, and the potential direct,
indirect, and overall effect of proposals on GHG emissions.   This should in
turn guide the development of the Plan’s spatial strategy and the
identification of development proposals to help reduce, avoid, or minimise
GHG emissions.
Gaps, Uncertainties or Key Issues Raised: Greenhouse gas emissions
lifecycle assessments – It is considered that this requirement will be most
appropriately dealt with at the Proposed Plan preparation stage, as at this
stage in the plan preparation process “detailed policies and site proposals
should not be included in the Evidence Report [and] detailed site appraisal
will not be appropriate…”5  As such, it is not known at this time whether or
not data or information gaps or uncertainties may arise when applying
either of these methodologies to individual development proposals, at
Proposed Plan stage.   It is suggested that to ensure that lifecycle
assessments are undertaken when preparing the Proposed Plan, an action
could be to include a question in the LDP3 Site Appraisal template
requiring a GHG lifecycle assessment for site proposals.    However, it
should be noted that this is a new field of expertise which local authorities
will need to develop a greater understanding of. 
Currently, no data is available for planning applications re GHG emissions
lifecycle assessments for existing, or recently submitted proposals. 
However, it is anticipated that the availability of this data may improve
between now and Proposed Plan preparation stage with NPF4 policies 2 a) 
5 Paragraph 108, Scottish Government Local development planning guidance, May
2023 
and 26 f) criterion.  This will require monitoring to be put in place in the
interim to identify relevant applications.
Department of Energy Security and Net Zero (DESNZ) Data 2022
The DESNZ data is an extremely useful data source, which provides an
understanding of current GHG emissions levels across Perth and Kinross
(including trends from 2005 to 2022).  As previously highlighted, the data
shows us that the Land Use, Transport and Agriculture sectors are the
largest GHG emitters across the area, and that although some progress has
been made to date, the Council Area is not currently on a trajectory with
the Scottish Government’s emission targets.  Many of the activities
occurring within these sectors which result in high GHG emissions levels
are outwith the scope of land use planning and the Council’s influence, and
will require a holistic and partnership approach, across many stakeholders,
to help realise national net zero emissions targets.
In terms of LDP3, the DESNZ data was helpful in guiding the development
of Council’s Climate Change Strategy and Action Plan.  These documents
contain key objectives and actions for each of the themes, which should be
reflected in our Local Development Plan, where appropriate, to help guide
the development of the Plan’s Spatial Strategy and the identification of
proposals in a manner that will reduce, avoid, or minimise emissions.  It
will also provide a baseline against which the effectiveness of LDP3’s
spatial strategy can be monitored in the future via the SEA process.
Gaps, Uncertainties or Key Issues Raised: Data is released by DESNZ
approximately 18 months after year end.  The most recent data available is

Page 32

the 2005 to 2022 publication.  It is worth noting that prior to the 2005 to
2020 publication, the DESNZ statistics covered emissions of Carbon Dioxide
(CO2) only.  Since then, it has also reported on Methane (CH4), and Nitrous
Oxide (N2O) at a local authority level.  This means that it is not possible to
monitor trends in data for these emission types for the Perth and Kinross
Area prior to 2020.
The Scottish Government, Climate Change (Emissions Reduction Targets)
(Scotland) Act 2024
This Act amends the Climate Change (Scotland) Act 2009 through replacing
the system of annual and interim emissions reduction targets, which are
concerned with Scottish emissions of GHGs in a given year, with a system
of periodic carbon budgets which concentrate on emissions over a five-
year period.  It also adjusts when the Scottish Government must next
produce a climate change plan to allow for that next plan to reflect the
new carbon budgets system.  Secondary legislation is expected to set out
the relevant detail of how the Act will be implemented in terms of the
setting of carbon budgets and any implications for local authorities/public
bodies as a result.  However, the overall Net Zero Emissions 2045 target is
still in place, and the Council, as a public body are still required to work
towards contributing to the achievement of that. 
Gaps, Uncertainties or Key Issues Raised:  The Act has only recently
come into being, and the details of how it will be implemented, as well as
any implications for public bodies in respect of their climate change duties
under the 2009 Act, are as yet unknown.  It is expected that the
introduction of secondary legislation and any related guidance will provide
more information in due course.
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)
Having a better understanding of the climate risks affecting, or likely to
affect the Perth and Kinross Area allows us to develop a spatial strategy
which avoids allocating development in the most vulnerable locations,
exacerbating those risks as a result.  It will also help to protect our
communities and assets (biodiversity, natural, and man-made) and build
resilience through identifying adaptation and mitigation measures.  A
spatial strategy which seeks to achieve sustainable development 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 can also help us to realise
some positive opportunities, including those identified through the
Council’s CCROA.
Our Changing Nature
The State of Nature Partnership, State of Nature Report 2023
Through having an awareness of these species, it can help with prioritising
which actions need to be taken, and also avoided, in order to protect and
conserve species through spatial strategies and policies.

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Gaps, Uncertainties or Key Issues Raised: The Biodiversity and Natural
Places Issue for this Evidence Report, and its corresponding background
Topic Paper explore the gaps and uncertainties with respect to data and
information on protected areas, habitats, and species.  Many of the
assessments of scope, condition, and abundance of these areas and
species are currently out of date; still in the process of being assessed, or
not available at a local authority level.  
Tackling the Climate and Nature Crises
Scottish Government, Scottish National Adaptation Plan 3 2024 - 2029
Scottish Government: Update to the Climate Change Plan 2018 – 2032:
Securing a Green Recovery on a Path to Net Zero
Scottish Government Scottish Biodiversity Strategy to 2045 – Tackling the
Nature Emergency in Scotland
Scottish Government, Scottish Biodiversity Strategy Post-2020: A
Statement of Intent, December 2020
Nature Scot, Climate Change and Nature Information Sheet
As already mentioned under the summary of evidence for the ‘Our
Changing Climate – Scotland and Perth and Kinross’ section, through
developing a better understanding of the climate risks currently affecting,
or likely to affect the Perth and Kinross Area we can develop our LDP3
Spatial Strategy in a way that helps avoid exacerbating the risks associated
with climate change to our most vulnerable people and in our most
vulnerable locations.  It can also help us to prioritise action and
investment, protect our assets, introduce climate change adaptation and
mitigation measures, and help build resilience. 
It is important that Perth and Kinross Council’s plans and strategies reflect
national policies, key actions, and outcomes, and that they are developed
through taking account of national advice in respect of adapting to a
changing climate, so that we can contribute towards achieving national
targets relating to emissions reductions, woodland creation, climate
change mitigation and adaptation, and protecting and enhancing habitats
and species.  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. 
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 2023-2033
Consideration of data, information and relevant actions that are contained
in the Council’s Climate Change Strategy and Action Plan will ensure that
development of the LDP3’s Spatial Strategy reflects the Council’s corporate
position on climate action, and those relevant actions identified in the
Action Plan, whose delivery can be supported via the land use planning
system, are included within LDP3.  It will also allow for the closer
monitoring of implementation of some of those actions.  
Through its Spatial Strategy, LDP3 can help support the delivery of some of
the RTS and Mobility Strategy actions in relation to active and sustainable
travel networks, and improvements to the transport network and its
associated infrastructure to help make it more resilient to the impacts of
climate change.

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Gaps, Uncertainties or Key Issues Raised:
PKC Climate Change Strategy and Action Plan - It is worth noting that 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.  For example:
• Business and Industry theme – lack of relevant data available around:
tourism businesses and Green Certification Scheme; % of businesses
with 250+ employees or largest energy demand (+0.5M) with carbon
emissions reduction targets. 
• Land Use theme – lack of or limited data on area of peatland
restored, and % of local and major planning consents which contain
approvals for biodiversity net gain.
• Resilience theme – up to date RAG (Red, Amber, Green) status of
flood risk management actions.
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.   
Perth and Kinross Council, Consultation Draft Mobility Strategy and
Tactran, Regional Transport Strategy 2023-2033
In their response to Topic Paper 004: Tackling the Climate and Nature
Crises, Tactran noted “that the potential for active travel to contribute to
climate change mitigation and adaptation is rather limited.”  Furthermore,
it is their view that “it is difficult to understand the scale of the problem
and the potential impact of new development on climate change without
knowing the baseline and forecast implications of existing and new
transport (specifically impact of traffic on greenhouse gas emissions) e.g.
existing and forecast traffic levels and ULEV adoption.” 
James Hutton Institute, Carbon Sequestration Study of Perth and Kinross
Council Area, December 2021
The JHI project report identifies some actions relating to the assessment
and use of natural resources which could be taken forward to help in
achieving net zero emissions.  This report can help guide the development
of the Plan’s Spatial Strategy, through highlighting existing sources of GHG
sequestration and storage, and identifying new opportunities, primarily
liked to tree planting and peatland restoration.  
Gaps, Uncertainties or Key Issues Raised: The JHI PKC Carbon
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

Page 35

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
Gaps, Uncertainties or Key Issues Raised:
Technological Sinks and Stores - The Council currently has no data available
in relation to technological sinks and stores as suggested for inclusion
under the Scottish Government’s May 2023 Guidance.
Local Living and 20 Minute Neighbourhoods Evidence - The Scottish
Government’s Guidance provides advice under its ‘Step by step guide’
section, regarding relevant evidence for NPF4 policy topics, to help
planning authorities in considering the national planning policies when
preparing their Evidence Report.   In respect of details of climate risks likely
to affect the plan area, the Guidance suggests that evidence referenced in
relation to other policies, including that on local living and 20 minute
neighbourhoods may be relevant.  At this stage, work has not begun on
identifying local living and 20 minute neighbourhoods across the Perth and
Kinross Area.  More detailed information will be gathered via the
Settlement Audit process as part of the preparation of the Proposed Plan. 
Due to the varying nature of the area (both urban and rural) it is likely that
a methodology or methodologies will be required to be developed that can
be applied to the different geographies.  
UK Climate Change Committee (UKCCC), Progress in reducing emissions in
Scotland – 2023 Report to Parliament (March 2024)
This UKCCC’s report and recommendations provides the Council with a
clear picture of the sectors in which significant progress needs to be made
(across Scotland) and at a rapid scale to achieve the necessary levels of
emissions reductions at the earliest date possible.  The LDP3 Spatial
Strategy should seek to deliver sustainable development and the creation
of sustainable communities.  Our Forestry and Woodland Strategy should
help facilitate enhanced woodland creation to contribute to achieving
Scottish planting targets, whilst ensuring the delivery of the right tree in
the right place as per Scottish Government Guidance.   Our work on Nature
Networks as part of LDP3 should, along with the Peatland ACTION Project,
identify areas for restoration and explore mechanisms for delivery with
partners. 
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
Scotland Wetland Inventory
Perth and Kinross Council Air Quality Webpages
Scottish Household Survey (SHS) Environment Statistics 2022 
Scottish Household Survey (SHS) Environment Statistics 2023
Taylor McKenzie Research and Marketing Ltd., Tactran Quantitative
Research, October 2023
The above data sources provide us with a better understanding of the
climate risks affecting, or likely to affect the Perth and Kinross Area, as well
as the public’s attitude towards climate change and making changes to
help tackle the issue, allowing us to develop a spatial strategy which avoids

Page 36

allocating development in the most vulnerable locations, or on areas which
provide benefits to biodiversity and serve as natural flood storage,
exacerbating those effects and the impacts felt by those most at risk as a
result.  It will also help to protect our communities and assets (biodiversity,
natural, and man-made) and build resilience through identifying
adaptation and mitigation measures.  
It is important when assessing the likely impacts of our proposed Spatial
Strategy to consider not just the effects on the immediate area within and
surrounding a site, but also up and down stream of the location.  A spatial
strategy which seeks to achieve sustainable development can help
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.
Gaps, Uncertainties or Key Issues Raised: 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 wetland areas which have not yet been surveyed or for which
survey data is not available digitally.

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Summary of Stakeholder Engagement:
Perth and Kinross Climate Change Strategy and Action Plan 
Engagement on the Draft Strategy and Action Plan took place between
October 2020 to January 2021.  The detailed results of the engagement
process can be viewed on the Council’s Climate Action website (Appendix
A to the Report to Council for the Draft Climate Change Strategy and
Action Plan).  A graphic summary of the key issues raised by consultees is
also provided on the Council’s Consultation Hub. 
Due to the Covid-19 Pandemic, engagement consisted of an online survey
which was split over thematic questionnaires – (480 responses received),
and several online thematic sessions supported by the Perth and Kinross
Climate Change network (over 240 attendees).  The thematic areas are:
General (including domestic waste and resilience), Transport, Buildings and
Energy, Business and Industry, and Land Use.
The engagement process not only looked at the wider issues associated
with the climate and nature crises, but also drilled down into a series of
themes, to help gauge the level of public understanding and awareness on
these subjects, and to identify examples of existing good practice which
could be rolled out further across Perth and Kinross, as well as areas for
action, and potential future projects.  
The overall results indicated that individuals across Perth and Kinross are
concerned about climate change and its impacts.  Almost all respondents
(91%) believe that climate change has already impacted the environment
around them.  Some of the changes noted were extreme weather events
including increased temperature levels over longer periods and increased
flooding.  Furthermore, the concern of respondents in relation to climate
change is also demonstrated by the fact that 84% had made lifestyle
changes to minimise their impact on the environment.  Examples given
include reduced car usage and increased use of more sustainable and
active travel methods (cycling and walking), as well as reducing single use
products and increasing recycling.
Respondents were aware of the Scottish Government’s targets in relation
to climate change, with 88% of respondents feeling that Perth and Kinross
should go beyond the Scottish Government in target setting.  The need to
set out a clear vision to reach net zero was supported by 63% of the total
responses.  The engagement survey feedback aligns with the national level
of concern regarding climate change.  The 2019 Scottish Household Survey
(which was current at the time of the engagement exercised) highlighted
that there had been an increase in the percentage of adults in Scotland
who agree climate change is an immediate and urgent problem, with 68%
having this view.  The most recent survey results show that this figure has
jumped to 81% (see details under previous ‘Summary of Evidence’ section). 
Some overarching themes were raised by a large number of respondents.
Almost 90% of overall respondents mentioned that Perth and Kinross
Council should lead by example and set its own targets.  The need for the
Council to work together with all stakeholders in its journey to reach net
zero was also outlined as a key action.  In addition, continuing to engage
with the public and raising awareness was emphasised in over 80% of the
comments received.  The need for a trusted source of information in
relation to climate change was also stressed extensively throughout the
engagement process.

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Specifically in relation to the Land Use theme, the engagement exercise
asked a total of 40 questions, covering a number of topics, including:
biodiversity, greenspaces, open spaces, planning controls, agriculture and
other land uses.  There were 67 overall responses, which was 13.9% of the
responses to the Council’s wider survey on climate change.  Some of the
questions were to help build a profile of the respondent and where they
lived.  A summary of results for the main topics are as follows:
Biodiversity – 67.2% of the respondents did not think that the Council had
enough measures in place at the time of the survey to protect biodiversity. 
Respondents also commented that the Council could enhance its
biodiversity protection measures through a number of actions, such as:
improve greenspaces, use planning powers to protect biodiversity, and
follow the approach used by other local authorities to safeguard
pollinators.  
Greenspaces – With respect to the Council exploring the use of existing
parks and greenspaces to deliver renewable heat/power for community
and public sector buildings, where these were considered to have
potential, the majority of respondents (80.6%) said they would fully
support PKC, while only 4.5% indicated that they would not support this
action.
Open Spaces – 91% of respondents would fully support an increase in
overall coverage of woodland in Council maintained open spaces. 
Community Food Growing – 70% of respondents expressed an interest in
potential community food growing initiatives, with all 3 options receiving a
sizeable response.  The formation of a new allotment/ community garden
was the most popular option, with 44.8% of respondents selecting it as
their first choice. 
Planning Controls – 41.8% of respondent were unsure whether planning
policies in the LDP contribute towards tackling climate change, however,
22.4% were sure that they did.  Respondents further commented that
climate change needs to be considered as a major factor in all policies
within the LDP where possible.  The removal of trees and woodland for
new development was highlighted as one of the main issues with the
Council’s planning policies.  Respondents suggested a stricter approach
should be applied with new developments in order to protect trees and
biodiversity.
Respondents were also asked to rank 9 aspects of tackling climate change
in order of importance.  Those aspects and their rankings were:
1) Energy efficient buildings (score of 5.4)
2) Good transport links (score of 5.1)
3) Good walking and cycling infrastructure (score of 4.9)
4) Developments that protect and create new resources for wildlife
and habitats e.g. wildlife corridors (score of 4.8)
5) Renewable energy sources to heat buildings and provide power
(score of 4.7)
6) A number of well-connected green and blue spaces (score of 4.6)
7) Planting of new trees (score of 4)
8) Access to local services and community facilities (score of 3.6)
9) Design of homes and access to digital infrastructure to support
homeworking (score of 2.7)
Other Land Uses – 77.6% of respondents agreed when asked if they think it
is extremely important that we change the way we use our land and how
this contributes to climate change.   13.3% of those who responded think

Page 39

that this is something that is moderately important, while 3% thought it is
somewhat important.   85% of respondents thought the role of land is
extremely important in helping us adapt to climate change; 9% thought it
is moderately important, and 1.5% that it is somewhat important. 
Climate Action Plan – Priorities Review
During October 2024, workshop sessions were held with our Elected
Members and the Perth and Kinross Climate Commission.  The purpose of
these workshops was to review the Council’s current top priority
projects/actions for climate change (as identified in the Council’s Action
Plan).  The outcome of the sessions was an overall agreement to roll over
the existing ongoing Top 15 projects as well as add a further 10 actions to
the list of priorities.   Table 1 to follow outlines the projects/actions within
that Top 25 list which the development and implementation of our LDP3
can have some influence over, whether directly or indirectly.
Priority Action LDP3 Level of Influence 
Review existing LDP
planning policy
framework and prepare
a suite of enhanced
policies for inclusion in
LDP3.
Direct influence – a suite of national planning
policies has been introduced via NPF4 since
this action was initially identified, but it may
still be appropriate to develop local policy
responses to address certain matters of
relevance to the PKC Area which have not
been fully covered by NPF4 policies.  
Additional areas of work linked to the
preparation of LDP3 will also help deliver
national policy objectives in respect of
tackling the climate and nature crises, such as
work on blue and green infrastructure,
identifying nature networks, reviewing our
Forest and Woodland Strategy, and,
Priority Action LDP3 Level of Influence 
producing our Strategic Flood Risk
Assessment etc.
Review and revise our
Forest and Woodland
Strategy (FWS) for
incorporation within
LDP3.
Direct influence - the Council’s FWS will be
reviewed as part of the development of our
LDP3. 
Identify and develop
Nature Networks for
Perth and Kinross.
Direct influence – Nature Networks will be
identified for inclusion within our LDP3.
Biodiversity Villages,
Neighbourhoods and
Towns Initiative – work
with local communities
to develop Biodiversity
Action Plans (BAPs),
supporting biodiversity
and climate change
mitigation and
enhancement.
Indirect influence – whilst work on our LDP3
will not include the development of BAPs in
conjunction with communities, LDP3 can,
through its Spatial Strategy, identify existing
assets for protection and any actions
identified as part of local BAPs for their
enhancement, as well as other actions which
will help support climate mitigation.  
The LDP3 can seek to safeguard those
locations with the potential to help deliver
local community biodiversity action plans and
promote nature-based solutions which will
help support biodiversity and climate change
mitigation and enhancement. 
Accelerate the deliver
of Tayside Local
Biodiversity Action Plan
(LBAP) – work across
services to maximise
opportunities for PKC
to achieve actions set
Indirect influence – LDP3 can help maximise
opportunities for the achievement of LBAP
actions through identifying existing assets for
protection via its Spatial Strategy, and
promoting opportunities for their
enhancement, in line with NPF4 policies.

Page 40

Priority Action LDP3 Level of Influence 
out the Tayside LBAP
2016-26.
Continued delivery of
Flood Risk
Management Cycle 1
Projects and
commence Cycle 2
Projects.
Direct influence – by taking into account the
relevant Flood Risk Management Plans for
the Plan Area, and their agreed land use
planning objectives and actions, along with
working in collaboration with our Flood Team
colleagues and SEPA, we can ensure flood
risk is adequately considered in local planning
decisions, and that our LDP3 supports their
implementation.
Support community
resilience groups to
build proactive
resilience.
Indirect influence – we can identify and
promote via our LDP3 Spatial Strategy
proposed actions (with a spatial element)
that have been developed by community
resilience groups, to help support the
building of climate resilience locally. 
Comply with Heat
Network Regulations
and identify areas
suitable for the
development of heat
networks, designating
Heat Network Zones
where favourable.
Indirect influence – in line with NPF4 Policy
19 we can identify in our LDP3 Spatial
Strategy any designated, and (if known)
potential Heat Network Zones (HNZ). Also, as
part of our ‘Call for Sites’ exercise we can ask
landowners, developers and/or their agents
to identify if their proposed site is within a
designated or potential HNZ, or 100m of one,
and if so, require the submission of
supporting information regarding estimated
heat demand of the site; any details of heat
network infrastructure that has been
considered at this stage.
Further development
of the Park and Choose
Indirect influence – we can help support the
delivery of these sites through identifying
their locations as part of our LDP3 Spatial
Priority Action LDP3 Level of Influence 
at Bertha Park and
Walnut Grove.
Strategy.  We can also ensure that
consideration has been given to the potential
for other proposed developments identified
as part of the Spatial Strategy to impact upon
the effective delivery of those Park and
Choose sites, either positively or negatively.
Develop Perth West
and Perth Eco-
Innovation Park as a
national net zero
exemplar.
Indirect influence – we can help support the
delivery of these sites through identifying
their locations as part of our LDP3 Spatial
Strategy.  We can also ensure that
consideration has been given to the potential
for other proposed developments identified
as part of the Spatial Strategy to impact upon
the effective delivery of those sites, either
positively or negatively.
Update the existing
Active Travel Strategy
in line with Transport
Scotland’s Active Travel
Strategy Guidance and
develop
comprehensive active
travel network in
association with
mobility strategy.  
Direct influence – whilst the updating of the
Council’s existing Active Travel Strategy lies
with another team within PKC, we can work
collaboratively with our Transport Planning
and Active Travel colleagues in the
undertaking of our Local Living and 20
Minute Neighbourhood analysis and
identification exercises, to support the
development of an active travel network
which meets the needs of our communities,
and can be safeguarded and promoted
through our LDP3 Spatial Strategy. 
Transition LHEES
Delivery Plan into
focussed
implementation of
actions.
Indirect influence – in the preparation of our
LDP3 we will consider the key objectives of
the Council’s LHEES, and our Spatial Strategy
will take into account the indicative HNZs as
areas of heat network potential and any
formally designated HNZs.

Page 41

Perth and Kinross LDP3 Big Place Conversation Results
During 2023 the Council carried out it’s ‘Big Place Conversation’ exercise,
which kicked started our LDP3 process.  The exercise involved over 100
events throughout the Council Area ranging from drop-in information
sessions, meetings, and online surveys to in person and online workshops
sessions using the Place Standard Tool to capture the views of local
communities.  There were also targeted sessions held with schools, service
user groups, and minority groups. 
The Place Standard Tool helps provide a framework to structure
conversations about place, based around 14 questions.  However, as none
of the questions in the version of the tool used ask participants specifically
their views on the dual climate and nature crises and the impacts of both
on people and places across Perth and Kinross, as would be expected,
there were no responses across all sessions directed related to these
subject matters.   There were however key points raised by participants
across several of the 14 questions, where action in terms of climate
mitigation and adaptation, and increasing and enhancing opportunities for
nature, could have a positive impact and provide multiple benefits for our
communities.  These include -
• Moving Around: 
− Improving active travel routes to reduce reliance on private
vehicles, which can in turn help reduce transport emissions and
improve the health and wellbeing of our people.
• Streets, Squares and Buildings:
− Repurpose vacant and derelict sites to provide a range of benefits
to local communities, including improved safety, aesthetics, and
delivery of new commercial or residential opportunities on
existing sites.  
− Increase levels of blue and green infrastructure in urban areas to
improve the look and appeal of places.  
− Increase provision of seating and sheltered areas in public spaces.  
• Natural Spaces: 
− Protection and enhancement of our important natural assets not
only for their beauty, but also their ecological significance.  
− Improvements to path networks would provide excellent
connectivity to natural spaces.  
− Provision of high-quality accessible and well-connected green
spaces in urban areas would enhance access to nature.   New
developments can contribute towards this.
− Biodiversity can thrive across urban and rural settings, and with it
support an abundance of wildlife and healthy ecosystems.  
− Gradual loss of natural spaces because of development on
greenfield sites, including greenbelt and open spaces, and
concerns regarding the cumulative impact of new development
and land management practices on ecosystem health.
− Insufficient provision of seating and sheltered areas in natural
spaces and along paths connecting to them.
• Play and Recreation:
− Access to facilities and activities is hindered by issues connected
to inadequate active travel infrastructure and public transport
links.
− Loss of informal play and recreation spaces due to
implementation of ‘No Mow’ grassland management approach by
PKC, which was introduced to support biodiversity.
• Facilities and Services:
− Need to travel to larger urban areas for retail and key services,
and there is limited access to healthcare facilities in most areas.
− Lack of affordable and varied food shopping options in local areas.

Page 42

− Poor digital connectivity in many areas, both for broadband and
mobile phones. 
− Development of rural hubs to deliver essential services or develop
more facilities to accommodate growth could help tackle some of
issues experienced.
− Improvements to mobile phone coverage and broadband would
help address connectivity issues. 
• Work and Local Economy:
− For most areas, residents were required commute for work
purposes; local jobs can be limited in roles and professional jobs
require travel.  Significantly, a lack of a variety of work
opportunities in villages and in Perth neighbourhoods was raised. 
− In many areas, the local economy was viewed as being dominated
by only a few sectors e.g., tourism, agriculture and retail, which
limits the employment opportunities, especially for young people.
− Some areas highlighted that access to employment locations,
especially in the evenings, is adversely affected by public transport
issues – this was raised in Perth City neighbourhoods as well as in
rural areas.
− Some areas identified poor access to Further and Higher
Education, which undermines local economic growth.
• Homes and Community:
− Older housing stock across PKC requires significant maintenance/
energy retrofitting.
− Issues of fuel poverty and homes which are not energy efficient/
difficult to heat.
− Prioritise brownfield development, protect greenbelt land, and
reuse and repurpose existing buildings to create housing.
• Feeling Safe:
− Flooding causes safety issues – improved drainage and flood
protection sought.  
− Development of community resilience plans, including rapid
response teams could help with issues of feeling safe due to flood
risk.
• Care and Maintenance:
− Blocked drains and farmland/hillside run off exacerbate flooding
issues.

Page 43

How the views expressed have been taken account of in the
Evidence Report?
The feedback received as part of the engagement exercises on the
Council’s Draft Climate Change Strategy and Action Plan was used to help
refine the Strategy and the list of actions contained within the final Action
Plan.  The contents of the Strategy and Action Plan as well as implications
for the Proposed Plan have been summarised in earlier sections under this
Issue.   Those Top 25 Climate Action Priorities identified at the most recent
workshops held with Elected Members and the Perth and Kinross Climate
Commission which are relevant to the Development Plan will be
embedded within our LDP3 Spatial Strategy, and where appropriate any
local policy responses developed, to help support their delivery.  It is worth
noting that many of the priority Land Use theme actions are statutory land
use planning requirements. 
Incorporating the Council’s position on climate action and any relevant
actions identified within the Climate Action Plan into our LDP3 will ensure
that LDP3’s Spatial Strategy reflects the Council’s corporate, as well as the
public’s position, on climate action within Perth and Kinross.  It will also
help to ensure that delivery of those actions can be supported via the land
use planning system and allow for the closer monitoring of implementation
relevant actions.  
The overall results of our Big Place Conversation (BPC) highlighted that
many of our communities concerns, whilst not directly attributed to the
dual climate and nature crises at the time, can be linked back to NPF4’s
Spatial Principles (Just Transition; Conserving and Recycling Assets; Living
Local; Compact Urban Growth; Rebalanced Development, and Rural
Revitalisation) as well as the policy outcomes and intent of the majority of
the Framework’s suite of National Planning Policies, which our LDP3 needs
to develop our Spatial Strategy in line with and therefore can help address
those concerns through doing so.  
The BPC exercise has given us an up-to-date awareness of the primary
concerns of our communities about their places, and by bringing the
results of the Place Standard sessions together we have a better
understanding not just about issues within specific settlements, or
localities, but a holistic overview of the Perth and Kinross Area as a whole.  
It has also helped to ensure that across the various policy issues included
within this Evidence Report the available evidence we have gathered is
appropriate and relevant to the concerns raised by our communities,
which in turn will ensure that the development of our Spatial Strategy
considers those concerns.   
By looking at those issues and any suggested solutions through a climate
change and nature lens, it has allowed us to identify overarching issues
affecting the area which our Spatial Strategy will look to address in line
with NPF4’s Spatial Principles and in particular policies 1, 2 and 3, and to
make key policy connections between those issues to ensure our Spatial
Strategy is developed in a coordinated and comprehensive way.      
The responses received on Topic Paper 004: Tackling the Climate and
Nature Crises during our 6 week consultation and engagement period, and
how the Council has taken those responses into account through the
production of this Evidence Report are set out in the ‘Statements of
Agreement/Dispute’ section to follow.

Page 44

Statements of Agreement/ 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 offered examples of additional sources of information which they felt should be considered.   A summary of these comments, their status,
and the Council’s response are provided in the table below.   There was 1 response on the Tackling the Climate and Nature Crises issue which the respondent
wished to be treated as a formal dispute to the Evidence Report (this has been highlighted in red in the table), 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 (these have been highlighted in amber in
the table). 
Respondent Agree or Dispute Summary of Comments PKC’s Response
Private Individual Neither List of Evidence/Datasets: Respondent disagrees
with the list of evidence and datasets included in
Topic Paper 004: Tackling the Climate and Nature
Crises for the reason that “there is no climate or
nature crises.”
Summary of Implications for Proposed Plan (PP):
Disagree with the summary of implications provided
but does not provide any comments to support
view.
Further Comments: No further comments made.
Formal Dispute: Respondent has checked this field
on the consultation questionnaire form as not
applicable. 
The UK Parliament and Scottish Government issued
environment and climate emergency declaration
statements in Spring 2019.  Perth and Kinross Council
declared support for these statements in 2019 and
adopted its Climate Change Strategy and Action Plan in
December 2021.
Section 3ZA Subsection (1) of the Town and Country
Planning (Scotland) Act 1997, as amended by the
Planning (Scotland) Act 2019 states the purpose of
planning ‘is to manage the development and use of land
in the long term public interest.  Subsection (2)
continues that ‘without limiting the generality of
subsection (1), anything which (a) contributes to
sustainable development, or (b) achieves the national
outcomes (within the meaning of Part 1 of the
Community Empowerment (Scotland) Act 2015).
The Brundtland Report defines Sustainable
Development as ‘development that meets the needs of
the present without compromising the ability of future
generations to meet their own needs.’

Page 45

Respondent Agree or Dispute Summary of Comments PKC’s Response
There are 11 National Outcomes in the Scottish
Government’s National Performance Framework each
with a set of National Indicators to measure progress
towards these outcomes.  The Outcomes focus on the
themes of Children and Young People, Communities,
Culture, Economy, Education, Environment, Fair Work
and Business, Health, Human Rights, International, and
Poverty.
NPF4 Policy 1: Tackling the Climate and Nature Crises
states that Local Development Plans (LDPs) ‘must
address the global climate emergency and nature crises
by ensuring the spatial strategy will reduce emissions
and adapt to current and future risks of climate change
by promoting future recovery and restoration in the
area.’
NPF4 Policy 2: Climate Mitigation and Adaptation
requires LDPs spatial strategies to ‘be designed to
reduce, minimise or avoid greenhouse gas emissions. 
The six spatial principles should form the basis of the
spatial strategy, helping to guide development to, and
create sustainable locations.  The strategy should be
informed by an understanding of the impacts of the
proposals on greenhouse gas emissions.  
LDPs should support adaptation to the current and
future impacts of climate change by taking into account
climate risks, guiding development away from
vulnerable areas, and enabling places to adapt to those
risks.’
NPF4 Policy 3: Biodiversity states that LDPs ‘should
protect, conserve, restore and enhance biodiversity in
line with the mitigation hierarchy.  They should also

Page 46

Respondent Agree or Dispute Summary of Comments PKC’s Response
promote nature recovery and nature restoration across
the development plan area…’ 
Development of the Perth and Kinross Council LDP3 will
be guided by the UK Parliament and Scottish
Government policy responses to tackling the effects of a
changing climate and biodiversity loss to deliver a spatial
strategy which contributes to sustainable development
and helps achieve the National Outcomes.  It will also
align with the requirements set out in NPF4. 
Ristol Consulting
Ltd.
Neither List of Evidence/Datasets: Agree
Summary of Implications for Proposed Plan (PP):
The respondent welcomes the topic paper and how
the themes and data can help shape the future LDP
spatial strategy and plan, but comments, in
assessing the datasets, they would request that
detailed consideration is given to developing a policy
framework that enables integrated infrastructure to
come forward to deliver sustainable, liveable and
productive places, as Perthshire has the geography
and capability to deliver, at the required scale and
pace, the infrastructure to enable a just transition to
climate adaptation.  The respondent considers this
requires bringing forward integrated renewable
energy, mobility and digital infrastructure, set within
place based solutions that are underpinned by the
circular economy.  They continue that early
pathfinder projects embedded in the new LDP
strategy covering smart, local energy
neighbourhoods and a mobility hub network shaped
by a material flow analysis and connected to the
applied research facilities, such as Binn Eco Park,
have the potential to be transformative for
PKC welcomes the respondent’s comments and does
not disagree with their view that the Spatial Strategy for
LDP3 would benefit from an integrated approach to
infrastructure, following a place based approach.   
As highlighted at paragraphs 1.5 and 2.2 of Topic Paper
004: Tackling the Climate and Nature Crises, and earlier
in this Evidence Report, due to the universal nature of
NPF4’s policies, NPF4 policies 1 and 2, it was not
considered possible or practical to cover in detail the
relevant climate and nature crises objectives for each
policy area under this issue, but rather it was more
appropriate and proportionate for Topic Paper 004 to
concentrate specifically on the requirements of policies
1 and 2, and for other individual topic papers to address
the relevant data and information, and explain the
implications of those to the development of the
Proposed Plan, including in relation to the climate and
ecological crises, where relevant.  
Our LDP3 Spatial Strategy will follow a place based
approach, and will be developed in line with NPF4’s
Spatial Principles (Just Transition, Conserving and
Recycling Assets, Local Living, Compact Urban Growth,
Rebalanced Development, and Rural Revitalisation) and

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Respondent Agree or Dispute Summary of Comments PKC’s Response
Perthshire in delivering a climate adaptation
strategy.
Further Comments:  No further comments made.
Formal Dispute: The respondent does not wish for
their response to be registered as a formal dispute.
policies – specifically of relevance to this response to
Topic Paper 004: policy 11: Energy, 12: Zero Waste, 13:
Sustainable Transport, 18: Infrastructure First, 19:
Heating and Cooling, and 24: Digital Infrastructure.  In
doing so, the Spatial Strategy will consider the key policy
connections and how they interact with one another to
deliver sustainable, liveable, and productive places for
now and the future. 
PKC note that the respondent has not commented on
Topic Papers 012: Energy, Heating and Cooling, or 013:
Zero Waste, but has commented on 014: Infrastructure,
in terms of transport infrastructure. 
No action required for this Evidence Report.
Errol Community
Council 
Neither List of Evidence/Datasets:  Respondent has
indicated that they neither agree nor disagree with
the evidence provided under Topic Paper 004:
Tackling the Climate and Nature Crises but does not
provide any comments in respect of this. 
Summary of Implications for Proposed Plan (PP):
Respondent has indicated that they neither agree
nor disagree with the summary of implications of
the evidence provided under Topic Paper 004 but
does not provide any comments in respect of this.
Further Comments: No further comments made.
Formal Dispute: Not applicable.
No action required for this Evidence Report.  
Nature Scot Neither List of Evidence/Datasets: No comment.
Summary of Implications for Proposed Plan (PP):
No comment.
Further Comments: The respondent strongly
supports the focus on the climate and nature crises
PKC welcomes Nature Scot’s comments on the evidence
provided under Topic Paper 004: Tackling the Climate
and Nature Crises and summary of implications of that
evidence for the Proposed Plan.  In response to their
comment that the importance of tackling the nature
crisis alongside the climate crisis comes through more

Page 48

Respondent Agree or Dispute Summary of Comments PKC’s Response
across the suite of topic papers.  They note that to
avoid repetition, Topic Paper 004 considers high
level strategies and reports relating to the nature
crises.  However, they consider that the importance
of tackling the nature crises alongside climate
change should come through more strongly. 
Formal Dispute: Not applicable.
strongly, the summary provided of the Scottish
Government’s Scottish Biodiversity Strategy has been
updated to emphasise that: the loss of species and
degradation of our natural environment presents a real
threat to human life on earth; there is a need for urgent
and transformative action to tackle that loss, and that it
should be addressed jointly with efforts to tackle the
climate crisis.  
No further action required for this Evidence Report.
Scottish
Environment
Protection Agency
(SEPA)
Agree List of Evidence/Datasets: The respondent agrees
with the list of evidence and datasets provided in
Topic Paper 004 but highlights that the Scottish
Government is due to publish its Scottish National
Adaptation Plan 3 (SNAP3) which will include
relevant evidence, including important objectives
and indicators for Scotland’s direction in adapting to
climate change, and advises that the Evidence
Report is updated to reflect SNAP3 once published.
Summary of Implications for Proposed Plan (PP):
Respondent agrees with summary of implications of
evidence provided in Topic Paper 004. 
Further Comments: As above, the respondent flags
the upcoming publication of SNAP3 which will be an
important evidence source for the Evidence Report.
Formal Dispute: Not applicable.
PKC welcomes SEPA’s comments on Topic Paper 004:
Tackling the Climate and Nature Crises.  Their suggested
inclusion of the ‘Scottish National Adaptation Plan 2024-
2029’, which was recently published on 24 September
2024, has been actioned under the list of evidence
provided for this issue in our Evidence Report (see
section titled ‘Tackling the Climate and Nature Crises’).
Historic
Environment
Scotland (HES)
Agree List of Evidence/Datasets: Agree
Summary of Implications for Proposed Plan (PP):
Agree
Further Comments: In response to Topic Paper 004:
Tackling the Climate and Nature Crises, HES
comment that our historic environment is not only a
PKC welcomes HES’ response to our evidence regarding
the issue of tackling the climate and nature crises.  It is
considered more appropriate to include these additional
sources of evidence and information under the Historic
Assets and Places issue for this Evidence Report, to
ensure the multiple benefits and opportunities linked to

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Respondent Agree or Dispute Summary of Comments PKC’s Response
finite resource that requires protection but is also
important for providing places and spaces which are
key to our everyday lives, cultural identity and sense
of place, including most of our building stock,
offices, infrastructure, public buildings and parks and
gardens.  As such, our use, maintenance and
adaptation of these assets is key to a sustainable
future, and our health and wellbeing.
HES highlights the new national strategy on the
historic environment – Our Past, Our Future (OPOF),
which sets the direction of travel for the historic
environment sector and identifies the priority areas
of action to focus work to support this objective. 
The Strategy’s three priorities are: Delivering the
Transition to Net Zero; Empowering Resilient and
Inclusive Communities and Places, and Building A
Wellbeing Economy.  The importance of the
contribution that maintenance, reuse and
adaptation can make in preventing waste and
reducing carbon emissions is recognised under the
transition to net zero priority.  
Furthermore, ‘Pointing the Way to the Future’, HES’
climate and nature crisis statement recognises that
the historic environment is part of a just transition
to net zero through contributing to our places,
communities and identities, and the reuse of historic
assets is central to sustainable development.
HES also highlight their Green Recovery Statement
and Guide to Climate Change Impacts as providing
further information and examples of the role that
the historic environment can play in the transition to
the historic environment of Perth and Kinross are
considered holistically.

Page 50

Respondent Agree or Dispute Summary of Comments PKC’s Response
a low carbon, resource efficient, more climate
resilient and socially inclusive economy. 
Formal Dispute: Not applicable.
Tactran Neither List of Evidence/Datasets: The respondent offers
the following points of clarification related to some
of the evidence in TP004:
• Page 3 refers to Scottish Government’s 2030 75%
emissions reduction target – this target has now
been withdrawn.  However, the 2045 net zero
target remains.
• Paragraphs 2.42 and 2.43 and the table in
Appendix A refer to the Draft Regional Transport
Strategy (RTS), which has now been approved
and adopted.  Tactran request that this reference
is updated accordingly. 
• Paragraph 2.44 notes that actions identified
under the RTS outcome to ‘increase the levels of
walking and cycling in the least affluent SIMD
data zones’ and ‘reduce transport emissions in
declared AQMAs’ will also contribute to climate
change mitigation and adaptation.  Tactran notes
that the potential of active travel to contribute to
mitigation and adaptation is rather limited.  It is
also difficult to understand the scale of the
problem and the potential impact of new
development on climate change without knowing
the baseline and forecast implications of existing
and new transport (specifically impact on GHG
emissions) e.g. existing and forecast traffic levels
and ULEV adoption.
• Paragraphs 2.64 to 2.66 refer to the Scottish
Household Survey (SHS) Environment Survey and
public attitudes regarding climate change.  As
PKC welcomes Tactran’s comments and responds to the
points raised as follows:
• References to the Scottish Government’s interim
emissions reduction targets have been removed
following the introduction of the new Climate
Change (Emissions Reduction Targets) (Scotland)
Act.  
• Reference to the Draft RTS has been updated to
reflect its adopted status.
• Tactran’s ‘Quantitative Research Report – October
2023’ has been included in the list of evidence for
the Tackling Climate and Nature Crises issue. 
• The reference to RTS outcomes on increasing active
travel in the least affluent SIMD areas and reducing
transport emissions in AQMAs has been amended
to reflect that there may be potential to contribute
to climate change mitigation and adaptation via
actions identified under these outcomes.  The
uncertainty highlighted by Tactran has been added
to the ‘Gaps, Uncertainties, and Key Issues Raised’
section of this Evidence Report.
• The reference to a lack of suitable data for some of
the indicators under the Transport theme was
taken from an acknowledgement of data gaps as
part of the Council’s Climate Change Strategy and
Action Plan monitoring.  We welcome Tactran
highlighting the availability of data regarding modal
share in the Census, SHS and the RTS survey data. 
Reference to these data gaps has been removed

Page 51

Respondent Agree or Dispute Summary of Comments PKC’s Response
part of the development of the RTS Tactran
commissioned representative market research of
attitudes towards climate change and the
implications for transport measures, with
findings supporting the findings of the SHS.  The
report is available from the Tactran website.
• Paragraph 2.76 refers to a lack of suitable data
availability and the lack of up-to-date data on the
% modal share attributed to public transport, %
of journeys to school by active transport, number
of passengers using Park and Ride services, and
number of road closures due to flooding or other
climate change impacts.  The respondent
comments that both the Census and SHS will
provide mode share data, and the RTS survey
data.  Also, the 2022 Travel to Work Census data
is due to be released, which can subsequently
inform the LDP.
Summary of Implications for Proposed Plan (PP):
No comment.
Further Comments:  No further comments made.
Formal Dispute:  Not applicable. 
from the ‘Tackling the Climate and Nature Crises’
issue of this Evidence Report, and instead
summarised under the Infrastructure: Transport
(including Sustainable Transport) issue.  The data
will also be used to inform both the SEA and
development of our LDP3 Spatial Strategy.  
No further action required for this Evidence Report. 
Homes for Scotland Disagree - but
does not wish to
register as a
formal dispute
List of Evidence/Datasets: Agree
Summary of Implications for Proposed Plan (PP):
Respondent disagrees with summary of implications
of evidence provided in Topic Paper 004.  They
comment that Section 72 of the Climate Change
(Scotland) Act 2009 introduced Section 3F into the
Town and Country Planning (Scotland) Act 1997. 
Section 3F requires LDPs to contain policies that
require new buildings to be designed to avoid a
specified and rising proportion of GHG emissions
PKC welcomes Homes for Scotland’s comments on the
evidence reviewed under Topic Paper 004, and responds
to the points raised through that response as follows:
• Paragraph 1.7 of Topic Paper 004 acknowledged the
Scottish Government’s intention (at the time of
producing the paper) to repeal Section 3F of the
Planning Act as national planning policies now go
further than Section 3F, and that the New Build
Heat Standard coming into force via the building
regulations targets heating related emissions as a

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Respondent Agree or Dispute Summary of Comments PKC’s Response
from their use through the installation and
operation of low and zero carbon generating
technologies.  In continuation the respondent
comments that as of 1st April 2024, the latest
national planning policy, heat policy and associated
building regulations go much further than LDPs are
required to under Section 3F, and there is therefore
no need for LDPs to set an ambition for optimising
build quality and performance to ensure new homes
and buildings are energy efficient, and that the focus
should be on enhancing the energy efficiency of
existing homes and buildings.  
The respondent comments that it is positive that
Topic Paper 004 states that through its Spatial
Strategy LDP3 can help support the delivery of some
actions in relation to active and sustainable travel
networks, and improvements to the transport
network to help make it more resilient to the
impacts of climate change.  
In response to Topic Paper 004 highlighting that
LDP3 should identify and direct the right
development to the most appropriate and
sustainable locations, helping to create sustainable
communities, the respondent comments that whilst
they agree with this, “ensuring there is a balance
between sustainable and marketable locations when
allocating development in the plan is vital.  In
addition to sustainable locations, marketable
locations for new developments must also be
considered as well as deliverability; this will ensure
development happens in the areas where there is a
significant demand for housing and assist in meeting
the Council’s MATHLR.”
significant source and removes current emissions
compliance calculation methodology.
• PKC acknowledges Homes for Scotland’s comments
in respect of achieving a balance between
sustainable and marketable locations, as well as
deliverability of new developments in meeting the
MATHLR for the Perth and Kinross Area, and the
links between new development and infrastructure
provision/investment.  The appropriate location for
new development across the Perth and Kinross
Area will be considered within the context of the
Scottish Government’s NPF4 spatial principles, the
six qualities of successful places, all relevant NPF4
policies, and informed by the consideration of
relevant sources of data identified in this Evidence
Report for those national policies.  In doing so, the
Spatial Strategy will consider the key policy
connections and how they interact with one
another to deliver sustainable, liveable and
productive places for now and the future. 
No action required for this Evidence Report.

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Respondent Agree or Dispute Summary of Comments PKC’s Response
Further Comments: The respondent further
comments that the socio-economic benefits of home
building cannot be understated.  They highlight that
their members contribute millions of pounds
annually to infrastructure investment across the
district and their role as a principal funder of future
investments must be fully recognised, as should
their role in the journey towards net zero through
the delivery of increasingly energy efficient homes
as well as local living neighbourhoods.  They refer to
the Homes for Scotland March 2022 commissioned
report commissioned by HFS: The Social and
Economic Benefits of Home Building in Scotland,
which states that in 2019 the home building sector
supported 79,200 jobs, equivalent to 3.5 jobs for
every home built, and that private sector home
building is also a key contributor to the delivery of
affordable housing. 
Formal Dispute:  The respondent does not wish for
their response to be registered as a formal dispute.
Holder Planning on
behalf of SSE
Renewables
Dispute List of Evidence/Datasets:  The respondent has
indicated that they disagree with the evidence
provided under Topic Paper 004: Tackling the
Climate and Nature Crises.  They comment that
generating more renewable energy will be critical to
tackling the climate crisis and achieving net zero. 
They suggest that the datasets/policies referred to
under Topic Paper 004 should be amended to
include the Scottish Government’s Onshore Wind:
Policy Statement 2022.  Furthermore, they comment
that Figure 1 of the Topic Paper refers to the 2030
target for renewable energy generation, but the rest
PKC welcomes the respondent’s comments and
responds as follows:
As per paragraphs 1.4 and 2.2 of Topic Paper 004 and
repeated earlier in this Evidence Report for the ‘Tackling
the Climate and Nature Crises’ issue, due to the
universal nature of NPF4’s policies 1 and 2 and their
interconnectivity with all the other remaining NPF4
policies, it is not possible or practical to cover in detail
the relevant climate and nature crises objectives for
each policy area under this issue.  Therefore, not all
relevant sources of data and information for these
subjects will be covered in this ‘Summary of Evidence’. 
Instead, these matters will be picked up under each of

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Respondent Agree or Dispute Summary of Comments PKC’s Response
of the document includes very little evidence on
renewable energy generation and distribution.
Summary of Implications for Proposed Plan (PP):
No comment. 
Further Comments: No further comments made.
Formal Dispute: The respondent wishes for their
comments to be registered as a formal dispute due
to the omission of the Onshore Wind: Policy
Statement 2022.  
the relevant summaries for the individual issues, to
ensure they are appropriately addressed.  The Scottish
Government’s Onshore Wind: Policy Statement 2022
will be reviewed in respect of the ‘Energy, Heating and
Cooling’ issue of this Evidence Report.
No further action required for this Evidence Report.   
Montagu Evans on
behalf of Loch
Developments Ltd.
Neither List of Evidence/Datasets: Respondent has indicated
that they neither agree nor disagree with the
evidence provided under Topic Paper 004: Tackling
the Climate and Nature Crises but does not provide
any comments in respect of this.
Summary of Implications for Proposed Plan (PP):
Respondent has indicated that they neither agree
nor disagree with the summary of implications of
the evidence for the Proposed Plan provided under
Topic Paper 004 but does not provide any comments
in respect of this.
Further Comments: No further comments. 
Formal Dispute:  Not applicable. 
No action required for this Evidence Report. 
Private Individual Disagree - but
does not wish to
register as a
formal dispute
List of Evidence/Datasets: The respondent indicated
that they disagree with the evidence provided under
Topic Paper 004.  They comment that the
‘Adaptation, Mitigation, and Achieving Net Zero and
a Just transition – Impacts of Climate Change’
section has not been expanded upon to quantify
what they will actually mean in terms of costs, even
if just a ballpark figure.  They continue that the
implications of these damages are vital to planning
PKC welcomes the respondent’s comments and
responds that the list of evidence considered for this
issue of our Evidence Report has now been updated to
include a summary of the Climate Change Risk and
Opportunities Assessment (CCROA) Technical Report
undertaken by ARUP on behalf the Council.   This report
outlines the estimated annual cost of the impacts of
climate change for the Tay District, which includes the
Perth and Kinross Council Area and some parts of

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Respondent Agree or Dispute Summary of Comments PKC’s Response
adaptation to them as we do not know their
severity. 
They also disagree with the lack of inclusion of
climate impacts from global challenges that could
have severe repercussions for Perth and Kinross
such as inflation, food inflation, food shortages,
social unrest, economic disruption, social
fragmentation, and no analysis of global climate
trajectories like RCP6.0 being more likely than
RCP2.6 or RCP8.5, and so we should prepare
adaptation around this level of damages. 
The respondent suggests that looking at the costs of
previous severe storm events such as Storm Babet
and Arwen as additional sources of information/
data.  They also suggest ARUP’s Climate Change Risk
and Opportunity Assessment Technical Report,
August 2023 which starts to look at general risk and
estimated costs.  They continue that although
ARUP’s work presented as high climate risk (RCP8.5)
and low climate risk (RCP2.6), with which there
should also be a potentially most likely climate risk
to show what we might actually be dealing with e.g.
RCP6.0 with inclusion of the other higher and lower
climate risk as better or worse scenarios. 
Summary of Implications for Proposed Plan (PP): 
The respondent indicated that they disagree with
the summary of implications of the evidence listed in
Topic Paper 004 for the Proposed Plan due to the
implications not having been set out in finer detail,
and no attempts on quantifying certain elements like
damages. 
Further Comments: No further comments made. 
neighbouring authorities’ areas, and current impacts on
the area, as well as probable future impacts and
associated risks.  
As the respondent highlights, the assessment considers
the RCP2.5 and RCP8.5 scenarios.  It does not look at
other alternative scenarios in between.  One of the
identified next steps for the Council in the CCROA is to
create a framework to allow the regular review of the
assessment work to ensure it remains up to date and
considers any new evidence.  Should any future reviews
consider alternative climate risk scenarios, our LDP will
incorporate any additional probable risks or
opportunities under those scenarios into the
development of the Spatial Strategy.  However, it is
considered that by planning for a worst case scenario
(RCP8.5) those mitigation and adaptation measures
incorporated into the LDP3 Spatial Strategy as a result of
the risks and opportunities identified in the August 2023
CCROA Technical Report, should mean that our LDP3 will
cover an RCP6.0 scenario if that is what occurs.

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Respondent Agree or Dispute Summary of Comments PKC’s Response
Formal Dispute: The respondent indicated that they
do not wish for their comments to be registered as a
formal dispute. 
SSEN Transmission Agree List of Evidence/Datasets: The respondent indicated
that they agree with the evidence included under
Topic Paper 004: Tackling the Climate and Nature
Crises.
Summary of Implications for Proposed Plan (PP):
The respondent indicated that they agree with the
summary of implications provided under Topic Paper
004.
Further Comments: The respondent highlights that
there is a typo in the topic paper on page 9,
paragraph 1.4, which should read “nonetheless”
rather than “none-the-less”.  
Formal Dispute: Not applicable. 
PKC welcomes SSEN Transmission’s response to Topic
Paper 004: Tackling the Climate and Nature Crises.  
There are no actions required for this Evidence Report. 
Scottish Water Agree List of Evidence/Datasets: Agree
Summary of Implications for Proposed Plan (PP):
Agree
Further Comments:  Scottish Water already
provided comments on the Council’s LDP3 Topic
Paper for Flood Risk and Water Management but
included those comments again in their response to
Topic Paper 004: Tackling the Climate and Nature
Crises due to the relevance of those comments to
this issue.  
In summary, they acknowledged that one of the
biggest impacts from climate change in Scotland is
flood risk, with many local authorities recognising
the need to adapt their places to the impact of
flooding, and further commented that they support
PKC welcomes Scottish Water reiterating their
comments in respect of sustainable flood risk principles,
surface water management planning and integrated
drainage in respect of the Tackling the Climate and
Nature Crises Topic Paper due to their relevance to this
issue also.  The matters raised within Scottish Water’s
response have been addressed under the Flood Risk and
Water Management issue of this Evidence Report. 
No further action required for this Evidence Report.

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Respondent Agree or Dispute Summary of Comments PKC’s Response
sustainable flood risk principles which seek to
manage surface water to reduce flood risk and work
collaboratively across organisations to support the
delivery of integrated drainage.   The principle of
surface water management planning recognises that
the current drainage infrastructure can become
overwhelmed in the more regular occurrences of
severe rainfall, and that climate change modelling
predicts these occurrences will increase, both in
respect of frequency and intensity.  This combined
with population growth and increase paving over
green spaces (urban creep) will place an even
greater pressure on infrastructure in the future with
increased risk of surface water flooding.  
Scottish Water continue that it will not be possible
to build underground urban drainage systems that
are large enough to accommodate the changing and
more intense rainfall events.  Surface water
management planning and integrated drainage
should minimise the amount of drainage going
underground and maximise opportunities to manage
surface water close to source and above ground e.g.
in SUDS ponds and basins, swales, raingardens, and
individual property level within water butts.  
Scottish Water welcomes the opportunity to
contribute to the surface water management
planning process for the areas identified in the Tay
Flood Risk Management Plan and will continue to
work closely with PKC and SEPA in this space.  
Formal Dispute: Not applicable.

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Respondent Agree or Dispute Summary of Comments PKC’s Response
Anonymous Agree List of Evidence/Datasets: The respondent indicated
that they strongly agree with the list of evidence and
datasets provided under Topic Paper 004.
Summary of Implications for Proposed Plan (PP):
The respondent indicated that they strongly agree
with the summary of implications for the Proposed
Plan provided under Topic Paper 004.
Further Comments: The respondent comments that
it is now just 6 years until 2030, and Figures 3 and 5
of Topic Paper 004 show the required trajectories to
then.  They comment that the concerning point is
that both trajectories show a sharp upturn in 2021,
and that it would be interesting to see if this was “a
blip or a trend”.  They further comment that Figure 4
shows that both the PKC Area and Scotland generally
suffered a rise in per capita rates of GHG emissions
in 2021 – then there were 9 years left to readdress
the trend and now there are 6.  The respondent
would find it of great interest to see the graphs at
Figures 3, 4 and 5 as at 2024, or at least 2023.
The respondent also expresses that section 2.25 of
the topic paper makes sobering reading and can be
tied to the biodiversity section of the paper. 
Formal Dispute: Not applicable. 
PKC welcomes the respondent’s comments on this issue. 
The graphs presented in Topic Paper 004, which the
respondent refers to, represented the most up to date
data available at the time of producing the Topic Paper. 
Since then, DESNZ has released its annual greenhouse
gas emissions data and this Evidence Report has been
updated to include a summary of the recently published
Perth and Kinross Council Climate Change Annual
Report, October 2023 - September 2024. 
Anonymous Agree List of Evidence/Datasets: Agree
Summary of Implications for Proposed Plan (PP):
The respondent indicates that they disagree with the
summary of implications provided under Topic Paper
004.  Whilst they agree that flooding in the future is
likely to become more frequent and severe, they
comment that the partial solution to this and
PKC welcomes the respondent’s comments on Topic
Paper 004 and agrees that a holistic approach is
required to tackling this issue.  In line with legislative
requirements and the expectations of LDPs under NPF4
Policies 20 and 22, our LDP3 will take a strategic ‘whole
systems’ approach to flood risk and water management,
and to protecting and enhancing blue and green
networks working with key stakeholders (including SEPA

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Respondent Agree or Dispute Summary of Comments PKC’s Response
existing problems lie within the urban area.  They
continue that planning authorities need to be
cleverer and not build on every piece of vacant
ground that becomes available.  When a piece of
land becomes vacant it should be thought of as an
opportunity to reduce flood risk.  It may provide an
opportunity to store surface waters and/our foul
water from under capacity sewer networks to
reduce downstream flooding.  Opportunities for
flooding in urban areas are extremely limited so
should be grasped before consideration is given to
building more homes and/or business on it. 
Further Comments:  No further comments.
Formal Dispute: Not applicable. 
and Scottish Water), landowners and developers.  This
approach will also be aligned with infrastructure first
principles, and open space, active travel and nature
networks.  This subject is explored in detail under the
‘Blue and Green Infrastructure’ issue of this Evidence
Report. 
No further action required for this Evidence Report. 
Earn Community
Council
Agree List of Evidence/Datasets: Agree
Summary of Implications for Proposed Plan (PP):
Agree
Further Comments: The respondent makes the
following further comments:
• District Heating (Tay and Earn) are both large
Heat Sinks.
• Promotion of 20 minute communities, as these
would reduce traffic, improve health.
• The concept of solar panels on the roofs of PKC
buildings.
• Support local landowners and farmers in their
development of more sustainable farming.
Formal Dispute: Not applicable. 
PKC welcomes Earn Community Council’s comments on
the evidence gathered and reviewed under Topic Paper
004: Tackling the Climate and Nature Crises, and
responds to the further comments raised in their
submission as follows:
• The subject of district heating/heat networks is
explored in more detail under the ‘Energy, Heating
and Cooling’ issue of this Evidence Report.  As per
NPF4 Policy 19, the Council’s LHEES Strategy and
Delivery Plan will inform the consideration of the
development of heat networks as part of LDP3’s
Spatial Strategy. The development process for our
LHEES explored in detail 7 potential heat network
zones (5 in Perth City, 1 each in Kinross, Blairgowrie
and Auchterarder).  The approach to identifying
potential zones builds upon the national heat
network assessment methodology, and our key
stakeholders have preliminarily screened potential
zones to identify any known issues or barriers which

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Respondent Agree or Dispute Summary of Comments PKC’s Response
limit taking the zone forward for further
investigation.  These potential zones will be further
assessed during the formal designation process, as
required by the Heat Networks (Scotland) Act.
• In light with NPF4 Policy 15, the development of our
LDP3 Spatial Strategy will consider what local living
and 20 minute neighbourhoods means in a Perth and
Kinross context, and seek to identify such areas
following the establishment of a criteria for defining
them.  The ‘Local Living and 20 Minute
Neighbourhoods’ issue of this Evidence Report looks
at this subject specifically.
• As part of the Council’s action to decarbonise its
estate, we have been undertaking several measures,
including improved building management systems,
use of renewable technologies to provide heating,
hot water, and energy generation. This is just the
start of the journey to Net Zero and Perth and
Kinross Council will be installing more of these
systems and adopt a ‘fabric first approach’ as part of
its Capital Improvement and Investment Programme. 
Progress against these actions is monitored via the
Council’s internal Buildings and Energy Climate
Change Working Group and reported via the Climate
Change Strategy and Action Plan and Annual Report. 
• The agricultural sector is outwith the remit of land
use planning.  However, PKC will promote and
encourage sustainable land use via our LDP3 Spatial
Strategy in line with NPF4 and the National Land Use
Strategy. Furthermore, the Council has established
links with the National Farmers Union Scotland
(NFUS) via our Climate Change - Land Use Working

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Respondent Agree or Dispute Summary of Comments PKC’s Response
Group and will continue to engage with NFUS and its
members in the development of LDP3. 
Savills on behalf of
Scone Estate
Neither List of Evidence/Datasets: No comment provided.
Summary of Implications for Proposed Plan (PP): 
No comment provided. 
Further Comments: The respondent comments that
the Local Development Planning Guidance states
that plans should be place based, developed in
collaboration and be robust.  NPF4 then states that
there should be certain climate and biodiversity
related initiatives outlined in LDPs, for example
woodland creation.  The respondent considers that
it should be explicitly recognised that Perth and
Kinross landowners are critical to achieving strategic
scale environmental benefits that, in turn, help
achieve LDP aims. This is really down to the scale of
available land but also the potential to cluster such
initiatives to maximise benefits.
The respondent continues that landowners, such as
Scone Estates, are increasingly focusing on
integrated land management to better benefit the
environment and also to increase social value
delivery. This is a win-win for Perth and Kinross and
thus should be referenced within any final Evidence
Report.
They acknowledge that there is reference within the
Topic Paper to the fact that work on identifying 20-
minute neighbourhoods has not yet commenced. 
Their view is that it must be remembered that PKC is
predominantly rural, and that work should be done
to increase resilience of settlements via innovative
means to deliver critical Local Living focused
PKC welcomes Savills’ submission on behalf of Scone
Estate and responds to the points raised within it as
follows:
• PKC will develop our LDP3 Spatial Strategy in line
with NPF4 and other legislative requirements as set
out in this Evidence Report for the suite of policy
matters.  The development of our LDP3 Spatial
Strategy and the narrative contained within the Plan
(both in discussing the overall spatial strategy and
location specific matters) will recognise the need to
follow the Scottish Government’s Creating Places and
Designing Streets policy statements, and the Scottish
Government and COSLA’s Place Principle to promote
and develop a shared understanding of place, and
the need for communities, public organisations,
businesses and other key stakeholders, including
landowners, to work together to achieve high quality
successful places, and better outcomes for people,
communities and nature.   Nationally land use
planning recognises the importance of working
collaboratively across all users and sectors to create
sustainable and successful places.  Although
landowners are not a legislatively prescribed key
stakeholder, they are widely recognised as being an
integral part of the development planning process,
through the identification and implementation of
deliverable development opportunities which can
contribute to the achievement of multiple benefits
and wider outcomes for places, communities and
nature.  Our LDP3 development process will seek to
continue to work with key stakeholders across the

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Respondent Agree or Dispute Summary of Comments PKC’s Response
services, which should be done instead of a slavish
adherence to 20-minute neighbourhoods and
blanket restrictions on development, based on
current services. The sustainability of rural areas is
dependent on population growth.  People will be
needed to live on the land managing it for
sustainable outcomes.  Lack of local housing in rural
areas is driven by restrictive planning policies and
weak markets with limited housebuilder activity.
Planning policies should seek to be generous in their
support of housing in rural areas. The market and
availability of housebuilders form their own
deterrent to any proliferation of rural housing.
Formal Dispute:  The respondent does not wish for
their comments to be registered as a formal dispute. 
Perth and Kinross Area, including landowners and
their agents, to deliver sustainable, liveable and
productive places for now and the future, as per our
Development Plan Scheme and Participation
Statement.  
• PKC welcomes the approach being adopted by
landowners, like Scone Estates, with an increasing
focus on integrated land management to achieve
multiple benefits.  Our LDP3 will refer to, promote,
and encourage the principle of integrated and
sustainable land management and the wider benefits
which can be achieved across a number of policy
areas in line with NPF4 and Scotland’s Third Land Use
Strategy.  
• As acknowledged under the relevant section of this
Evidence Report, the Council’s work on local living
and 20 minute neighbourhoods will recognise the
need to develop a methodology which is appropriate
to a Perth and Kinross context, considering both the
urban and largely rural nature of the Council Area,
and explore where opportunities may exist to
identify and build upon local living networks within
rural areas.  In terms of the respondent’s comments
regarding local housing in rural areas, this subject is
considered in detail under the ‘Homes’ issue of this
Evidence Report. 
No action required for this Evidence Report.
Savills on behalf of
Dupplin Estate
Dispute - but
does not wish to
register as a
formal dispute
List of Evidence/Datasets: The respondent disagrees
with the list of evidence.  They continue that PKC
should understand the role of central low carbon
infrastructure in Perth and Kinross for driving the
national transition to emissions reductions.  They
PKC welcomes Savill’s submission on behalf of Dupplin
Estate and responds to the points raised within it as
follows:
• A number of the outputs of the University of
Edinburgh’s Centre for Future Infrastructure (CFI)

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Respondent Agree or Dispute Summary of Comments PKC’s Response
suggest that the evidence should also identify the
impact of investment in infrastructure around Perth
trunk road network on freight journeys across
Scotland.   The respondent suggests the University of
Edinburg Edinburgh Futures Institute Centre for
Future Institute paper on Perth West: A Strategic
Site for Scotland and the UK (Professor Sean Smith).
Summary of Implications for Proposed Plan (PP): 
The respondent comments that they neither agree
nor disagree with the summary of implications
provided under Topic Paper 004.
Further Comments: The respondent further
comments that it should be explicitly recognised as
part of the evidence base for the LDP that Perth and
Kinross landowners are critical to achieving strategic
scale environmental benefits that are essential to
achieving NPF4 and LDP aims. 
Land owning estates such as Dupplin, are
increasingly focusing on integrated land
management with multiple benefits for the
environment and the delivery of social value.
Landowners are also increasingly cooperating on
landscape-scale schemes.
Dupplin Estate to the west of Perth is already
delivering on all of these fronts including extensive
woodland planting and rewilding of agricultural land
on the urban fringe, to support nature networks,
biodiversity, and carbon reduction, as well as
renewable energy generation to tackle climate
change and support community wealth building, and
provision of housing both through existing estate
rented properties and planned future new homes. 
research conducted on behalf of the Lamberkin Trust
to investigate the potential role of the Perth West
development to support future low carbon transport
via a key hub site, have been referenced under the
‘Local Living and 20 Minute Neighbourhood’ issue of
this Evidence Report (Perth Innovation Highway,
Perth Eco Innovation Park, and a logistics, mobility
and refuelling hub) in relation to the ‘Invest in Perth:
Smart Investing Now and for the Future’ document.  
The housing component of the project (Lamberkin
Village) will be addressed at the Proposed Plan stage
of our LDP3 development as it deals with site specific
or locational specific proposals which are not
appropriate to the Evidence Report stage of the LDP3
process.
• As per the response to the same comment submitted
on behalf of Scone Estate, PKC will develop our LDP3
Spatial Strategy in line with NPF4 and other
legislative requirements as set out in this Evidence
Report for the suite of policy matters.  The
development of our LDP3 Spatial Strategy and the
narrative contained within the Plan (both in
discussing the overall spatial strategy and location
specific matters) will recognise the need to follow
the Scottish Government’s Creating Places and
Designing Streets policy statements, and the Scottish
Government and COSLA’s Place Principle to promote
and develop a shared understanding of place, and
the need for communities, public organisations,
businesses and other key stakeholders, including
landowners, to work together to achieve high quality
successful places, and better outcomes for people,
communities and nature.   Nationally land use
planning recognises the importance of working

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Respondent Agree or Dispute Summary of Comments PKC’s Response
Dupplin is working with a number of adjacent
landowners to bring forward the 175 hectare "Perth
Sustainability Park" on the southwestern edge of
Perth, which will deliver a new parkland for the city
with a mix of countryside access, renewable energy,
natural flood risk management, community
woodland creation, and potentially some enabling
housing. This project will be a landscape and natural
capital led plan with countryside access, biodiversity
enhancement and wellbeing at its heart as well as
energy innovation. This parkland with its spectacular
high level views, will add to the recreational and
tourism assets of the city.  
Partnerships between Perth and Kinross Council and
Perth and Kinross landowners such as Dupplin, will
be critical to achieving strategic scale environmental
benefits that achieve LDP and NPF4 aims.
Perth and Kinross has the opportunity to present
exemplar projects aligned to Scottish Government
Biodiversity Strategy.  Perth is accessible to a wide
proportion of the Scottish population and Perth is
accessible to a diverse range of habitats in close
proximity.  If this is a priority for the LDP then
engagement with landowners that can deliver
development projects that aim to tackle Climate and
Nature Crises is essential.  Officers need to
encourage wider engagement with delivery partners
if they are to set out a realistic plan that can be
delivered.  The Perth Sustainability Park is an
opportunity to develop a project that can deliver
Climate and Nature benefits but policy must
recognise that enablers to bringing forward such
projects are essential.  The draft regional transport
collaboratively across all users and sectors to create
sustainable and successful places.  Although
landowners are not a legislatively prescribed key
stakeholder, they are widely recognised as being an
integral part of the development planning process,
through the identification and implementation of
deliverable development opportunities which can
contribute to the achievement of multiple benefits
and wider outcomes for places, communities and
nature.  Our LDP3 development process will seek to
continue to work with key stakeholders across the
Perth and Kinross Area, including landowners and
their agents, to deliver sustainable, liveable and
productive places for now and the future, as per our
Development Plan Scheme and Participation
Statement.  
• PKC welcomes hearing about the work currently
being undertaken by Dupplin Estate with an
increasing focus on integrated land management and
cooperating on landscape scale schemes to deliver
multiple benefits.  Where appropriate, the LDP3
Spatial Strategy will identify existing proposals and
future opportunities, and would welcome Savills, on
behalf of Dupplin Estate, to submit any relevant
proposals as part of the LDP3 ‘Calls for Ideas’
exercise in the future. 
• The Council will continue to seek the protection,
conservation, restoration and enhancement of
biodiversity, in line with national planning policy, and
the Scottish Biodiversity Strategy, through our LDP3
Spatial Strategy.  The Council will work with key
agencies, like Nature Scot, and key stakeholders and
delivery partners, such as Tayside Biodiversity

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Respondent Agree or Dispute Summary of Comments PKC’s Response
strategy is targeting 56% reduction in transport
emissions.  The topic paper is skewed towards
private vehicle usage.  Achieving an ambitious
emissions reduction strategy for transport needs to
focus on delivering a charging infrastructure into
rural communities and reducing emissions of public
transport (buses), intercity coaches and road
haulage vehicles.  Perth's location at the core of the
Scottish Trunk Road network should be exploited to
provide infrastructure to deliver a transition of road
haulage aware for the internal combustion engine. 
Proposed improvements to the Broxden
Roundabout and Perth West development should be
accelerated to provide alternative fuelling facilities
(hydrogen or electric) for goods vehicles and inter
city buses.
Formal Dispute: The respondent does not wish for
their comments to be registered as a formal dispute.
Partnership, Perthshire Nature Connections
Partnership, local biodiversity and interest groups,
Perth and Kinross Countryside Trust, communities,
and landowners and developers to identify
opportunities for projects and proposals which will
deliver nature based solutions, and contribute
towards Scotland achieving its aim of being nature
positive by 2030, with biodiversity being restored
and regenerated by 2045. 
• PKC disagrees that Topic Paper 004 is skewed
towards private vehicle usage.  The summary of
evidence for the Council’s Draft Mobility Strategy
highlights that the Strategy considers all modes of
transport for the movement of goods and people,
across our urban and rural areas, to help achieve the
national targets and outcomes established under the
National Transport Strategy 2, and the key issues and
action targets identified under Tactran’s Regional
Transport Strategy 2024-2034.  Our Draft Mobility
Strategy was developed in alignment with both NTS2
and the Regional Transport Strategy.  All three of
these strategies address the whole transport system
(people and freight), and recognise the different
needs of our cities, towns, remote and rural areas.  
This will be reflected accordingly in our LDP3 Spatial
Strategy.  Furthermore, the subject matter of
transport is covered in detail under the
‘Infrastructure - Transport (including Sustainable
Transport)’ issue of this Evidence Report.
No action required for this Evidence Report.

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Issue: Biodiversity and Natural Places
Corresponding NPF4 Policy/Policies:
• National Planning Framework 4, Policy 3: Biodiversity and Policy 4
Natural Places
• Other Key NPF4 Policy Connections - 1: Tackling the climate and
nature crises; 2: Climate mitigation and enhancement; 5: Soils; 6:
Forestry and Woodland, and 20: Blue and green infrastructure.
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 005: Biodiversity and Natural Places
https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume
nts/TP005_Biodiversity_and_Natural_Places.pdf 
Information required by the Act and NPF4 regarding the topic:
Section 15(5) of The Town and Country Planning (Scotland) Act 1997, as
amended by the 2019 Planning Act: 
• The principal physical and environmental characteristics of the
district.
• In addition Perth & Kinross Council is under a duty set out in the
Nature Conservation (Scotland) Act 2004 s 1 “It is the duty of every
public body and office holder, in exercising any functions, to further
the conservation of biodiversity so far as it is consistent with the
proper exercise of those functions”
NPF4 Policy 4 expects LDPs to:
• Identify and protect locally, regionally, nationally and internationally
important natural assets, on land and along coasts.
• Safeguard these assets taking into account their objectives and level
of protected status when allocating land for development.
• Better connect nature rich areas by establishing and growing nature
networks to help protect and restore the biodiversity, ecosystems
and natural processes in the area.
The Policy intent of Policy 4 is to:
• Protect, restore and enhance natural assets making best use of
nature-based solutions
The Policy outcomes are:
• Natural places are protected and restored
• Natural assets are managed in a sustainable way that maintains and
grows their essential benefits and services.
NPF4 Policy 3 expects LDPs to:
• protect, conserve, restore and enhance biodiversity in line with the
mitigation hierarchy.
• promote nature recovery and nature restoration across the
development plan area.
• facilitate the creation of nature networks and strengthen
connections between them to support improved ecological
connectivity.
• restore degraded habitats or create new habitats.
• incorporate measures to increase biodiversity, including populations
of priority species. 
The Policy intent of Policy 3 is to:

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• Protect biodiversity, reverse biodiversity loss, deliver positive
effects from development and strengthen nature networks.
The Policy outcomes are:
• Biodiversity is enhanced and better connected including through
strengthened nature networks and nature-based solutions.
The Scottish Government’s Local Development Plan Guidance (May 2023)
under it’s ‘Step by step guide’ provides advice on relevant evidence for the
NPF4 policy topics to help planning authorities in considering the national
planning policies when preparing their Evidence Report.  With respect to
NPF4 Policy 4, the Guidance advises that planning authorities are expected
to take into account:
• Locations of and any links between locally, regionally, nationally and
internationally important natural assets, on land and along coasts
Other relevant information suggested for consideration include
• Review of locally important natural assets, the links between these,
and details of known management arrangements.
With respect to Policy 3, the Guidance advises that planning authorities are
expected to take into account: 
• Existing nature networks
• Details of degraded habitats
Other relevant information suggested for consideration include
• Local Biodiversity Action Plan
The natural assets covered by Policy 4 include those sites that are
designated for their landscape, wildness, geological, ecological and/or
recreational value. In the adopted Local Development Plan (LDP2)
landscape is a key asset recognised and valued through policy 39. This is
regardless of whether the landscape is protected or not. This approach in
LDP3 is supported by the general statement in NPF4 Policy 4(a) that:
“Development proposals which by virtue of type, location or scale
will have an unacceptable impact on the natural environment, will
not be supported.”
Local Development Plan Policies 45, 46 and 47 address the catchments of
Protected Areas Loch Leven, River Tay and the Lunan Lochs (Dunkeld-
Blairgowrie SAC). These policies are compatible with NPF4 Policy 4 and
provide local detail. Preparation of the Local Development Plan will
address whether these policies remain effective or require amendment.

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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
• CEH (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 & 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 [link needs added]
o Candidate Local Biodiversity Sites [link needs added]
o SEPA, Scotland Wetland Inventory 
o Plantlife Important Plant Areas
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

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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) [link needs added]
• Existing Restoration Projects 
o Riverwoods Projects [link needs added]
o Nature Restoration Funded Projects [link needs added]
o Northwoods Rewilding Network [link needs added]
o Peatland Action projects
o Biodiversity Villages [link needs added]
o Wildlife Accredited Estates [link needs added]
o Scottish Forestry Native Woodland grants [link needs added]
o SEPA Water Environment Framework Projects.
o NatureScot(2023) Mountain Woodland Restoration Sites
• Opportunities, Degraded Land and Constraints
o Loch Leven LENS [link needs added]
o Natural Flood Management Studies [CORE DOCS]
 Aberfeldy
 Blackford
 Comrie
 Invergowrie
 South Kinross
o PKC (2024) Strategic Flood Management Assessment [link
needs added]
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
o JHI (2000s) Land Capability for Agriculture Map
o Perth and Kinross LDP3 Big Place Conversation

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Summary of Evidence:
Evidence available which will be used to develop the Local Development
Plan includes national and local policy, information on existing protected
areas, valued habitats, species, landscapes and geology at all scales. Most
of these are national datasets. Further information on nature restoration
projects and opportunities will support the development of nature
networks. More of this information will come from in-house studies and
local studies and initiatives. 
National Policy Context
Scottish Biodiversity Strategy to 2045  
Strategic Biodiversity Framework Delivery Plan 2024-2030
Scotland’s new strategy sets out a vision to tackle the twin climate and
biodiversity crises. The ambition to be Nature Positive by 2030 and a
vision:
• By 2045, Scotland will have restored and regenerated biodiversity
across our land, freshwater and seas.
• Our natural environment, our habitats, ecosystems and species, will
be diverse, thriving, resilient and adapting to climate change.
• Regenerated biodiversity will drive a sustainable economy and
support thriving communities, and people will play their part in the
stewardship of nature for future generations. 
The Strategy is accompanied by a delivery plan which sets out 31 priority
actions to deliver the strategies high-level goals: 
• 1. Accelerate restoration and regeneration
• 2. Protect nature on land and at sea across and beyond protected
areas
• 3. Embed nature-positive farming, fishing and forestry
• 4. Protect and support the recovery of vulnerable and important
species and habitats
• 5. Invest in nature; and
• 6. Take action on the indirect drivers of biodiversity loss 
Relevant actions in the delivery plan that can be supported by LDP3
include:
• Introduce a programme of ecosystem restoration
• Enhance water and air quality. Undertake water management
measures to enhance biodiversity.
• Identify, expand and enhance Nature Networks and ecological
connectivity
• Enhance biodiversity in Scotland’s urban green and blue spaces
• Expand our Protected Areas to at least 30% of the land and seas
• Champion new planning and development measures for
protecting and enhancing biodiversity
• Implement measures to protect and recover Scotland’s wild
Atlantic salmon
• Engage and strengthen the connection between people and
communities with nature
Nature Networks Framework & Practitioner’s Guide to Nature Networks
These documents set out a vision and guidance for developing nature
networks. Principles include: 
• Bottom up delivery of nature networks
• Transparent governance with empowered delivery partners
• Inclusive, empowering engagement 
• Developing Nature Networks witih local knowledge, experience and
best practice
• Collaborative mapping making best use of data
Considerations for mapping nature network include:

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• Understanding place
• Involving People
• Creating core sites
• Building Resilience
• Embracing Dynamism
• Thinking ‘Networks’
• Considering Constraints
• Planning long term
• Monitoring Progress
More detailed consideration of the identification of nature networks and
vision is set out in the practitioner’s guide and more detail around delivery
is set out in the framework.
Local Context
Perth and Kinross Council Corporate Plan 2022-2027 
Our Local Development Plan 3 (LDP3) will be prepared within the context
of the Council’s Corporate Plan, which sets out the Council’s vision for a
Perth and Kinross ‘where everyone can live life well, free from poverty and
inequality.’  It proposes a number of key priorities for the 5-year period
2022 to 2027.  It also reflects the principles of the Perth and Kinross Offer.   
The Corporate Plan identifies 7 Priorities delivered through a range of Key
Actions.  The Principles include “Tackling climate change and supporting
sustainable places” along with the Key Action to “To conserve and enhance
the biodiversity of our natural environment.
In November 2022 the Council declared a Climate and Biodiversity
Emergency and is a signatory to the Edinburgh Declaration on the post
2020 Global Biodiversity Framework. In December 2021 the Council
adopted its first PKC Climate Change Strategy and Action Plan (CCSAP).  It
sets out the next steps and an initial route map to take us to a net zero
carbon and climate resilient Perth and Kinross.  
The Strategy contains 27 Council Commitments which are needed to
achieve the outcomes guided by Six Overarching Climate Change Strategy
Principles which include, as relevance to biodiversity and natural places,
resilience and enhancing biodiversity.  The Action Plan sets out the
measures being undertaken. Further information is available in Appendix
A, issue A1 Tackling the Climate and Nature Crises.
PKC (2019) Landscape Guidance
The guidance sets out the Local Landscape Areas, their qualities and the
approach of the Council to Wild Land. Together with LDP2 Policy 39 this
sets out the current approach to the most valued landscapes.  
PKC (2020) Forest and Woodland Strategy
Our Forest and Woodland Strategy (FWS) Supplementary Guidance
provides a strategic framework for the development of forestry in the area
and includes a map of sensitivities and opportunities. The map categories
of preferred, potential, sensitive and unsuitable are used to inform forestry
and woodland creation proposals.   
The strategy also sets out principles and opportunities for action by which
new forest and woodlands should be guided. As set out in Appendix A,
issue A4 Forestry, Woodland and Trees there are likely to be competing
demands on our land across Perth and Kinross, and it will be important to
ensure the development of our Spatial Strategy takes account of directing

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future land uses to the most appropriate locations to help achieve
sustainable development.
The Tayside Local Biodiversity Action Plan (2016-2026). The Tayside LBAP
contains a list of priority species, habitats and areas along with actions to
address those priorities. The action plan includes actions for pollinators,
swifts, hedgehogs, bats, amphibians and more. Some of these actions are
already reflected in PKC (2020) Planning for Nature guidance. The actions
will all be taken into account when preparing local policies and
development site allocations.
Existing Landscapes and Geodiversity within Perth & Kinross
Important landscapes are currently identified by national and local
designations. Perth & Kinross covers a wide range of landscapes from
lowland straths and glens to the moors and uplands of the Highlands. Our
landscapes are largely shaped by the underlying geology. While the Local
Authority Area includes the Cairngorms and Loch Lomond and the
Trossachs National Parks the Planning Authority area excludes these. A
large part of the Council area is covered by National Parks, other national
designations for landscape and local landscape designations. Site specific
geological features are covered by Geological Conservation Review sites
and the current programme to designate Local Geodiversity Sites.  Map 1
(included at the end of this paper) shows the national and local
designations for landscape including Gardens & Designed Landscapes with
a high or outstanding scenic value, and Map 2 shows national and draft
local geodiversity designations in Perth & Kinross.
National Parks: Both the Cairngorms and Loch Lomond and the Trossachs
National Parks cross into the Perth & Kinross Local Authority Area. National
Parks are designated for their value including recreation, ecological value
and landscape. National Parks have their own planning authorities. There is
however a need for co-operation on the boundaries of these particularly
with regards to viewsheds of larger initiatives such as windfarms and
Nature Networks.   
National Scenic Areas: There are four NSAs within the Planning Authority
Area. These are:
• Loch Rannoch & Glen Lyon (part)
• Loch Tummel
• River Earn (Comrie to St. Fillans)
• River Tay (Dunkeld)
A report on the Special Qualities of the National Scenic Areas was
produced in 2010 following a resurvey. This will inform implications of
potential development on these areas. 
Wild Land Areas: The NatureScot (2014) Wild Land Areas Map and
Descriptions identifies five WLAs partly within Perth and Kinross Planning
Authority Area. 
• 10. Breadalbane-Schiehallion
• 11. Lyon-Lochay
• 12. Ben Lawers
• 14. Rannoch-Nevis-Mamores-Alder
• 15. Cairngorms

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These also largely overlap with National Scenic Areas and Local Landscape
Areas. By their remote and wild nature they are not expected to come
under pressure from built development. However renewable energy
developments are not excluded from these areas and it is necessary to
identify these areas as sensitive in spatial strategies including for
renewables. Impacts outside the boundaries receive limited consideration
under NPF4 and NatureScot (2023) Assessing impacts on Wild Land Areas –
technical guidance.
Local Landscape Areas: These areas were identified in a comprehensive
review in 2014 using (as was) SNH and Historic Scotland guidance. These
receive a lighter level of protection through NPF4 but are still expected to
be protected from built development and receive consideration through
the Forest & Woodland, Renewables and Nature Networks spatial
strategies.  LLAs and their qualities are identified in PKC (2019) Landscape
guidance . A review of the Local Landscape Area boundaries and qualities
will be conducted to inform the development of the Proposed Plan. 
Landscape Character Types. NatureScot (2019) Landscape Character
Assessment in Scotland produced a map of Landscape Character Types for
the whole of Scotland. These include general descriptions of the character
types with statements covering the specific areas including the perception
of these landscapes. These are useful in assessing any changes to
settlement boundaries or significant allocations to both the impacts and
enhancement opportunities. 
Inventory of Gardens and Designed Landscapes. The inventory contains
sites with Scenic Interest. There are 31 sites in Perth & Kinross which
contain high or outstanding levels of scenic interest as assessed by Historic
Environment Scotland. These will help inform the location of development
and protected views from settlements. Further information can be found
in Appendix A, issue A4 Foresty, Woodland and Trees.
Big Place Conversation Feedback. Some feedback was received during the
Big Place Conversation regarding landscape features of importance in
particular settlements and comments of relevance to landscape in general
such as lighting in rural areas, and the importance of surrounding nature
and rural context. Rural communities in particular valued their location
within open, countryside settings and people throughout villages, towns
and cities valued their access to nature. This information will support
discussions with communities around development allocations and access
and views to the surrounding landscape including the value of a continued
local landscape policy.
Sites of Scientific Interest (Geological and Mixed). These include sites of at
least national importance designated for their geodiversity value. These
are available on SiteLink. These are primarily outside settlements but are
of significance to other spatial strategies including the Forest & Woodland
Strategy, Renewables and Green Infrastructure. Threats to these sites may
come from rural development or renewable applications. The main benefit
of these sites however is for scientific study, historical significance and
public education. Therefore there are potential implications from rural
development on access to these sites.
Proposed Local Geodiversity Sites. The Council is in the final stages of
assessing Local Geodiversity Sites with assessment, landowner feedback

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and adoption to be completed by July 2025. All Proposed LGS are available
to the public at www.pkc.gov.uk/ldp2naturesites. Implications for the plan
are as with SSSIs for geodiversity discussed above although noting that the
protections through NPF4 for local sites are more limited, particularly from
renewable energy applications. See Map 2 (included at the end of this
paper).
Geological Conservation Review Sites. GCRs are nationally and
internationally important sites for geological and geomorphological value.
Further information is available on NatureScot’s webpage on GCRs . The
boundaries are available on SiteLink. The majority of these are covered by
Sites of Scientific Interest (SSSI) but around 20% are not. These remaining
GCRs or parts of GCR sites not covered by SSSIs have been surveyed and
reviewed through the Local Nature Conservation Site programme in
consultation with NatureScot. Where assessed to be of at least local
importance these have been identified as proposed Local Geodiversity
Sites.
Scottish Geology Trust Geosites Database. The project led by the SGT
provides a central database for volunteers to monitor the condition of
geologically important sites currently looking at GCRs. The Council has
access to this database and contributes to it. This information will help to
identify condition, threats and recommended management of GCR sites
where affected by site allocations, boundary changes or spatial strategies. 
Existing Protected Areas and Species within Perth & Kinross
To protect and conserve biodiversity, the most valuable areas, species and
habitats need to be identified. A description of the evidence to be relied
upon follows. This includes protected areas but also includes habitats of
importance for protected species. This will inform where development can
occur, the delineation of settlement boundaries and designation of open
space along with potential local policies to protect or enhance locally
important areas, species and habitats. A map of protected areas for
biodiversity is included in Map 3 (included at the end of this paper).
State of Nature Partnership (2023) State of Nature 2023. This report sets
out the trends for species including plants. The Scotland specific summary
contains commentary on protected areas, woodlands and peatland, the
impacts of land use activities, and climate change. This includes:
• A 15% decline in species abundance
• A 15% increase in distribution of invertebrates due to climate
change
• 11% of species in Scotland are now classified as threatened with
extinction
• 57% decrease in plant and lichen distributions
These declines are measured since 1994 so do not include earlier declines
through habitat loss. The declines (and increases) overall in some species
does not reflect that there are large differences in individual species or
species groups. 43% of terrestrial and freshwater species showed a strong
or moderate decline over the last 10 years with 36% of species showing an
increase. Moths for example have declined 18% since 1970 with the
majority of that decline occurring over the last 10 years. Priorities from this
report include:
• Vascular plants

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• Bryophytes and lichens
• Species associated with arable farmland and semi-natural grassland
• Upland birds
• Wading birds
• Wintering waterbirds
Other concerns include:
• 7% contraction in red squirrels range between 1993-2016
• Significant decline in critically endangered pine hoverfly due to
habitat loss
• 36% of vertebrates are threatened in Scotland
• 31% of Amphibians and reptiles are threatened UK wide
Awareness of these species will help prioritise the actions taken – and
avoided – to protect and conserve these species through spatial strategies
and policies.
The Tayside Local Biodiversity Action Plan (2016-2026). The Tayside LBAP
contains a list of priority species, habitats and areas along with actions to
address those priorities. The action plan includes actions for pollinators,
swifts, hedgehogs, bats, amphibians and more. Some of these actions are
already reflected in PKC (2020) Planning for Nature guidance. The actions
will all be taken into account when preparing local policies and
development site allocations.
Scottish Government (2013) Scottish Biodiversity List. This list contains
species and habitats in Scotland of international, UK or Scotland level
concern. These include the UKBAP listed species and habitats. While the
conservation status of some of these species have changed the JNCC
Conservation Designations for UK Taxa update provides up to date
information on these. 
NBN Atlas.  The NBN Atlas provides records of species on a geographical
basis which can be used together with the status spreadsheets above to
help identify areas that may be affected by allocations and settlement
boundary choices.
NatureScot (2024) Priority Species Heat Mapping. New mapping in
development from NatureScot may help us with identifying - and avoiding
impacts on or delivering support for – priority and protected species when
considering allocations and settlement boundary choices. This has not yet
been released.
Special Areas of Conservation, Special Protection Areas and RAMSAR.
These internationally important protected areas are available on SiteLink
and are important for their habitats, birdlife and wetland habitats
(respectively). These will be taken into account during development of the
Proposed Plan including the Habitats Regulations Appraisal and Strategic
Environmental Assessment. Through NPF4’s promotion of Nature
Networks there is an increased emphasis on supporting these core areas
through buffers and connectivity. This will shape spatial strategies as well
as policies regarding our most important and vulnerable sites. Note that
RAMSAR sites in Perth and Kinross area are covered by SSSI or higher
designations. See Map 3 (included at the end of this paper).
Sites of Special Scientific Interest (Biodiversity and Mixed). These are
nationally important sites for biodiversity (mixed sites also have a

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geodiversity interest). As with SACs, SPAs and RAMSAR sites these are
available on SiteLink. The Strategic Environmental Assessment (SEA) of any
spatial strategies or site allocations will include consideration of the value
of these sites. See Map 3 (included at the end of this paper).
SiteLink contains the latest monitoring results of the conservation status of
international and nationally designated sites. SiteLink will be used to assess
whether these sites should be targeted for particular measures for
protection or enhancement. The overall conservation status of a site is a
result of an aggregation of the status of its qualifying features so further
examination may be necessary. Monitoring may also have not occurred for
some time. The requirement in NPF4 Policy 4 to take a precautionary
approach to these sites is therefore important to bear in mind. For
example Loch Leven SSSI, RAMSAR and SPA an overall favourable status
but features including breeding tufted duck, wetlands and the loch itself
are unfavourable recovering. 
SEPA water classification hub. The hub  has a more up to date picture of
water bodies and water courses and although this is a different measure of
the quality of a site to the official conservation status for protected areas it
can give an indication of whether such a site is improving or in decline
since its last assessment. 
Currently LDP2 has special policies and guidance for select protected areas.
Assessment of these areas will affect the policies and strategies in the Plan
including a precautionary reallocation of housing numbers in Kinross-shire
to protect Loch Leven. Subject to the assessments precautionary measures
may continue to be implemented for the following protected areas, their
catchments and qualifying interests:
• River Tay SAC
• Dunkeld- Blairgowrie SAC (Lunan Lochs)
• Loch Leven SPA, NNR, RAMSAR and SSSI 
All features of the River Tay SAC are classified as favourable on SiteLink
although the latest visit was in 2012 for otters, 2011 for salmon and earlier
for other fish species. On the SEPA water classification hub the majority of
the Tay SAC is shown as moderate to good although some sections
including the River Tummel to River Isla section, and the River Bruar are
poor to bad. 
The Lunan Lochs show an unfavourable picture (excluding otters) on
SiteLink but an improving picture on the water classification hub. 
Loch Leven on SiteLink is overall favourable for the majority of features
associated with the site but unfavourable recovering for the eutrophic loch
itself. This was last reviewed in 2024 and remains unchanged from the
previous assessment in 2008. The water classification hub shows a
worsening picture for phosphorus input – the main concern in the loch.
Lochs and Climate Change research. The CREW partnership including the
UK Centre for Ecology & Hydrology (CEH) has carried out two recent
studies into the impacts on Climate Change on freshwater Lochs in the UK.
The first looking at the effect of climate change on lochs and the second
looking at solutions. These include the use of Loch Leven as a case study.
Changes to land use, changing rainfall patterns and rising temperatures are

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impacting lochs. The main solution to the input of phosphorus into lochs
are measures to prevent erosion and run off. The planning system has little
control over sustainable land management practices but erosion and
runoff from rural development can be controlled through mechanisms
such as the Forest and Woodland strategy and incentives through the
identification of nature networks and potential use of offsite enhancement
from NPF4 policy 3. 
Lower South Queich Restoration Project. A further study was
commissioned by the Council to scope the requirements for a reduction in
erosion on the South Queich. The completed report from the Forth Rivers
Trust provides information on how this intervention could remove a
barrier to fish migration and reduce loss of soil with a significant
consequent drop in phosphorus entering the loch. It will help inform
development of local policy to tackle loch pollution.
Loch Leven Natural Flood Management Study. This report produced for
the South Kinross Flood Management Scheme contains a comprehensive
set of costed proposals to reduce flooding further downstream. The
cost/benefit analysis resulted in no NFM measures being pursued at the
time but with a recommendation that they be brought forward when
possible. Potential interventions and options for the contribution of
development to NFM are being explored through the Loch Leven Lens
project currently under development. This also has implications for the
Forest & Woodland Strategy and Nature Networks.
Loch Leven Nutrient Load and Source Apportionment Study published by
and available from NatureScot in 2017 set out the sources of phosphorus
into the loch (the main source of algal blooms) and informed the
development of LDP2. An updated study due to be commenced in 2025
will also address the impacts of combined sewer overflows into the Loch.
The report and updated data from the new study will inform consideration
of and preparation of policy and spatial implications for development in
Kinross and Milnathort. 
Candidate Local Biodiversity Sites. Proposed Local Nature Conservation
Sites for Biodiversity have been identified through a combination of
Scottish Wildlife Trust records, valued sites from expert NGOs and
NatureScot. Further information is available on the Local Nature
Conservation Sites webpage. Sites include lowland and gorge woodland,
bog, species rich grassland and ponds.  The majority but not all of these
sites remain of value for biodiversity, with forestry and undergrazing on
grassland sites the most common cause for concern. These sites, shown on
Map 3 (included at the end of this paper), are largely outwith settlements
but may be affected by countryside development, forestry and renewable
applications. Sites will be finalised in 2025.
Existing Information to inform Nature Networks, biodiversity
protection and compensation.
NPF4 requires LDPs to spatially identify Nature Networks. NPF4 also
requires development to protect and deliver Nature Networks, along with
biodiversity compensation and enhancement following the mitigation
hierarchy. Information sources are identified that will inform the
development of Nature Networks and other potential priorities for
protection and delivery of restoration through compensation and
enhancement including offsite measures.

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AECOM Strategic Corridors Maps: This Scottish Government funded
project has identified strategic corridors for nature to be used as a basis for
developing nature networks. These maps are accompanied by a project
optimiser tool which will help identify the value of specific proposed
interventions but can also help shape the corridors themselves. This work 
will be supplemented by engagement to identify other nature valuable
sites for inclusion and the principles on which local nature networks should
be based. 
AECOM Wildlife Movement Map. Developed to inform the AECOM
Strategic Corridors map, this will be used to inform the development of the
Council’s own nature networks map where shifts to the existing corridors,
or new corridors, are considered necessary as a result of further
engagement and mapping work. 
AECOM Eco-uplift tool. Developed to allow local authorities to design their
own nature network corridors or explore enhancement projects. The tool
utilises a range of underlying habitats and factors to produce an ecosystem
services score for each. As a combination of satellite data and existing
mapping, any such work will need to be assessed against but provides a
additional tool to assess potential corridor creation and biodiversity
enhancement measures. Opportunities mapped along the AECOM
strategic corridors which have a positive weighting for biodiversity and at
least neutral for flood and carbon storage are shown in Map 6 (included at
the end of this paper).
Existing Nature Rich Areas (proxy  OECMs).  OECMs are Other Area Based
Conservation Measures. These are sites rich for nature and managed for
nature which are expected to be core components of Nature Networks.
There is an international definition of these areas including a requirement
for a long term management plan. NatureScot is tasked with identifying
and assessing these areas which will take time. For the purposes of
establishing Nature Networks we need to at least recognise and
incorporate areas that can be reasonably assured to be managed for
nature and will function to support nature through inclusion in Nature
Networks. These may often be sites on private land that have not been
identified through the Local Nature Conservation Site programme. Note
that all RSPB and SWT reserves are covered by other designations, and
Woodland Trust sites are being reviewed as part of the Local Nature
Conservation Site programme. Additional proxy OECMs could include
sizeable (e.g. over 2ha):
• Community Woodlands
• National Trust for Scotland natural sites
• Areas of estates managed exclusively for nature 
Existing restoration projects. A significant amount of work is already being
carried out across Perth and Kinross to improve land and water for nature.
An understanding of these projects, their future impact and how they
function will help draw together Nature Networks. Ongoing projects also
provide an opportunity for enhancement delivered by offsite enhancement
where this meets rigorous tests of additionality, validation, evaluation and
monitoring. These projects include:
• Riverwoods: Upper Tay Catchment Communities and The  River
Ericht Catchment Regeneration Initiative
• Loch Leven LENS

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• Nature Restoration Fund Projects: Both NatureScot and PKC funded
projects
• Northwoods Rewilding Network sites 
• Peatland Restoration fund projects
• Woodland Carbon Code 
• Biodiversity Villages initiatives
• Wildlife Accredited Estates 
Where boundaries are available these projects are included on Map 5
(included at the end of this paper).
Investment Ready Projects. Some of the projects above including
Riverwoods and Loch Leven LENs may be appropriate for offsite
enhancement as the Council develops its approach to NPF4 policy 3(b).
Further engagement and discussion will be needed with these projects to
develop local policy guidelines to deliver positive effects for biodiversity.
Natural Flood Management Studies.  There are existing NFM studies
which were carried out as part of flood prevention schemes throughout
Perth & Kinross. These will provide opportunities for intervention for
blue/green infrastructure, nature networks and will help inform the
development of local policy to deliver offsite enhancement for policy 3(b).
Studies have been carried out for:
• Aberfeldy
• Blackford
• Comrie
• Invergowrie
• South Kinross
PKC (2024) Strategic Flood Risk Assessment. The Strategic Flood Risk
Assessment July 2024 is designed to inform the development planning
process, primarily to avoid increasing overall flood risk by avoiding the
flood risk area as defined in NPF4. Further information can be found in
Appendix B, B5 Flood Risk and Water Management.
Forest and Woodland Strategy. The current FWS is currently under review.
The existing FWS will be taken into account when developing nature
networks and will be informed by studies as it progresses.
NatureScot (2022) Habitat and LandCover Map of Scotland Eunis 2 . This
landcover map available on NatureScot’s open data website will be used to
help shape Nature Networks and identify land where development and
forestry should not occur including Scottish Biodiversity List priority
habitats where these align with EUNIS level 2 or at least a wider category
within which the SBL habitats sit, to allow for further investigation on a site
by site basis.
NatureScot Mountain Woodland Restoration Areas. The NatureScot
dataset for Mountain Woodland Restoration shows areas of mountain
restoration of woodland across Scotland where deer have been excluded
including areas in Perth & Kinross namely:
• East Schiehallion
• Dun Coillich 
• East Morenish, Edramucky and Craig an Lockhart at Ben Lawers

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These sites are known restoration areas which will benefit and be
benefited by inclusion in Nature Networks and are shown on Map 5
(included at the end of this paper).
SEPA Wetlands Inventory. This map and associated data provides
information on Scotland’s wetlands including non-designated sites. Healthy
wetlands are a rich resource for biodiversity and for water resilience. This
will be taken into account in Nature Network mapping in support of Green
/ Blue Infrastructure mapping.
SEPA River Basin Management Plan for Scotland. This water classification
hub update from 2021 sets out pressures and actions for waterbodies and
the data may identify pressures in the water environment which creation
or enhancement of nature networks can address.
SEPA Water Classification Hub. The SEPA Water Classification Hub gives an
up to date picture of the state of the majority of water courses and water
bodies in Scotland. As well as identifying which protected areas require
additional support through policy, the data will help identify potential
restoration opportunities for offsite enhancement and nature networks.
SEPA Riparian Vegetation Planting Opportunities. This map will support
development of nature networks and opportunity mapping for Blue/Green
Infrastructure. 
SEPA Geomorphic Risk Buffer. This map identifies areas at risk of erosion
where positive interventions will have the most positive impact on
downstream sedimentation affecting aquatic habitats and loch health.
SEPA River Recovery Potential. This data layer identifies the ability of
rivers to be restored following identification of need. Rivers with higher
energy are identified as having greater opportunity for restoration.
SEPA Obstacles to Fish Migration. This data layer identifies fish barriers
which impact the migration of species which spawn in upper catchments.
Where there is suitable habitat upstream and the transfer of inappropriate
species can be managed removal or management of these barriers can be
an effective way to support these species by increasing their available
range with a simple step. Identifying these may lead to interventions
through off site enhancement or targeting through nature networks.
SEPA Flood Hazard Maps. A range of flood extent maps are available from
SEPA Environmental Data website. Because development is required to
avoid flooding, these areas (excluding important areas for food growing)
are therefore available for enhancement associated with nature networks. 
SEPA Recommended Riparian Buffer. This new map available on the SEPA
Environmental Data website will provide a recommended riparian offset to 
allow rivers to adapt to changes in flood frequency. As well as being
relevant to the location of development it will also be valuable in
identifying nature networks and blue/green infrastructure to support
wildlife and the benefits that riparian vegetation can bring.
SEPA Water Environment Framework Projects. This layer available from
the SEPA Environmental Data website sets out the locations of potential,
existing and completed projects for improvement of the water
environment. There are no completed or current projects in the area but

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potential project location will inform nature networks and restoration
opportunities.
Inventory of Raised Bogs.  This dataset derives from the R Lindsay and P
Immirzi (1996) An Inventory of Lowland Raised Bogs in Britain. Raised bogs
are a priority habitat and are valuable habitats for biodiversity and carbon
sequestration. The data will be used to help identify priorities for
intervention and inclusion within nature networks. There are a significant
number of bogs on the inventory in Kinross-shire, some of which are
covered by other designations. 
Invasive Non-Native Species. Records for non-native invasive species
particularly the priority plant species of Himalayan Balsam, Japanese
Knotweed, Giant Hogweed, American Skunk Cabbage are recorded on NBN
Atlas. Hotspots for mink, grey squirrel and signal crayfish will also be
considered. Many of these areas are already being tackled by the Scottish
Invasive Species Initiative and Perth & Kinross Council working closely with
SISI. Further identification of problem areas will help target intervention
opportunities in Nature Networks.
Peatland Action Mapping.  Data from the peatland action mapping portal
provides information on current and completed peatland action
restoration projects to inform the development of nature networks.
Soils Maps. A number of other soil maps will help inform restoration and
nature network opportunities by providing information on active and
degraded peat, underlying soil types to help identify the most relevant
interventions, and agricultural soils maps to identify constraints and
restoration opportunities:
• National Soil map of Scotland
• Carbon and Peatland 2016 map
• Land Capability for Agriculture map 
Important Plant Areas. These are areas identified as internationally
important for plant assemblages particularly covering highland grasslands.
Most areas are SSSIs and the ones that are currently not already protected
will be surveyed as part of the Local Biodiversity Sites identification
programme.
Important Bird Areas. This layer from RSPB opendata shows areas of
importance for birds identified as part of the BirdLife International IBA
programme. These are a relevant consideration when considering routes
for nature networks where not already under another protective
designation.
Ancient Woodland Inventory. The AWI available on the Environment Web
portal, provides data on Scotland’s woodlands providing different
categories. The AWI covers a range of woodland beyond that addressed in
the NPF4 definition but are still valuable or potentially valuable for
biodiversity. By overlaying this with the Native Woodland Survey of
Scotland data, current Ancient Semi Natural Woodland can be identified
for inclusion in Nature Networks. Other categories such as LEPO may be
suitable for restoration. See Map 4 (included at the end of this paper).
Native Woodland Survey of Scotland and Aerial Mapping. Scotland’s
Environment web mapping provides the Native Woodland Survey of
Scotland data. This data is incorporated into the AECOM Strategic
Corridors mapping tool. This data is dated and needs to be validated

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alongside aerial mapping and NatureScot Habitat Mapping to ensure the
woods are still there but provides evidence for local identification of
nature networks. See Map 4 (included at the end of this paper).
Forest Research (20232) GB National Forest Inventory. This dataset
provides an up to date view of existing 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. This data can be used alongside the
NWSS survey above to help validate existing native woodlands.
Buglife B Lines. The BLines map sets out areas identified in Perth & Kinross
for pollinator enhancement. The Strathmore section of these have
received active restoration work with support from Tayside Biodiversity
Partnership and BugLife. These are existing identified nature networks and
the Planning Authority supports delivery of these to be included as already
established within the local Nature Network mapping. These also provide
clear opportunities for offsite delivery. See map 5 (included at the end of
this paper).
Butterfly Conservation Priority Butterfly Records.  These records for 4
priority species (in house data provided by Butterfly Conservation) will
provide hotspots and existing corridors to help develop nature networks. 
Inventory of Gardens and Designed Landscapes. The inventory contains
sites with Nature Conservation Value. There are 22 sites which contain
high or outstanding levels of nature conservation value as assessed by
Historic Environment Scotland and are shown on Map 4 (included at the
end of this paper). These will help inform Nature Networks. Further
information can be found in Appendix A, issue A4 Forestry Woodland and
Trees. 
Summary of Implications for the Proposed Plan:
Landscape & Geodiversity
The evidence listed includes existing landscapes of national importance
which will be taken into account in developing spatial strategies. Locally
identified landscape and geological features can provide some safeguard
of areas of at least local importance and will be taken into account during
the Proposed Plan preparation. Further landscape information from the
sources indicated will be used to inform allocation and settlement
proposals. Settlement audits and discussion with stakeholders and
communities around the importance of landscape will assess the need for
and shape any continued local landscape policy.
Protected Areas and Species
The evidence for priority habitats, species and protected areas will help
develop spatial strategies by the identification of important areas to avoid
but also where development can support interventions for habitats and
species through policy development and site specific enhancement in
allocations or overall approaches in settlements or areas. A review of the
condition of the status of SPAs, SACs and SSSIs both through condition
monitoring and SEPA water based monitoring, and invasive species records
will help inform whether continued or additional interventions are
necessary and how they should be implemented. NatureScot has indicated
that invasive species are now a threat in the Loch Leven catchment.

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The Tayside LBAP and Scottish Biodiversity List together with the NBN Atlas
can provide information on locations of importance for protected and
priority species. Guidance already requires minimum enhancement
measures for amphibians, hirundine bird species, barn owls and bats.
Engagement with Tayside Biodiversity and NatureScot will help shape any
local policies required in LDP3, while reviews of data at settlement and site
level will shape the spatial strategy. 
Nature Networks, Compensation and Enhancement
NPF4 Policy 1 and NPF4 Policy 3 lend significant weight to the nature crisis.
The introduction of Nature Networks and biodiversity enhancement lends
additional weight to proactive action for biodiversity to be delivered
through development subject to the gaps and uncertainties raised below.
This has implications for site and settlement analysis and policy
development where enhancement opportunities and network connectivity
will need to be promoted. On a wider landscape scale, the role of
landowners is essential, many of whom are already delivering significant
benefits through integrated land management and biodiversity projects.
Successful delivery will require collaboration with landowners to deliver
the ambitions in NPF4. This will also be true in identification of
opportunities and nature networks.
Nature Networks provide a strategic route for protection and restoration
of nature to ensure species and genetic movement between nature rich
sites. This will promote resilience of species in the face of climate change
with additional ecosystem benefits such as flood mitigation and erosion
protection. As the Council develops its approach to offsite mitigation and
enhancement, the identification of Nature Networks also enables the
identification of opportunities for strategic interventions as a result of
developments which cannot deliver full compensation or enhancement on
site. 
Gaps, Uncertainties or Key Issues Raised:
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 6 qualities of
place. Perth & 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 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.

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There is currently no policy which covers 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 LGS standard.
Whether remaining GCR should be protected through policy as a
consequence 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 NatureScot to
complete assessments. Many of these are out of date. The result is that
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 still 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 & Kinross is 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 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 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. A
number of potential opportunities and constraints are identified in the
sources above 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 & 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.

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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. 
Relevant Stakeholder Engagement to Date
Consultation on Perth and Kinross Council’s Draft Climate Emergency
Report and Action Plan (2019)
Public engagement took place from October 2020 through to January 2021
on the Council’s draft Climate Emergency Report and Action Plan (2019). 
The engagement exercise consisted of an online survey split into five series
of questionnaires and several thematic online sessions.  
The engagement survey received 480 responses while an approximate of
280 attendees took part to the online sessions. The feedback received
throughout the engagement survey was considered in the development of
the finalised Climate Change Strategy and Action Plan.
Participants were asked their views under the Land Use theme of the
survey on a range of topics, including biodiversity, greenspaces, open
spaces, planning controls, agriculture, and other land uses.  There were 67
responses overall to this theme.  
With regards to biodiversity – 67.2% of the respondents did not think that
the Council had enough measures in place at the time of the survey to
protect biodiversity.  Respondents also commented that the Council could
enhance its biodiversity protection measures through a number of actions,
such as: improve greenspaces, use planning powers to protect biodiversity,
and follow the approach used by other local authorities to safeguard
pollinators
In response, the Council’s ‘Enforcement Charter’ has recently been
reviewed, and part of that review it was considered whether appropriate
priority is given to cases impacting on Perth and Kinross Council priorities,
such as climate change, trees affected by tree preservation orders, and
biodiversity. A monitoring exercise will also be conducted as part of the
development of the new Local Development Plan 3 to assess the
effectiveness of planning policies and planning conditions, keeping in mind

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that for the most part, current LDP2 policies have been superseded by
national policies contained in NPF4.
Perth and Kinross LDP3 Big Place Conversation
The Council carried out its ‘Big Place Conversation’ exercise to kick start
the LDP3 process across Perth and Kinross communities during most of
2023.  The exercise involved over 100 events across the Council Area.  
The results of the Big Place Conversation have been collated at Council,
ward and community council level.  This includes place specific concerns
regarding landscape, valued natural assets such as the Cateran trail, the
River Tay and Loch Leven, and opportunities such as locations where
natural flood management could be explored. A summary of the results of
the exercise, are provided as part of LDP3’s Evidence Report. The main
themes coming out of the exercise are:
• The importance of nearby countryside for access to nature and
landscape value
• The importance of hills, forests and rivers to young people
• A desire for more biodiversity in urban greenspaces, particularly
from young people
• A desire to ensure natural spaces are protected and not lost to
development 
• Limited natural or green spaces in some urban neighbourhoods
Nature Networks and Biodiversity Enhancement Consultation
Prior to publishing of interim guidance on the Council’s approach to NPF4
Policy 3, an online consultation was held to inform the next steps for the
development of nature networks and compensation and enhancement
mapping and guidance. This provides a starting point for developing policy
around enhancement and nature networks. Responses were received from
18 members of the public and 12 landowners or public bodies. The main
points from the consultation were:
• Local Biodiversity Sites should be included as core areas in Nature
Networks
• Focus for Nature Networks should be on priority species, natural
flood management and improving existing core areas
• Constraints such as agricultural land should be overcome rather
than avoided
• Following natural existing corridors should take priority
• Enhancement requirements should include a specific percentage
uplift for local applications
• An enhancement requirement for major applications should be
between 10-30%
• A mixed picture was received on whether enhancement should
reflect that affected by development or what is best for biodiversity
• Most thought enhancement should be as close to the development
as possible but landowners took a wider view
• Assurance is required for delivery of offsite measures on land
outwith the developer’s control
• There was strong support for a Council register of landowners
willing to agree enhancement measures on their land as a result of
development. 
Summary of Stakeholder Engagement:
The Council produced and consulted on a series of Topic Papers which
covered the individual subject matters of NPF4’s national planning policies
suite.  These papers set out in detail the evidence the Council has gathered

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to help produce our Evidence Report, and which we hope to use to
prepare our LDP3 Proposed Plan.  The papers were published on the
Council’s Consultation Hub for a 6 week period during July and August
2024.  As part of our consultation process for LDP3 Topic Papers we
welcomed the views of our key stakeholders (who were contacted
specifically via email regarding the consultation exercise) and 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.

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Statements of Agreement/ 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. A summary of these comments, their status, and the Council’s response
are provided in the table below.   
There were 2 responses on the Biodiversity and Natural Places issue which the respondents wished to be treated as a formal dispute to the Evidence Report
(highlighted in red in the table), 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 (highlighted in amber in the table). 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Private Individual Disagree – but
does not wish to
register as a
formal dispute
List of Evidence/Datasets: Does not agree with list of
evidence but no further information received.
Summary of Implications: Does not agree with summary of
implications for the proposed plan. 
Further Comments: States there is no climate or nature
crisis.   
Formal Dispute: The respondent does not wish for their
comments to be registered as a formal dispute. 
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• PKC has declared both a climate emergency
and signed up to the commitments of the on
post-2020 global biodiversity framework. 
No action required for this Evidence Report. 
Ristol Consulting Disagree – but
does not wish to
register as a
formal dispute
List of Evidence/Datasets: Agrees with the list of evidence
Summary of Implications: Does not agree with summary of
implications for the proposed plan and would welcome the
development of a biodiversity net gain framework, a future
developer contributions policy and a biodiversity register for
offsite enhancement. 
Further Comments: No Comment
Formal Dispute: The respondent does not wish for their
comments to be registered as a formal dispute. 
PKC welcomes the respondent’s comments and
responds to the points raised within as follows
• An interim position on net gain biodiversity
has been provided through guidance since
completion of this consultation. This will be
developed further into policy as set out
above as part of preparation of the
proposed plan.
• A biodiversity register will be explored first
as part of “opportunity mapping” as part of
Nature Networks mapping engagement.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response 
• Future developer contributions policy to
contribute to specific projects will be
considered at plan preparation stage. A
general fund for biodiversity enhancement
is not currently possible under the policy
and legal framework.
Errol Community
Council
Neither List of Evidence/Datasets: No comment
Summary of Implications: No comment
Further Comments: 
• Concern about enforcement of unconsented
development
Formal Dispute: No Comment
Not a comment on the evidence report but will be
taken into account in policy development during
proposed plan preparation.
Nature Scot Neither List of Evidence/Datasets: Neither agrees nor disagrees with
list of evidence
Summary of Implications: Suggested changes to emphasise
condition monitoring and policy changes
Further Comments: 
• An update on Loch Leven condition monitoring was
provided 
• Inclusion of landscape and GCR was welcomed
Formal Dispute: No comment
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• Summary of implications section has been
revised to emphasise the required sections
• Reference to the draft Scottish Biodiversity
Strategy has been added
• Additional information on Loch Leven
incorporated into the text
SEPA Disagree – but
does not wish to
register as a
formal dispute
List of Evidence/Datasets: Disagree with the list of data.
• Recommend Strategic Flood Risk Assessment in
nature network mapping rather than flood maps
alone
• Recommends including the 2021 update to the River
Basin Management Plan for Scotland (RBMP3)
https://informatics.sepa.org.uk/RBMP3/) as
important for nature networks. 
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• The recommended data sets have now been
included
• Agree that river corridors provide multiple
benefits and are existing nature networks.
They will naturally receive priority. This reflects
the results of the nature networks engagement
carried out above. For some core areas that

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Summary of Implications: Emphasises the importance of the
water environment to nature networks and requests that
river corridors are established as a key principle in the
identification of nature networks across Perth and Kinross.
Further Comments: None
Formal Dispute: The respondent does not wish for their
comments to be registered as a formal dispute
require support or connections riparian
habitats may not be the most appropriate
connection or a more direct route e.g. across
watersheds may not follow rivers.
• The 2021 update to the RBMP3 has been
included as evidence
Kenmore and
District Community
Council
Neither List of Evidence/Datasets: Neither agrees nor disagrees with
the list of evidence
Summary of Implications: Neither agrees nor disagrees with
the summary of implications
Further Comments: 
Concern raised that Loch Tay should be a “quiet loch” and
concern around impacts from development on the
biodiversity of the loch, particularly with regards to
discharge of effluent.
Formal Dispute: No Comment
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• Pressures on the loch will be reviewed with
reference to the databases noted above and
also in conjunction with the community during
preparation of the proposed plan.
No changes are made to the evidence report as a
result.
Homes for Scotland Dispute List of Evidence/Datasets: Agrees with the list of evidence 
Summary of Implications: Disagrees with the implications
for the proposed plan. 
• Reiterates that LDP3 is expected to identify and protect
natural assets at all levels and safeguard those assets
when allocating land for development, with the Topic
Paper stating locally identified landscapes can provide
some safeguard of areas of at least local importance and
will be taken into account during the Proposed Plan
preparation. Citing NPF4 Policy 4 states that the plan
should not restrict developments from happening
completely but all for developments that align with
policy 4 due to the socioeconomic benefits of building
homes. 
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• The commitment of house builders to
biodiversity is welcome. There is no tension
between the statement that areas of at least
local importance will be taken into account and
aligning with policy 4. Socio economic benefits
will be assessed in accordance with policy 4.
• While recognising that residual risks to the
environment can be mitigated through a CEMP,
NPF4 requires LDPs to implement the
mitigation hierarchy. A CEMP would be suitable
consideration following avoidance in the first
instance.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
• Requests that the Topic Paper recognises that risks to the
water environment can be mitigated through the use of a
Construction Environment Management Plan. 
• States that trees/woodland on promoted sites should not
preclude the site from development as trees/woodland,
can be incorporated into site layout and benefit from a
management plan thereby contributing to the amenity of
the development and providing a community asset. All
factors should be considered for a balanced decision. 
Further Comments: 
• Homes for Scotland members already committed to
integrating biodiversity with 21 home builders, some of
whom are HFS members signed up to Homes for Nature. 
• HFS members support nature networks by strengthening
habitat connectivity by providing permeable boundaries
to allow safe movement for nature, therefore supporting
improved ecological improvement and helping to restore
degraded habitats.
• Notes that HfS responded to NatureScot’s consultation
on the biodiversity metric that the metric will assist Local
Authorities in the identification/assessment of existing
habitat. 
• It is important to recognise that the site selection process
must also consider other factors alongside matters
relating to biodiversity, including marketability and
deliverability. 
Formal Dispute: Yes 
• Agree with the statement that trees and
woodland do not necessarily preclude a site
from consideration.
• Further comments not directly related to the
evidence or implications for the plan are
welcomed. 
Loch Developments
Ltd
Agree List of Evidence/Datasets: Neither agrees nor disagrees with
the list of evidence 
List of Evidence/Datasets: Agrees
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:

Page 93

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Summary of Implications: Neither agrees nor disagrees with
summary of implications 
Further Comment: 
• Consideration should be given to opportunities to create
enhanced access and connections for people and nature
to protect sites 
Formal Dispute: No 
• Agree with the comment. Nature networks and
green infrastructure will aim to achieve this.
SSEN Transmission Agree List of Evidence/Datasets: Agrees
Summary of Implications: Agrees
Further Comment: 
• Recommends National Forest Inventory be added to the
evidence. NFI should increase across council area.
Formal Dispute: No
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• Agree that the NFI 2023 is useful and this is
added to the data sources above 
Scottish Water Agree List of Evidence/Datasets: Agrees
Summary of Implications: 
Further Comment: 
• Scottish Water remains committed to continuing to work
with Perth & Kinross Council on surface water
management and assessing the impacts of sewer
overfows and other sources on Loch Leven
Formal Dispute: No
PKC welcomes the respondent’s comments
Anonymous Agree List of Evidence/Datasets: Agrees.
• Supports depth of consideration
• Supports the highlighting of the state of nature
Summary of Implications: No comment
Further Comment: No Comment
Formal Dispute: No
PKC welcomes the respondent’s comments

Page 94

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
GS Brown
Construction Ltd
Neither List of Evidence/Datasets: Neither agrees nor disagrees
Summary of Implications: No comment
Further Comment: 
• Identifies that nature networks will be a helpful tool
for developers to assist in improving connectivity and
enhance nature networks and in turn providing
better neighbourhoods. Would like to explore further
how nature networks can provide positive
opportunities for new built development.
Formal Dispute: No
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• Once draft nature network map is
established based on existing habitats and
restoration opportunities, the preparation
of LDP2 will enable consideration of
delivery of nature networks by and
alongside development.
Private Individual  Dispute List of Evidence/Datasets: Disagrees
• The topic has failed to consider smaller issues of
housing impacting biodiversity
Summary of Implications: Disagrees
• Local biodiversity is not considered as for example
the A94 corridor which has plenty of biodiversity
away from the road.
Further Comment: 
• No comment
Formal Dispute: Yes:
• The lack of consideration to local biodiversity
• The negative impact of development
PKC has not received a response from the
respondent to enquiries regarding the dispute.
The strategic implications of impacts on
biodiversity of housing and infrastructure
developments are addressed through the evidence
set out above. Further consideration will be given
to site specific impacts of allocations, settlement
boundaries and their impacts on green
infrastructure as the proposed plan is developed.
Earn Community
Council
Agree List of Evidence/Datasets: Agrees
Summary of Implications: Agrees
Further Comment: 
• Big Place Conversation mentioned several times. 
• Planning must take account of land quality, flood risk
and biodiversity when reviewing development plans.
“Planning for Nature” states increased on- site
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• More detail is now provided on Big Place
Conversation results and reports have been
provided
• Site assessment will take into account all of
the issues mentioned

Page 95

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
restoration and enhancement. Last resort is “off Site”
compensation. 
• Village initiatives are mentioned, but no detail.
• “Nature Networks” mentioned but on-going so no
detail.
• There are many species under threat throughout
Scotland.
Formal Dispute: No
• Village initiatives will be considered during
the collaborative proposed plan stage
• Nature Networks are ongoing and
community councils will be included in the
discussions
• Species under threat will be considered in
more detail during the plan preparation
utilising the tools noted above.
Dupplin Estate Neither List of Evidence/Datasets: Neither agrees nor disagrees
Summary of Implications: Neither agrees nor disagrees
Further Comment: 
• Land owning estates such as Dupplin, are increasingly
focusing on integrated land management with
multiple benefits for the environment and the
delivery of social value. Landowners are also
increasingly cooperating on landscape-scale schemes. 
• Dupplin is working with a number of adjacent
landowners to bring forward the 175 hectare "Perth
Sustainability Park" on the southwestern edge of
Perth, which will deliver a new parkland for the city
while connecting woodland habitat, rewilding
agricultural land and enhancing existing natural
assets 
• Focus should be made to bring biodiversity and
Natural Places into the larger urban areas in the
council area to improve the current state of
biodiversity. 
Formal Dispute: No
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• Landowner partnerships are welcome and
will be supported wherever possible
especially in the delivery of nature
networks. 
• Biodiversity enhancement within
settlements will be the focus of
development delivered biodiversity and
opportunities will be assessed through the
site appraisal process, green infrastructure
mapping and collaborative plan
preparation. 
Scone Estate Neither List of Evidence/Datasets: Neither agrees nor disagrees
Summary of Implications: Neither agrees nor disagrees
Further Comment: 
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
• It should be explicitly recognised that Perth and Kinross
landowners are critical to achieving strategic scale
environmental benefits that, in turn, help achieve LDP
aims. Landowners are increasingly focusing on integrated
land management to better benefit the environment and
also to increase social value delivery. This should be
referenced within any final Evidence Report.
Formal Dispute: No
• Agree with the role of landowners in delivering
biodiversity enhancements and particularly in
relation to nature networks. The summary of
implications section has been updated to
reflect this role.

Page 97

Map 1: National and Local Landscape Interests

Page 98

Map 2: Geodiversity Designations

Page 99

Map 3 Protected Areas for Biodiversity

Page 100

Map 4 Nature Networks: Existing Natural Areas

Page 101

Map 5: Nature Restoration Projects

Page 102

Map 6: Nature Restoration Opportunities

Page 103

Map 7: Constraints

Page 104

Issue: Soils
Corresponding NPF4 Policy/Policies:
National Planning Framework 4 Policies:
 NPF4 Policy 5 – Soils
 Other key NPF4 policy connecfions:
o Policy 1 – Tackling the climate and nature crises
o Policy 2 – Climate mifigafion and adaptafion
o Policy 3 – Biodiversity
o Policy 4 – Natural places
o Policy 6 – Forestry, woodland and trees
o Policy 7 – Historic assets and places
o Policy 11 – Energy
o Policy 20 – Blue and green infrastructure
o Policy 29 – Rural development
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 006: Soils
Information required by the Act and NPF4 regarding the topic:
In line with the requirements of the Act, the following information is required for
the Plan:
 Principal physical and environmental characterisfics of the district in
relafion to soils
Under NPF4 Policy 5, LDPs are expected to:
 protect locally, regionally, nafionally, and internafionally valued soils,
including land of lesser quality that is culturally or locally important for
primary use.
Evidence has been prepared relating to the policy subject of soils as contained in
the ‘Local Development Planning Guidance’ (2023, p.43). This includes
information relating to the NPF4 Policy Advice & considerations referenced in the
Evidence Report Guidance for the soils policy topic (NPF4 Policy 5).
Specifically, the Guidance (p. 112) sets out that:
“The spatial strategy should take a strategic approach to managing the soils
within the plan area. Soils are vital living ecosystems in their own right, which also
underpin biodiversity across all the ecosystem services upon which people
depend. Maintaining and improving soil health is a key outcome for Scotland’s
Biodiversity Strategy, for nature, people, and our economy. Peatland and carbon-
rich soils in addition hold the potential to play a critical role in helping to achieve
the net zero target by 2045, through sequestering and storing carbon, whilst
peatland restoration can help Scotland's people and nature adapt to the impacts
of climate change through, for example, helping to control flooding and bringing
increased resilience to drought to peatland ecosystems. More broadly, soils are
one of our most valuable assets and are critical to ambitions for Scotland to be a
global leader in sustainable and regenerative agriculture. 
The process for allocating land for development can therefore be informed by the
location of valued soils that are to be maintained, protected and/or enhanced
and restored. In assigning value, consideration may be made to the wider benefits
that soils offer to sustainable land-use. Benefits include carbon sequestration,
natural flood alleviation, blue-green infrastructure and supporting biodiversity
and nature networks.”
Links to Evidence:

Page 105

Soil and habitat types/characteristics
 Nafional Soil Map of Scotland
 Soil map of Scotland (parfial 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 Hufton Insfitute (JHI) - Carbon Sequestrafion Study (2021)
[Core Doc Ref: CD1]
 Peatland Acfion - peat depth | Scotland's soils
(environment.gov.scot)
Land Capability for Agriculture
 Land capability for agriculture map (parfial cover)
Soil Risk Maps
 Soil risk maps
 Map of subsoil compacfion risk (parfial cover)
 Map of topsoil compacfion risk (parfial cover)
 Map of soil erosion risk (parfial cover)
 Map of runoff risk (parfial 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 & Kinross Council
 PKC mapped local community growing inifiafives
 Wetlands | Scotland's environment web
 Natural Flood Management maps
 Land Capability for Forestry

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Summary of Evidence:
Soil and habitat types/characteristics
The information contained in the soil and habitat type/characteristics
maps provide a useful baseline to understand the ‘Principal physical and
environmental characteristics of the district in relation to soils’ as required
by the Act.
The southern section of the PKC area is dominated by brown soils with
alluvial soils, mineral gleys and mineral podzols generally close to existing
water bodies. The Ochil hills are dominated by peaty podzols and peat. The
northern section of the PKC area is dominated by mineral podzols
particularly along the Straths, with the upland areas dominated by a
mixture of peaty podzols, peat, mineral gleys and peaty gleys.
A summary of the Habitat type/characteristics is included in the SEA.
Carbon Rich Soils, Peatland and Priority Peatland Habitat
Carbon and Peatland Map
The Carbon and Peatland Map (2016) – prepared by Scottish Natural
Heritage (now NatureScot) – is a map that shows the distribution of carbon
and peatland classes across the whole of Scotland, giving a value to
indicate the likely presence of carbon rich soils, deep peat and priority
peatland habitat for each individually mapped area. Class 1 and 2 soils are
identified as the nationally-important resource and are solely, or are
dominated by, land with peat soil and peatland priority habitats. Class 5 is
peat soil > 50cm but currently without peatland habitats whilst Class 3 is
peaty soil with some/mostly peat forming vegetation. NPF4 Policy 5 has
policy/spatial implications in relation to carbon rich soils, peatland and
priority peatland habitat. Figure 1 (at the end of this document) shows the
extent of Class 1, 2, 3, 5 soils across the PKC area.
Across the PKC area, only a small number of settlements are located
adjacent or in close proximity to Class 1, 2, 3, and 5 soils. Rannoch Station
has an area of Class 2 soils in the surrounding area of land. The settlement
of Crook of Devon, in Kinross-shire, has a small area of Class 1 soils to the
south of the village. There are no settlements located adjacent, or in close
proximity, to Class 3 soils. There are 5 settlements that are located
adjacent, or in close proximity, to Class 5 soils: Crook of Devon,
Greenacres, Powmill, Rannoch Station, and Scotlandwell. In particular,
Crook of Devon, Greenacres and Scotlandwell intersect with areas of Class
5 soils.
Outwith settlements, Class 1, 2, 3, and 5 soils are generally located in
upland locations particularly to the north and north-west of the PKC area. 
Carbon Sequestration Study
On behalf of PKC, James Hutton Institute (JHI) prepared a study in to
Carbon Sequestration across the PKC area. The study considered a range of
relevant areas of research, including:
 Esfimates of Soil Carbon Stocks in PKC area
 Carbon Stocks and emissions from Peatland
 Recommendafions across a range of land-based inifiafives to
support carbon sequestrafion 
The study provides a research resource to support PKC’s wider net zero
initiatives. 
Peatland Action Sites
The Peatland Action (peat depth) map provides peat depth point data for
sites surveyed as part of the Peatland Action Project between 2013-2022.
The project has included peat depth data across various upland sites

Page 107

identifying depths of between 0-10+ metres, as well as the lack of peat
present.
Land Capability for Agriculture
The Land capability for agriculture map (partial cover, 1:50K scale) shows
the distribution of the different land classes across virtually all of
Scotland’s cultivated agricultural land and adjacent uplands.
Land in classes 1, 2 and 3.1 is often referred to as prime agricultural land
and is capable of being used to produce a wide range of crops.
There is no land within the PKC area that is identified as Class 1 prime
agricultural land. Typically, areas of land identified as Class 2 or 3.1 are
found within lowland areas where environmental, topographic and soil
conditions are more favourable for growing arable crops. In the PKC area,
prime agricultural land is predominantly found within the Strathearn,
Strathtay, Strathmore, Almond & Earn, Carse and Kinross-shire areas.
There is some limited prime agricultural land located in and around the
lowland areas of river valleys associated with the Tay and Tummel rivers,
however typically prime agricultural land isn’t found in upland areas. Many
of the settlements across Perth and Kinross are adjacent and/or in close
proximity to prime agricultural land. Figure 2 (at the end of this document)
shows where settlements are adjacent and/or in close proximity to prime
agricultural land. Table 1 lists those settlements affected.
Risks to Soil – Compaction, Sealing, Erosion and Runoff
Various risk maps have been prepared to show areas of soil at potential
risk including from: topsoil and subsoil compaction; sealing; erosion; and
run-off. 
Land of Lesser Quality that is Culturally or Locally Important for Primary
Use
There is no nationally consistent methodology for identifying land of lesser
quality that is culturally or locally important for primary use. The
classification of this land was considered as part of the Topic Paper (006)
for soils and PKC welcomed input from stakeholders on this matter. A
range of datasets were included for consideration. Through the topic paper
consultation one response was received from HES noting that they
welcomed the use of HES Canmore data to support consideration of
development proposals. As noted in our response to HES comments on this
issue this is considered further in Appendix A, issue A5 Historic Assets and
Places. 
PKC has not identified land under this classification. Following stakeholder
engagement through the topic paper consultation it is not intended to
proceed with designating land under this classification.

Page 108

Summary of Implicafions for the Proposed Plan:
Soil and habitat type/characteristics
The information contained in national maps on soil and habitat
type/characteristics provides a useful baseline of the ‘soil’ environment
and can support both the development of the Spatial Strategy in terms of
soil and related land use/habitat type as well as the assessment of
development proposals against relevant policies including NPF4 Policy 5,
where relevant. This information can provide a baseline from which sites
can be considered in relation to soil/habitat type(s).
Carbon Rich Soils, Peatland and Priority Peatland Habitat
The Spatial Strategy – and selection/assessment of sites – for the next LDP
will be informed by existing data on carbon rich soils, peatland, and priority
peatland habitat (Class 1,2,3,5 soils). NPF4 Policy 5 specifies that LDPs
“should protect locally, regionally, nationally, and internationally valued
soils”. The Spatial Strategy of the next Plan will be required to 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. For any
proposals for settlement expansion there are a number of limited cases
where the carbon and peatland map is of direct relevance however for
proposals in more upland areas e.g. renewable energy developments,
pressures on carbon rich soils, peatland and priority peatland habitat will
likely be higher. Any Spatial Strategy proposals involving these soil/habitat
types will need to take into account the requirements of NPF4 Policy 5a, c
& d.
Further information – available through the JHI Carbon Sequestration
Study (2021) and Peatland Action Site data (2013-2022) – will also
potentially help to inform the decision-making process for relevant
proposals, where gathered site survey information is available.
Land Capability for Agriculture
The land capability for agriculture dataset will inform the next Plan’s
Spatial Strategy and assessment/selection of sites. NPF4 Policy 5a & b
specifically addresses development proposals in relation to prime
agricultural land. 
As demonstrated in Figures 3 and table 1 (included at the end of this
document) a large number of settlements within the Council area are
adjacent and/or in close proximity to prime agricultural land. A number of
respondents to our Topic Paper consultation highlighted the existence of
prime agricultural land in relation to existing settlements and potential
areas for growth, particularly in and around the key strategic settlement of
Perth. It is recognised that the Spatial Strategy for the next Plan will need
to carefully consider the implications on prime agricultural land arising
from identifying sites to meet the required Housing Land Requirement,
alongside a range of other land use considerations. The Spatial Strategy
will avoid/minimise any loss of prime agricultural land in accordance with
NPF4 Policy 5 and the associated mitigation hierarchy. Prime agricultural
land will form part of the SEA site assessment process to assist with the
assessment of sites at the Plan Preparation stage.
Risks to Soils – Compaction, Sealing, Erosion and Runoff
NPF4 Policy 5 seeks to ensure development proposals protect soil from
damage including from sealing, erosion, and/or compaction. These issues

Page 109

may influence site specific developer requirements/considerations
including for development allocations as well as the assessment of
development proposals against NPF4 Policy 5. The datasets will support
the consideration of development proposals both in preparing the
Proposed Plan as well as through the development management process.
Land of Lesser Quality that is Culturally or Locally Important for Primary
use
As noted above it is not intended to proceed with designating land under
this classification.
Gaps, Uncertainties or Key Issues Raised:
Key issues in relation to carbon rich soils and prime agricultural land are
underpinned and guided by existing, national datasets, as noted above.
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 responses (see table below) have identified that site information
can supplement the consideration of soils including carbon rich soils and
prime agricultural land.
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.
Summary of Stakeholder Engagement:
The following relevant stakeholders were engaged during our topic paper
consultation to help inform the preparation of our Evidence Report:
 Key Agencies: SEPA, NatureScot, HES 
 Neighbouring planning authorifies: Aberdeenshire, Angus, Dundee,
Highland, Sfirling, Fife, Clackmannanshire, Argyll & Bute,
Cairngorms NPA, Loch Lomond and Trossachs NPA
 Other organisafions: James Hufton Insfitute, Perthshire Nature
Connecfions Partnership, NFU Scotland, Peatland Acfion, Forestry
Commission Scotland, Scoftish Forestry, Scoftish Environment Link,
Scoftish Government Planning
The table below outlines where we have received responses from
stakeholders during our topic paper consultation.

Page 110

Statements of Agreement/ Dispute  
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Errol Community
Council
Neither  List of Evidence/Datasets and Summary of Implications
for Proposed Plan (PP): The Community Council
indicated that they neither agreed nor disagreed with
the sufficiency of the list of evidence/datasets identified
in Topic Paper 006: Soils, or the summary of implications
of that evidence for the preparation of the Proposed
Plan.   
Further Comments: No further comments to make.
Formal Dispute: Errol Community Council do not wish
for their response to be treated as a formal dispute.
No further action required.
NatureScot Neither List of Evidence/Datasets and Summary of Implications
for Proposed Plan (PP): NatureScot indicated that it was
good that recommended data sources from the draft
stage have been incorporated, and the maps are clear
and a useful addition.  
Further Comments: No further comments to make.
Formal Dispute: NatureScot do not wish for their
response to be treated as a formal dispute.
Comments noted. No further action
required.
Historic
Environment
Scotland (HES)
Agree List of Evidence/Datasets and Summary of Implications
for Proposed Plan (PP): HES agreed with the list of
evidence/datasets and summary of implications for the
Proposed Plan.
Further Comments: The recognition of the key role that
the management and protection of soils and peatlands
plays in preserving cultural and archaeological heritage is
welcomed. While the identification of some sites within
HES Canmore that are classified as “agricultural
cropmark” with cultural interest is noted a wider
consideration of this would be appropriate when
considering development proposals.
Comments noted. Consideration of sites
within HES Canmore will be of primary
relevance under the ‘Historic Assets’
section. No further action required.

Page 111

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Formal Dispute: HES do not wish for their response to be
treated as a formal dispute.
Homes for
Scotland
Neither List of Evidence/Datasets and Summary of Implications
for Proposed Plan (PP): Homes for Scotland agreed with
the list of evidence/datasets however disagreed with the
summary of implications for the Proposed Plan.   
Further Comments: 
HfS note the presence of peaty soils/peatland is an
important planning consideration included as part of
NPF4 Policy 5, discussing how the plan will seek to
protect and avoid allocations or extensions to
settlements that would impact peat and high organic
matter rich soils. HfS highlight it is important to note any
policy included in the plan needs to recognise there are
tools which can be utilised to minimise the impact of
development on peat and high organic matter rich soils
e.g. Construction Environmental Management Plan. It is
acknowledged that this is included in the Topic Paper
and can be used by local planning authorities when
allocating/consenting development providing a degree of
control including using enforcement powers if required. 
HfS highlight that the Topic Paper does not include the
scenarios under NPF4 Policy 5b in which development
proposals on prime agricultural land, or land of lesser
quality that is culturally or locally important for primary
use will be supported. This includes for “essential
infrastructure and there is a specific locational need and
no other suitable site”. HfS highlight the socio-economic
benefits that home building provides including the
number of jobs supported. 
In response to point 1 about peaty
soils/peatland these are identified in NPF4
and LDP Guidance and therefore will be
afforded protection through the Plan
preparation process. Only a limited
number of exceptions are allowed under
NPF4 Policy 5c for the development of
peatland, carbon rich soils and priority
peatland habitat, with NPF4 Policy 5a
noting that the mitigation hierarchy is to
be used when considering proposals on
undeveloped land. The overall policy intent
of NPF4 under soils is to “protect carbon-
rich soils, restore peatlands and minimise
disturbance to soils from development.”
In response to points 2 and 4 regarding
house building and prime agricultural land
it is noted that a balance will need to be
struck between these often-conflicting
interests for land use. Specifically in
relation to NPF4 Policy 5b, it is important
to note that NPF4 includes a glossary
(p.148) which identifies those
developments considered as “essential
infrastructure”. Whilst meeting the
housing needs of the area is a key
component of the next Plan, house
building is not included under this
definition in terms of NPF4 Policy 5b which
is used for assessing development

Page 112

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
HfS highlight that a range of datasets/information
sources have been considered for this new classification
of ‘lesser’ land for the next LDP, however, there is
currently no land identified specifically for this primary
purpose. HfS welcome that the Topic Paper plans to
engage with stakeholders and their views will help to
inform how this issue will be considered for the Evidence
Report, and potentially for the preparation of the
Proposed Plan. 
HfS highlight that in order to meet the default Minimum
All-Tenure Housing Land Requirement (MATHLR) Topic
Paper 019: Local Living and 20 minute neighbourhoods
recognises that due to the extremely limited brownfield
opportunities that exist across Perth and Kinross the
sustainable growth of the area will rely on greenfield
land release also. HfS highlight that the Council cannot
on one hand advocate greenfield development but then
use soils as a barrier, preventing development. HfS
highlight that tools such as a CEMP can help to minimise
the impact of development given the recognition in
Topic 019 that greenfield land, and therefore
disturbance to soil, is required.
Formal Dispute: Homes for Scotland do not wish for
their response to be treated as a formal dispute.
proposals through the Development
Management process. In developing the
Spatial Strategy the Council will need to
balance the interests of identifying suitable
housing land alongside the need to protect
prime agricultural land, including using
mitigation measures – guided by the SEA
process – where sites on undeveloped land
are proposed.
In response to point 3 this is noted and
welcomed. Further consideration of the
“lesser land” classification is provided in
this issue. As previously noted, PKC is not
intending to designate land to address this
new policy criterion.
Montagu Evans
o/b/o Loch
Developments Ltd
Neither List of Evidence/Datasets and Summary of Implications
for Proposed Plan (PP): The respondent indicated that
they neither agreed nor disagreed with the sufficiency of
the list of evidence/datasets identified in Topic Paper
006: Soils, and our summary of implications of that
evidence for the preparation of the Proposed Plan.   
Further Comments: No further comments to make.
No further action required.

Page 113

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Formal Dispute: The respondent does not wish for their
response to be treated as a formal dispute.
Scottish Water Agree List of Evidence/Datasets and Summary of Implications
for Proposed Plan (PP): Scottish Water agreed with the
list of evidence/datasets and summary of implications
for the Proposed Plan.
Further Comments: Efforts to protect carbon-rich soils,
restore peatlands and minimise disturbance to soils from
development is strongly supported by Scottish Water.
Managing restoration of peatlands carefully is vital as
damaged, poor condition or eroded peatland can have a
significant impact on drinking water quality supplies of
upland sources from increases in dissolved organic
carbon (DOC) and Scottish Water welcome early
engagement to determine if development proposals
impact on drinking water catchments. Scottish Water’s
abstraction areas are designated as Drinking Water
Protected Areas (DWPA) under Article 7 of the Water
Framework Directive. 
Formal Dispute: Scottish Water does not wish for their
response to be treated as a formal dispute.
Comments noted. No further action
required.
Gray Planning &
Development
o/b/o GS Brown
Construction Ltd
Agree List of Evidence/Datasets and Summary of Implications
for Proposed Plan (PP): The respondent indicated that
they agreed with the sufficiency of the list of
evidence/datasets identified in Topic Paper 006: Soils,
and neither agreed or disagreed with the summary of
implications of that evidence for the preparation of the
Proposed Plan.   
Further Comments: The respondent notes that the
evidence on prime agricultural land (land capability
maps) highlights that obvious locations for future
development including for housing will be in direct
The Spatial Strategy will be guided by NPF4
and the LDP Guidance. It is acknowledged
that there is a significant amount of land
around existing settlements – where future
growth is most likely to be located – that is
prime agricultural land. The Spatial
Strategy will need to balance a wide range
of considerations when considering the
allocation of sites for new development
including the potential loss of prime
agricultural land. In response to the query

Page 114

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
conflict with aims of NPF4 Policy 5 and that the next LDP
(including the Spatial Strategy) will be informed by
existing data for prime agricultural land. A query is posed
in relation for there being PKC-level mapping being
available given limitations of existing national-level data.
Formal Dispute: The respondent does not wish for their
response to be treated as a formal dispute.
on PKC-level mapping, this currently does
not exist and site-specific circumstances
will be guided by site surveys undertaken
by landowners/applicants in support of
their site submissions, where relevant. It
would not be appropriate nor would there
be resources to undertake a PKC-wide
assessment of prime agricultural land.
Earn Community
Council
Agree List of Evidence/Datasets and Summary of Implications
for Proposed Plan (PP): Earn Community Council agreed
with the list of evidence/datasets and summary of
implications for the Proposed Plan.
Further Comments: Earn Community Council noted the
following comments:
 Allocafion of development land should be
dependent upon soil type and its benefit to
carbon sequestrafion, flood plain management
and alleviafion.
 There was a big emphasis on peat land but this is
a very small % of P & K area. 
 Land of “Cultural or Locally Important” is
menfioned but no definifion, agriculture seems to
come under this. Stakeholder engagement is
menfioned.
 Soils are important to many other of the topics.
E.g.  007, 021, and 028.
Formal Dispute: Earn Community Council does not wish
for their response to be treated as a formal dispute.
Comments noted. 
In terms of the development of land being
dependent upon soil type, NPF4 provides
guidance on those soil assets which should
influence the development process
including carbon rich soils, peatland, and
priority peatland habitat, and prime
agricultural land.
NPF4 Policy 5 and LDP Guidance recognise
the importance of carbon rich soils and
peatland to help sequester carbon and
other benefits such as upland water
management.
As noted in this Issue PKC is not intending
to designate land under the “lesser
quality” classification.
Connections with other topics are noted in
this Issue.
Savills on behalf of
Scone Estate
Dispute List of Evidence/Datasets and Summary of Implications
for Proposed Plan (PP): The respondent disputed the list
The Spatial Strategy will be guided by NPF4
and the LDP Guidance. It is acknowledged
that there is a significant amount of land

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
of evidence/datasets and summary of implications for
the Proposed Plan.
Further Comments: The response highlights limitations
of the existing national-scale land capability dataset and
cannot be relied upon at local level without detailed
understanding of specific sites. Concerns also raised
around having an embargo on development on this land
classification when Perth and most of the main
settlements are surrounded by prime land, particularly in
the context of limited opportunities for brownfield land
development.
The response also highlights concerns around
designating ‘culturally or locally important’ particularly
with no robust methodology in place.
Formal Dispute: The respondent wishes to formally
dispute the evidence, with the following summary: 
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.
around existing settlements – where future
growth is most likely to be located – that is
prime agricultural land. The Spatial
Strategy will need to balance a wide range
of considerations when considering the
allocation of sites for new development
including the potential loss of prime
agricultural land.
In terms of the national dataset for
identifying prime agricultural land this will
form a core part of the evidence used to
help guide the Spatial Strategy and
development allocations, as set out in
NPF4. It is acknowledged that this is a high
level dataset and can be supplemented
with site survey information to confirm the
status of prime agricultural land or
otherwise. Whilst it would not be
appropriate nor would there be resources
to undertake a PKC-wide assessment of
prime agricultural land, site submissions
during the ‘call for sites’ stage can be
accompanied by site surveys that provides
information on soil conditions and/or how
land is/can be used.
In terms of the lesser land classification, as
noted above PKC is not intending to
designate land to address this new policy
criterion.
Savills on behalf of
Dupplin Estate
Neither List of Evidence/Datasets and Summary of Implications
for Proposed Plan (PP): The respondent neither agreed
See above PKC response which addresses
points 1-3.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
or disagreed with the list of evidence/datasets and
summary of implications for the Proposed Plan.
Further Comments: The response highlights limitations
of the existing national-scale land capability dataset and
cannot be relied upon at local level without detailed
understanding of specific sites. Concerns also raised
around having an embargo on development on this land
classification when Perth and most of the main
settlements are surrounded by prime land, particularly in
the context of limited opportunities for brownfield land
development.
The response also highlights concerns around
designating ‘culturally or locally important’ particularly
with no robust methodology in place.
The response also highlights that greater focus should be
on increased density as the most efficient and
sustainable use of space and a driver for economic
revival of urban centres across PKC.
Formal Dispute: The respondent does not wish for their
response to be treated as a formal dispute.
In terms of point 4 around higher density
development this is generally supported.
Matters around development density will
be considered further in the development
of the Spatial Strategy including an
assessment of the appropriate
development density for allocated sites in
context of the need to maximise the use of
developable land, surrounding amenity,
and its landscape/streetscape context.

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Figure 1: Carbon Rich Soils/Peatland/Priority Peatland Habitat (Class 1, 2, 3 and 5 soils) across PKC area - Overview1 
1 James Hutton Institute1:25,000 and 1:250,000 scale soil data and Land Cover Scotland 1988. Used with the permission of The James Hutton Institute. All rights reserved.

Page 118

Figure 2: Prime Agricultural Land (Class 2 and 3.1 soils) across PKC area – Ove
rview2 
2 Soil Survey of Scotland Staff (1984-87). Land Capability for Agriculture maps of Scotland at a scale of 1:50 000. Macaulay Institute for Soil Research, Aberdeen. DOI: 10.5281/zenodo.6322760'

Page 119

Figure 3: Prime Agricultural Land (Class 2 and 3.1 soils) across PKC area – Detailed Area Maps3 
3 Soil Survey of Scotland Staff (1984-87). Land Capability for Agriculture maps of Scotland at a scale of 1:50 000. Macaulay Institute for Soil Research, Aberdeen. DOI: 10.5281/zenodo.6322760'

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Table 1: Settlements adjacent and/or in close proximity to prime agricultural land (Class 2 and 3.1 land)
Aberargie Dunning Muthill
Abernethy Errol New Alyth
Aberuthven Errol Airfield/Grange Oudenarde
Alyth Forgandenny Perth
Ardler Forteviot Perth Airport
Auchterarder Fowlis Wester Pitlochry
Balado Glenlomond Powmill
Balbeggie Greenacres Rait
Baledgarno Guildtown Scone
Ballinluig gWest Scotlandwell
Balnaguard Hattonburn Spittalfield
Bankfoot Inchture St David’s
Birnam Invergowrie St Madoes/Glencarse
Blackford Kettins Stanley
Blairgowrie/Rattray Kinfauns Tibbermore
Bridge of Earn Kinnaird Wester Balgeddie
Burrelton/Woodside Kinnesswood Wolfhill
Caputh Kinross/Milnathort 
Carsie Kinrossie 
Clathymore Logierait 
Cleish Longforgan 
Cottown/Chapelhill Luncarty 
Coupar Angus Maryburgh 
Crieff Meigle 
Croftinloan/Donavourd/East Haugh/Ballyoukan Meikleour 
Drunzie Methven 
Dunkeld Murthly/Gellyburn

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1 
Issue: Forestry, Woodland, and Trees
Corresponding NPF4 Policy/Policies:
• National Planning Framework 4, Policy 6: Forestry, woodland and
trees
• Other key NPF4 policy connections - 1: Tackling the climate and
nature crises; 2: Climate mitigation and enhancement; 3: Biodiversity;
4: Natural places; 5: Soils; 7: Historic assets and places; 8: Green
belts; 11: Energy; 14: Design, quality and place; 15: Local living and
20 minute neighbourhoods; 19: Heat and cooling; 20: Blue and green
infrastructure; 21: Play, recreation and sport; 22: Flood risk and water
management; 23: Health and safety, and 30: Tourism.
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 007: Forestry, Woodland, and Trees
(https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume
nts/TP007_Forestry_Woodlands_and_Trees_2.pdf) 
Information required by the Act and NPF4 regarding the topic:
Section 15(5) of The Town and Country Planning (Scotland) Act 1997, as
amended: 
• The principal physical and environmental characteristics of the
district.
Of relevance to this issue, Section A159 of the 1997 Act, as amended by
the 2019 Planning (Scotland) Act requires planning authorities to prepare a
forestry and woodland strategy which:
• Identifies woodlands of high nature conservation value within the
planning authority’s area.
• Sets out the planning authority’s proposals as to the development of
forestry and woodlands; the protection and enhancement of
woodlands, in particular those of high nature conservation value; the
resilience of woodlands of high nature conservation value; the
expansion of woodlands of a range of types to provide multiple
benefits to the physical, cultural, economic, social, and environmental
characteristics of the area, and any other matter which the planning
authority consider appropriate. 
Under Policy 6, NPF4 expects Local Development Plans to:
• Identify and protect existing woodland and the potential for its
enhancement or expansion to avoid habitat fragmentation and
improve ecological connectivity, helping to support and expand nature
networks, and
• LDP spatial strategies should identify and set out proposals for
forestry, woodlands, and trees in the area, including their
development, protection and enhancement, resilience to climate
change, and the expansion of a range of types to provide multiple
benefits.  This is to be supported and informed by an up-to-date
Forestry and Woodland Strategy.

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2 
The Policy Intent of NPF4 Policy 6 is noted as:
• To protect and expand forests, woodland and trees.
The Policy Outcomes are:
• Existing woodlands and trees are protected, and cover is expanded.
• Woodland and trees on development sites are sustainably managed.
The Scottish Government’s Local Development Plan Guidance (May 2023)
under it’s ‘Step by step guide’ provides advice on relevant evidence for the
NPF4 policy topics to help planning authorities in considering the national
planning policies when preparing their Evidence Report.  With respect to
NPF4 Policy 6, the Guidance advises that planning authorities should:
• Take account of existing woodland in the plan area.
• Be informed by an up-to-date forestry and woodland strategy.
Other relevant information suggested for consideration include -
inventories such as the Native Woodland Survey of Scotland, and the
Ancient Woodland Inventory, alongside records such as Tree Preservation
Orders, to help identify trees and woodlands of high nature conservation
value in the plan area.
Note: The evidence collated and evaluated as part of our LDP3 Topic Paper
007: Forestry, Woodland, and Trees and summarised in this Evidence
Report will help feed into the review of our existing Forest and Woodland
Strategy, which was adopted in 2020, and will be incorporated into our
LDP3 Spatial Strategy.  
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 
• PKC Interactive Heritage Map
• Historic Environment Scotland’s Portal
• Scottish Forestry Map Viewer, Scottish Forestry

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• Public Registers, Scottish Forestry
• National scale Land Capability for Forestry Map
• Nature Scot, Carbon and Peatland Map (2016)
• PKC 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 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:
Perth and Kinross Council Corporate Plan 2022-2027 
Our Local Development Plan 3 (LDP3) will be prepared within the context
of the Council’s Corporate Plan, which sets out the Council’s vision for a
Perth and Kinross ‘where everyone can live life well, free from poverty and
inequality.’  It proposes a number of key priorities for the 5-year period
2022 to 2027.  It also reflects the principles of the Perth and Kinross Offer.   
The Corporate Plan identifies 7 priority areas which the Council feels it can
directly influence and have the most impact upon, and those which are
most important to delivering the Vision for Perth and Kinross.  These
priorities are:
1) Working in partnership with communities
2) Tackling poverty
3) Tackling climate change and supporting sustainable places
4) Developing a resilient, stronger, and greener local economy
5) Enabling our children and young people to achieve their full potential
6) Protecting and caring for our most vulnerable people
7) Supporting and promoting physical and mental wellbeing
Delivery of the Corporate Plan’s Priorities will be underpinned by a set of
Key Principles and delivered through a range of Key Actions.  
National Policy Context
The UK Forestry Standard (UKFS)
The fifth edition of the UK Forestry Standard (UKFS) was published in
October 2023 and is the reference standard for sustainable forest

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4 
management in the UK and applies to all UK forests.  The document sets
out the context for forestry, the approach of the UK governments to
sustainable forest management, outlines standards and requirements, and
provides a basis for regulation and monitoring.  
Previous editions of the UKFS were supported by a series of guidelines, but
since the 2017 edition, these guidelines have been incorporated into the
publication and consider separately the key elements of sustainable forest
management, which are forests and: biodiversity; climate change; the
historic environment; landscape; people; soil, and water.  A summary of
the key issues and opportunities for each of these elements are provided
below.
Forests and Biodiversity
• The conservation of biodiversity is regarded as an essential part of
sustainable forest management.  
• Forests cover a large proportion of the world’s total land area and are
vital to ensuring environmental functions like climate regulation, soil
conservation and biodiversity.
• Forests provide habitats for a large range of plants and animals.
• Through providing these important ecosystem services, forests and
woodlands also contribute to the sustainability of the wider landscape.
• Due to the progressive loss and fragmentation of the natural forests of
the British Isles, our forest resource is a much smaller proportion that
many other European countries, with significant consequential effects
on native biodiversity.
• Pressures on our forest and woodland resource over last century
include: large-scale planting of non-native trees with a focus on timber
production; agricultural intensification accelerating the loss of
woodland biodiversity through the loss of woods and hedgerows and
the fragmentation of woodland habitat; increased grazing pressures,
particularly in the uplands; decline in traditional woodland
management e.g., coppicing, reducing the amount of open woodland
and alongside it associated insect populations, like butterflies. 
• Whilst forest policies since the 1970s have given greater emphasis to
environmental benefits (diverse structure of forests with more native
tree species planted), and a focus on managing and restoring ancient
woodland, creating new native woodland, and improving habitat
conditions for priority woodland species, species and habitats are still
at risk from inappropriate management, the long-term effects of
habitat fragmentation and degradation, and possible adverse impacts
due to climate change, pests and diseases. 
• The conservation, enhancement and restoration of semi-natural
habitats and priority species is a clear aim in the UKFS and Scotland’s
National Forestry Strategy.  
• The UKFS identifies the key factors important for forests and
biodiversity as being: Priority Habitats and Priority Species; Native
Woodlands; Ecological Connectivity; Ecological Processes; Tree and
Shrub Species Selection; Forest and Stand Structure; Veteran Trees and
Deadwood; Open, Scrub and Edge Habitats; Riparian Zones; Habitat
Creation and Restoration (restoring degraded habitats and targeting
new habitat creation); Invasive Species (effective control), and effective
management of the Grazing and Browsing of domestic livestock and
other herbivores.  
Forests and Climate Change
• In the UK, the increased frequency and severity of summer drought is
likely to represent the greatest threat to woodlands from climate
change.
• Despite uncertainty associated with climate change projections, the
UKFS Guidelines on Forests and Climate Change is focused on actions
forest managers can take to protect forests and woodlands in the UK,
to ensure they can adapt to new threats and opportunities brought

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through climate change, whilst still maintaining and expanding a
sustainable forest and woodland resource.
• Forests and Carbon – forests play an important role in the global
carbon cycle.  If managed in a sustainable manner, forests can perform
a vital role as carbon stocks and sinks.  
• Forest soils are particularly important – often storing a greater
proportion of carbon dioxide than the tree biomass, especially on
peat-based soils.
• Forests contribute to climate change mitigation as a source of
renewable energy and sustainable wood products.
• UK forestry needs to respond to climate change via mitigation and
adaptation.   
• Climate change mitigation in the context of forestry means establishing
new woodlands and the sustainable management of existing
woodlands and wood products to enhance their potential as a sink for
greenhouse gases (GHGs).   Sustainable forest management
approaches include – the transfer of carbon stored in the forest to
wood products; minimising of short-term loss of carbon from soils
through some forest operations; use of wood as a sustainable building
material and extending the carbon storage of wood through its
recycling for other uses, and woodfuel as a substitute to the use of
fossil fuels.
• Climate change adaptation in the context of forestry means reducing
the vulnerability of forests, as well as using forests to reduce the
vulnerability of society to climate change.  Climate projections suggest
that although there will be little change to total annual rainfall,
summer rainfall will decrease while winter rainfall will increase, likely
resulting in more frequent and severe summer droughts, and a larger
proportion of rainfall likely to occur during extreme events in summer
and winter, extending the duration of winter waterlogging and
increasing the severity of summer flooding.  This will also increase soil
erosions and the frequency of landslips.
• An increased concentration of carbon dioxide in the atmosphere
stimulates photosynthesis and is likely to lead to an increase in growth
rates and leaf area.  
• Other likely indirect impacts include changes to the frequency and
severity of pest and disease outbreaks, increasing mammal
populations which may cause damage, and the impact of existing and
new invasive species.
• Planning for uncertainty in developing approaches is the key
consideration, as although it is still uncertain how trees will respond to
the likely changes in the climate, and how woodland ecosystems, as a
whole, will be affected, the level of change already experienced in the
global climate requires adaptation responses.  
• A reassessment of the suitability of species for use in commercial
forestry is needed in response to the threats posed to forests and
woodlands through increased frequency and severity of summer
drought. 
• Considering the long timescales for forestry, anticipatory adaptation
offers the highest potential gains for ensuring forests, and the benefits
they provide, are maintained in the future.  Anticipatory (or Proactive)
Adaptation is adaptation which takes place before the impacts of
climate change are observed.
• Resilience to climate change is likely to be a key attribute for most
types of forests and woodlands, but in developing resilience a balance
needs to be found to ensure (as far as possible) the integrity of existing
ecosystems is maintained.  Making appropriate choices in terms of
species and origin, diversity in species and structure, and effective
stand management could all help to build resilience.
• Forests and woodlands can help people and society adapt to climate
change through providing a range of benefits, including - providing
habitats that also provide ecological connectivity; natural flood
management; diffuse pollution control; slope stability and control of
soil erosion; a renewable energy source; temperature control, and

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shade and shelter.  To a varying degree, woodlands will contribute
these benefits depending on their location, woodland type and soil
type.
• The UKFS identifies the key factors important for forests and climate
change as being: Mitigation – carbon in forest products, soils, and
forest ecosystems, and operation carbon footprint.  Adaptation –
forest planning; adaptive management; tree and shrub species
selection; ecological connectivity, and environmental protection.
Forests and Historic Environment
• Surviving elements of the historic environment include ancient
woodlands, veteran trees, earthworks, ruined structures, and buried
archaeological features, which together can provide a good source of
information about past societies and how they used and managed the
land, including forests and woodlands. 
• Important to note that many elements of the historic environment
may remain buried below ground, like archaeological features and
artefacts.  Woodland or vegetation cover may also hide other features.
• It is important that all significant heritage features, and not just
designated ones, are protected and that consideration is given to the
preservation and enhancement of cultural landscapes.  
• Good management of woodlands is needed to ensure these features
present within woodland are preserved and not damaged by forest
operations.
• UKFS requirements for forestry and the historic environment state
that: 
− Schedule Monuments must not be damaged, and consent must be
obtained from the relevant historic environment authority [HES]for
any works with the potential to damage a monument. 
− HES must be informed if any objects found that come within the
scope of the law covering archaeological finds.
− Listed Building Consent must be obtained from the local authority
to demolish a listed building or structure, or any part of it, or to
alter it in any way that would affect its character.
− Forests should be designed and managed to take account of the
historical character and cultural values of the landscape, and to take
account of policies associated with historic landscapes, battlefield
sites, historic parks and gardens, and designed landscapes of
historic interest.
− Steps should be taken to ensure that historic features, which may
be adversely affected by forestry, are known and evaluated on an
individual site basis, taking adverse from local historic environment
services.
− Forest management plans and operational plans should set out how
important historic environment features, including veteran trees,
are to be protected and managed, and where existing forests do not
meet the UKFS Requirements for Forests and Historic Environment,
improvements should be made when management opportunities
arise.
• The UKFS identifies the key factors important for forests and historic
environment as being:  Historic Context; Evidence of the Historic
Environment; Forest Planning; Woodland Heritage; Open Space
(appropriate setting for historic environment features); Forest
Operations; Site Hydrology, and Access and Interpretation.
Forests and Landscape
• Forests and woodlands are important visual elements in the landscape
that change over time, with great potential to enhance and enrich the
environment and make a significant contribution to landscape quality.
• Forests and woodlands provide a setting for recreational activities and
can help bring people closer to nature.

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• Due to agriculture and other land uses, the UK has lost a greater
proportion of its natural forest cover than most other European
countries.
• Climate change has focused attention on the special roles that trees
and woodlands can play in mitigation and adaptation.
• The development of forest design has been supported by research into
public preferences for woodlands and trees in the landscape – diversity
of structure and composition coming out as the most important
characteristics.
• Woodland and trees in urban areas can contribute towards urban
character, quality of life, the restoration of derelict land, landscape
restoration, reducing any unwelcome visual prominence in the wider
landscape, and the rehabilitation of urban communities.
• Woodlands and trees can form part of green infrastructure, bringing a
natural element into urban areas, providing places for recreation and
relaxation, and a setting for new housing and business and industry
developments.
• Access to forests and woodlands for recreation is an important public
benefit.
• UKFS requirements for forests and landscape state that: 
− Forests should be designed and managed to take account of the
landscape context, landscape designations, designed landscapes,
historic landscapes, and the various policies that apply. 
− The principles of forest design, informed by the landscape context,
should be applied to ensure landscape and visual aspects are
appropriately addressed, and where existing forests do not meet
the UKFS Requirements for Forests and Landscape, improvements
should be made when management opportunities arise.
• The UKFS identifies the key factors important for forests and landscape
as being:  Landscape Context - landscape character, landscape and
visual sensitivities, historic context, and designed landscapes.  Forest
Design Principles – shape, landform, pattern of enclosure, scale,
diversity, unity, and spirit of place. 
Forests and People
• Forests and woodlands provide a wide range and diverse benefits to
people, such as, supporting livelihoods and employment,
environmental and social goods and services via sustainable forest
management, providing wildlife habitats, climate change mitigation,
and opportunities for access and recreation.  
• The social benefits of forests and woodlands are considered
particularly valuable in the UK due to its high population density, and
the demand for outdoor recreation.  The main social themes have
been around: maintaining and increasing access and provision for
recreation; maintaining livelihoods based on the production of forest
products and services and encouraging public participation in forest
decision-making processes.
• In more recent times, there has been a lot of interest in, and progress
made, on understanding the wider social benefits that well managed
forests and woodlands can provide; such as: rural development
opportunities; improved health and wellbeing; enhanced social
integration and community development; opportunities for the
development of education and skills, and improved quality of life,
particularly in urban areas through providing access to greenspace.
• Increasing recognition that the benefits of forests and woodlands can
be delivered through community involvement in management, and in
some cases, community ownership.
• Rural diversification in the forestry sector can help support rural
economies, including expanding the service economy (particularly
enterprises linked to recreation and tourism).
• Forests contribute to a local sense of place and can form part of the
wider physical and cultural landscape.
• Some of the UKFS requirements for forests and people state that:

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− Rights of way must be respected and not obstructed.
− In Scotland, provisions under the Land Reform (Scotland) Act must
be complied with, including access rights to woodland (people must
not be obstructed from using their access rights responsibly).
− Landowners and managers should consider providing access to their
woodland, in addition to that required by statute. 
− Where uses of woodland are established by long tradition they
should be respected and allowed to continue, providing the use is
sustainable and not detrimental to management objectives.
− Where public access for recreation and other responsible uses is
well established and recognised as a public benefit, or a potential
benefit, consideration should be given to the design and provision
of appropriate facilities.
− Reasonable steps should be taken to discourage anti-social
behaviour, and where such behaviour continues, the local authority
or policy should be informed, and advice sought. 
− The Equality Act must be complied with in the provision of facilities,
goods and services.
− Consideration should be given to involving people in the
development of forestry proposals who have a recognisable interest
in the proposal or its outcomes.
− Consideration should be given to promoting and facilitating local
forest and woodland-based enterprises and economic activities.
• The UKFS identifies the key factors important for forests and people as
being:  Public Involvement; Accessibility; Visitor Information;
Recreation; Traditional and Cultural Uses; Education and Learning;
Volunteering; Vandalism and Anti-Social Behaviour, and Enterprise
Development. 
Forests and Soil
• Soil is a fundamental part of the forest ecosystem. The characteristics
of soil are important in determining the nature of the flora and fauna
that sustain biodiversity, and its productive potential.
• Soil is a valuable habitat and forms a living system that includes
organisms belonging to many plant, animal and microbial species.
• Soil must be used in a sustainable way to ensure it can continue to
perform a number of functions.
• The actions and complex interactions of soil biology help maintain
nutrient, energy and water flows, supporting the forest ecosystem.
• Soils also provide an important filtering and buffering function that
protects other parts of the ecosystem from pollution and damage, and
they can be a major source (sink) of CO2 and other GHGs.
• The physical, chemical and biological properties of soils are continually
altered by several natural processes, including leaching, waterlogging,
and the addition and decomposition of organic matter.  
• Some of the least disturbed soils in the UK are found in ancient
woodlands, as they’ve remained untouched by agriculture for
hundreds of years.
• For the purpose of the UKFS ‘forest soils’ are defined as those soils
which support forests and woodlands, including post-industrial, or
brownfield, soils that are being restored. 
• Climate change has the potential to affect forest soil function both
directly and indirectly – rising temperatures can speed up
mineralisation rates and soil nutrient availability, and nutrient leaching
can be enhanced by higher winter rainfall.  Increasing soil moisture
deficits in summer could also decrease both nutrient uptake by trees
and leaching losses.  The risk of physical soil disturbance could
increase because of greater winter waterlogging and windthrow,
especially if the frequency of storm events increases.  All of these
effects have implications for the nutrient and carbon balance of forest
soils.

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• Some forest management activities, like planting, harvesting and
moving and stacking timber, can impact on forest soils.  
• Engineering works e.g. building roads and bridges, involve soil
movement and disturbance.  
• More subtle changes to forest soils can happen through species choice,
stocking density and brash management.
• Some forestry practices e.g, cultivation and drainage, can also result in
short term loss of soil carbon until this is replaced over the rotation as
forests grow. 
• Deep peat soils are particularly vulnerable to disturbance, and
woodland establishment can lead to a net loss of stored carbon.
• Brownfield soils are likely to be substantially modified by their previous
use.  Forests can help restore post-industrial areas and establish a
productive and environmentally beneficial resource.  However,
successful restoration can often require intensive management and the
importing of soil or soil-forming materials from elsewhere. 
• Forest soils and ecosystem services – forests soils provide a number of
ecosystem services including: a store of carbon; a growing medium for
trees; water management (most forest soils have a high infiltration
capacity which helps reduce rapid run-off, with potential local flood
management benefits and the control or abatement of diffuse
pollution); a historic archive (containing archaeological and palaeo-
environmental evidence of the past); revitalisation of derelict or
neglected land (role in economic regeneration, particularly in and
around towns), and habitat creation and restoration.
• Some of the UKFS requirements for forests and soil state that:
- The regulatory authority (SEPA) must be consulted prior to the
application of wastes to forest soils.
- Where a designated site or priority habitat or species might be
affected, appropriate regulators and conservation agencies must
be consulted before the aerial application of pesticides, and the
use of pesticides in or near water, and where appropriate,
authorisation obtained.
- The quality of forest soil should be protected and enhanced in
terms of its physical, chemical and biological properties.
- Forest soil fertility levels should be maintained to safeguard the
soil’s character and productive potential.
- Forest operations should be planned and managed to avoid
damage to soil structure and function; should damage occur,
reinstatement measures should be undertaken, and adverse effects
mitigated.
- The environment adjacent to forests should not be subject to
adverse effects due to water run-off, contamination or erosion
arising from forest management practices. 
• The UKFS identifies the key factors important for forests and soil as
being:  Acidification; Contamination; Compaction; Disturbance;
Erosion; Fertility, and Organic Matter. 
Forests and Water
• Forests and woodlands have a close relationship with our water
resources, and forest management and water quality are closely linked. 
• Sustainable forest management is essential to ensuring the supply of
good-quality fresh water, to providing protection against natural
hazards, like flooding or soil erosion, and to protect the needs of aquatic
species. 
• Land management activities can affect the flow of water and degrade
the quality and ecology of waters, which knock-on implications for the
economic, environmental and social benefits provided by water.  Some
activities can directly affect a waterbody itself, while other impacts
result from catchment land use, such as urban development.  Effects can
also arise from far beyond the boundaries of an individual catchment,
e.g. deposition of acid pollutants from the atmosphere and the effects
of GHGs and climate change.

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• The benefits of ‘protection forests’ and sustainable forest management
for water quality are increasingly recognised, and in many countries,
woodland is being created to safeguard the water environment. 
Although there may be some trade-offs in relation to the potential for
forests to reduce water yield, these are typically more than
compensated by water quality and the other ecosystem services
provided by forests.
• Forestry land use itself can have a range of detrimental effects on water,
within the forest and downstream.  Poorly designed or managed forests,
or forests that have been planted in unsuitable locations, can exacerbate
the effects of acid deposition, cause eutrophication, increase sediment
delivery, affect water colour, and contribute to local flooding.  These
effects can also degrade aquatic habitats and lead to loss of aquatic
wildlife, reducing ecological quality and damaging fish populations and
dependent fisheries.  
• Where drinking water is abstracted, poor forest management can add to
water treatment costs and have an impact on public health.  Private
water supplies are particularly vulnerable to disturbance as they often
undergo limited or sensitive forms of water treatment, and there may
be limited scope for alternative solutions/sources in the event of
pollution.
• Climate change is expected to have a significant impact on the
freshwater environment and is likely to affect both the timing and
volume of river flows and extent of groundwater recharge, with
subsequent effects on water quality and ecology.  The increased risk of
flooding and soil erosion is of particular concern, because of wetter
winters and more frequent extreme rainfall events throughout the year. 
The vulnerability of water resources in the face of reductions in summer
rainfall is another concern, with potential serious implications for water
supplies and ecosystem flows. 
• Greater soil drying because of climate change could increase water
colour through the enhanced decomposition of soil organic matter and
the release of dissolved organic carbon.  This could impact upon
freshwater ecology and interfere greatly with water treatment, causing
taste problems and increasing the cost of treatment.  
• Higher water temperatures could threaten the survival of salmonid fish
and other sensitive freshwater life.  
• Forest and forestry management practices can help to lessen or
exacerbate the impacts of climate change, therefore there is a need to
develop appropriate strategies for the management and redesign of
forests for water protection.
• Vegetation cover in water catchments can impact on the quality and
quantity of the water entering the soil.  Water quantity is affected when
the trees and other vegetation intercept some of the precipitation,
which then evaporates back into the atmosphere without reaching the
ground (interception loss), for the water which reaches the soil, some
water is taken up by vegetation, and the rest is either retained in the soil
or drains away.  Water quality be affected by evaporative loss –
chemicals present (mist, aerosols and pollutant gases) are captured by
the canopy, and by chemical interactions within the vegetation layer. 
The amount of water flowing through each of these routes can be
influenced by the nature of the vegetation and soil, and as such by land
use practices. 
• Drainage water can take a number of pathways over and through the
soil and bedrock to the river basin outlet.  These pathways will depend
on geology, topography and soil, and human interventions, and these
pathways will have a noticeable impact on the timing, volume and
quality of water reaching watercourse and waterbodies.
• Groundwater is important for water supply (public and private),
maintaining river flows in drier months and sustaining wetlands. 
Groundwater bodies are very sensitive to contamination e.g. the
careless use of pesticides.  Once groundwater is contaminated it may be
difficult or impossible to restore good water quality.
• Riparian Zones - areas of land adjoining the aquatic zone and influenced
by it, which includes the riverbank, but not the wider floodplain.

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Riparian zones can be ecologically rich, host a wide range of habitats,
they can link ecologically rich habitats and provide migration corridors
for invertebrates, birds and mammals.   In locations where natural
flooding occurs, large areas of wet woodland habitat can extend from
the riparian zone across the floodplain – these woods are now rare in
the UK and are identified as priority habitat types in biodiversity
strategies. 
• Aquatic Zones – are areas that are frequently or permanently under
water, forming streams, rivers, ponds, lakes, wetlands, estuaries, and
coastal waters.  They can vary greatly in their size and sensitivity to
pressures.  Waterbodies make up the management units for controlling
pressures as a result of human activities, with environmental objectives
and standards set to protect and improve the quality and the quality of
the river basin as a whole.
• Forests and freshwater ecology – waterbodies provide habitats for a
large range of plant and animal species and forests have an important
role in the ecological functioning of the freshwater environment.  To
meet UKFS Requirements, forest design and management must
maintain or restore the natural features, processes and habitats the
define the freshwater ecology and characterise the site.   By doing so,
the water element of the forest environment will be protected, and the
water resource suitable for a range of purposes.  The needs of protected
and priority species e.g. otter, water vole, Atlantic Salmon, freshwater
pearl mussel, require specific attention when considering how forests
and forest management can help sustain the ecological requirements of
plants and animals.   The spread of invasive species (plants and animals)
can also pose a threat in terms of degrading riparian and freshwater
habitats, leading to a loss of native species – coordinated action is
required to control the spread.  The protection of small streams, which
can be an important spawning habitat for salmonid fish, is fundamental
to the sustainability of fish populations and downstream fisheries, as
well as for maintaining other freshwater life. Estuarine and coastal
waters are less influenced by forestry, but some waterbodies are very
sensitive to disturbance e.g. designated shellfish waters, which can be
negatively impacted by increased sediment and nutrient inputs linked
with larger-scale forestry operations. 
• Integrated Catchment Management Approaches – these approaches
address sustainable forest management from a catchment perspective,
providing a framework to safeguard the natural functioning of
freshwater ecosystems.  Land management has a substantial impact on
the water environment, therefore its vital that forest planning is
considered within the context of the wider catchment. 
• Some of the UKFS Requirements for Forests and Water state that:
−  Prior permission must be obtained from SEPA or lead local flood
authority for building, engineering and other activities in or adjacent
to watercourse that affect river hydromorphology, including water
abstraction, impoundments, constructing culverts and extracting
river gravel (particularly in the case of SACs, SPAs or SSSIs).  
−  Groundwater must be protected from harmful and polluting
substances, and the water regulatory authority must be consulted
regarding the disposal of such substances to land.
−  Forestry operations must not lead to harmful or polluting substances
contaminating public or private water supplies.
− Appropriate regulators must be consulted for new woods next to
main rivers and flood defences, and the necessary consents obtained.
−  Appropriate protection and conservation must be given where sites,
habitats and species are subject to the legal provisions of EU
Directives and UK and country legislation.  An Appropriate
Assessment is required for Natura 2000 sites likely to be affected.
−  Forest management should contribute towards achieving River Basin
Management Plans objectives and ensure forestry pressures on the
aquatic environment are addressed.
−  Woodland creation and management should aim to help protect and
restore the quality of the freshwater environment through reducing

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the impact of more intensive land management activities and
environmental change.
−  Watercourses and waterbodies should be identified, and appropriate
buffer areas established and maintained to protect aquatic and
riparian zones from adjacent activities – recommended buffer widths
are 10m, 20m and 50m depending on the situation. 
−  Where new planting or restocking is proposed within catchments of
waterbodies at risk of acidification, an assessment of the contribution
of forestry to acidification and the recovery process should be carried
out and details of the assessment procedure agreed with the water
regulatory authority.
−  In areas prone to flooding, woodland creation or the management
and redesign of existing forests and woodlands in relevant upstream
water catchments should be considered as a means of mitigating
flood risk.
−  Where new woodlands are proposed, the sensitivity of downstream
waterbodies and wetlands to a reduction in water quantity should be
considered and advice sought from the water regulatory authority
and conservation agency where there is an issue.
• The UKFS identifies the key factors important for forests and water as
being:  Acidification; Sediment Delivery; Nutrient Enrichment;
Pesticides; Fuel Oils, Lubricants and Fire-Fighting Chemicals; Water Yield
and Low Flows; Peak Flows and Flooding, and Shade and Shelter.
Scotland's Forestry Strategy 2019-2029, Scottish Government
The Strategy sets out the Scottish Government’s ambition for forestry in
Scotland.  It contains a 50-year vision and 10-year framework to action,
expand, protect and enhance Scotland’s forests and woodlands, and at the
same time deliver multiple benefits for the people of Scotland, including
greater economic, social and environmental ones. 
The Strategy is underpinned by sustainable forest management principles
and includes an expansion target to increase the annual level of woodland
creation up to 18,000 Hectares (Ha) in 2024/25. 
The Strategy’s Objectives are:
• Increase the contribution of forests and woodlands to Scotland’s
sustainable and inclusive economic growth. 
• Improve the resilience of Scotland’s forests and woodlands and
increase their contribution to a healthy and high quality
environment.
• Increase the use of Scotland’s forest and woodland resources to
enable more people to improve their health, wellbeing and life
chances. 
It’s identified Priorities are:
• Ensuring forests and woodlands are sustainably managed.
• Increasing the adaptability and resilience of forests and woodlands.
• Expanding the area of forests and woodlands, recognising wider land-
use objectives.
• Enhancing the environmental benefits provided by forests and
woodlands.
• Improving efficiency and productivity, and developing markets.
• Engaging more people, communities and businesses in the creation,
management and use of forests and woodlands. 
Scotland's Forestry Strategy Implementation Plan 2022-2025, Scottish
Government
This Implementation Plan sets out emerging priorities and actions to be
delivered, which will progress the long-term objectives of Scotland’s
Forestry Strategy.

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The Plan identifies and considers the 5 Strategic Drivers which reflect more
current circumstances and Government priorities since the publication of
the national Forestry Strategy.  Those drivers are:
1. Resilience
2. Reversing Biodiversity Loss
3. Net-Zero
4. Just Transition
5. Green Recovery
It also identifies a range of actions linked to the Priorities of Scotland’s
Forestry Strategy 2019-2029. 
Scottish Forestry, The Right Tree in the Right Place: Planning for Forestry
and Woodlands
This Scottish Government guidance, issued by Forestry Commission
Scotland (now Scottish Forestry), provides advice to planning authorities
on planning for forestry and woodlands.  It supports the Scottish Ministers’
wish to see a significant expansion in woodland cover across Scotland,
delivering with it multiple societal benefits.   The guidance note should be
used to inform the preparation of development plans and may be a
material consideration in planning decisions.  
Section 2 of the document considers the current policy context and drivers
and highlights that modern forestry policy and practice has a focus on
achieving sustainable development and delivering a wide range of benefits
to society from trees and woodlands.  The guidance recognises that ‘well
planned and well managed and integrated effectively into the local mosaic
of land use, woodlands can play an important role in delivering a wide
range of Government objectives, as well as meeting local priorities and
needs.’   On the other hand, when poorly planned and managed,
opportunities to realise woodland benefits can be lost, or negative impacts
on the economy, society, and the natural and historic environment can
occur.
Section 3 provides advice on preparing an up-to-date forestry and
woodland strategy, including suggested scope and content and outline
process for producing one.
Section 4 considers the range of Scottish Government outcomes that
forestry and woodland can make a contribution towards the delivery of,
and details how they can be supported via development planning; such as:
sustainable economic growth; sustainable construction; timber transport;
energy forests and biomass; woodlands for people (including
strengthening communities and improving quality of life and sense of
place, and  woodlands for recreation, health and wellbeing); woodlands
and landscape, biodiversity, the historic environment, water, soils, land
restoration, and climate change.   This support can either be through policy
or guidance.  
Section 5 looks at the subject of woodlands and the development
management process.  It provides guidance to planning authorities on the
consideration of forestry and woodlands, including their protection,
creation, restructuring, and removal, in development management, and
how to involve Scottish Forestry in decision-making.

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2020 Challenge for Scotland’s Biodiversity - A Strategy for the
conservation and enhancement of biodiversity in Scotland, Scottish
Government
This national biodiversity strategy sets out ambitious policy proposals for
restoring nature and getting more benefits from it, including improving the
condition of native woodlands identified in the Native Woodland Survey of
Scotland, and improving places for people and nature through expanding
and enhancing green and blue infrastructure and networks to help
encourage more physical activity and contact with nature. 
Scotland’s 2020 Challenge aims to:
• Protect and restore biodiversity on land and in our seas, and to
support healthier ecosystems.
• Connect people with the natural world, for their health and wellbeing
and to involve them more in decisions about their environment.
• Maximise the benefits for Scotland of a diverse natural environment
and the services it provides, contributing to sustainable economic
growth. 
The Strategy advocates applying an Ecosystems Services approach at a
river catchment level to help restore ecosystem health in catchments
across Scotland.  It also recognises the value of natural capital to both
people and economy and making the most of our natural assets in the
most resource efficient manner. 
NFI Woodland Ecological Condition Assessment Methodology, Forest
Research
Forest Research has created a new methodology for determining the
ecological condition of Scotland’s woodlands (both plantation and semi-
natural) to help inform policy and land management decisions.  The
Woodland Ecological Condition assessment is based on National Forest
Inventory data and uses 15 indicators of woodland ecological condition
and a further classification of woodland habitat into it condition status of
favourable, intermediate and unfavourable. 
The Scottish Government's Policy on Control of Woodland Removal,
Forestry Commission Scotland
Under the Scottish Government's Control of Woodland Removal
Policy, loss of woodland should only be permitted if it results in significant
public benefits.  Planting in other areas to make up for any loss of
woodland is often expected.  The Policy outlines the following 5 Guiding
Principles:
• There is a strong presumption in favour of protecting Scotland’s
woodland resources.
• Woodland removal should be allowed only where it would achieve
significant and clearly defined additional public benefits.  In
appropriate cases a proposal for compensatory planning may form
part of this balance.
• Approval for woodland removal should be conditional on the
undertaking of actions to ensure full delivery of the defined additional
public benefits.
• Planning conditions and agreements are used to mitigate the
environmental impacts arising from development and Forestry
Commission Scotland [now Scottish Forestry] will also encourage their
application to development-related woodland removal.

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• Where felling is permitted but woodland removal is not supported,
conditions conducive to woodland regeneration should be maintained
through adherence to good forestry practice as defined in the UK
Forestry Standard. 
Scottish Water Sustainable Land Management
Scottish Water’s Sustainable Land Management (SLM) Team work in
collaboration with landowners and developers to protect sources of
drinking water throughout Scotland.  Land use practices, operations and
activities, such as farming, large and small scale construction, and forest
activities, can impact upon the quality of source water.  Therefore, it is
important to properly assess the risks in order to avoid the quality of the
source water being impacted, with knock on effects of increases in energy
and chemical use for water treatment.  
Scottish Water abstractions are designated as Drinking Water Protected
Areas (DWPA) under Article 7 of the Water Framework Directive, therefore
protection is required to avoid deterioration.  Each water treatment works
is designed according to the quality of the water it supplies, as such, any
deterioration in water quality can impact on its ability to treat water to
meet drinking water quality standards and regulatory requirements.  Map
A4(1) to follow shows the location of DWPA Catchments within the Perth
and Kinross Area.  Map A4(2) shows the DWPA Groundwaters, and Map
A4(3) the DWPA Rivers and Lochs. 
1 Source water catchments are areas that generate public drinking water supplies,
including land draining to reservoirs, lochs, rivers, springs and boreholes. 
Scottish Water Guidance on Forestry Activities near Scottish Water
Assets, September 2017
This guidance note sets out the precautions Scottish Water wish to see met
when forestry activities are taking place in source water catchments1 and
areas that contain their infrastructure assets, to ensure that activities do
not result in reduced water availability, a deterioration in water quality, or
cause damage to the water supply and waste water infrastructure.
The document is intended to help forest managers and practitioners
understand the extra precautions that should be taken in source water
catchments, and near assets, to demonstrate compliance with relevant
legislation – in particular, the legal requirement that forestry operations
must not lead to harmful or polluting substances contaminating drinking
water supplies.   Scottish Water invite forest managers to contact them
with details of the proposed woodland to allow them to help determine if
it lies within a source water catchment or near their assets, to allow them
to confirm what extra precautions will be needed, along with any
appropriate risk-based measures, to help inform their forest management
plans and operations.  This could entail the consideration of natural and
artificial drainage patterns, proposed infrastructure and protection,
potential changes to water availability, and pollution mitigation measures.
Extra precautions identified in the guidance focus on the themes of
Hazardous Substances, Roads and Drains, and Near Infrastructure.

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Map A4(1): Scottish Water Drinking Water Protected Areas – Catchments

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Map A4(2): Scottish Water Drinking Water Protected Areas – Groundwaters

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Map A4(3): Scottish Water Drinking Water Protected Areas – Rivers and Lochs

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Existing Forestry, Woodland, and Trees within Perth and Kinross
National Forest Inventory (NFI), Forest Research
The National Forest Inventory (NFI) provides information about the size,
distribution and composition of all forests and woodlands in Scotland. 
Map A4(4) on the following page shows the NFI for the Perth and Kinross
Area.  The 2022 NFI data release tells us that 17.9% of the total land area
of Perth and Kinross (96,877.63 Ha) is covered by woodland.  The
percentage breakdown of the main woodland cover subsets for the area is: 
• Conifers – 48.1% (46,569.93 Ha)
• Broadleaved – 18.1% (17,490 Ha)
Native Woodland Survey of Scotland (NWSS), Scottish Forestry
Map A4(5) to follow shows the Native Woodland Survey of Scotland
(NWSS) for the Perth and Kinross Area.  The NWSS identifies and maps the
location, extent, type, and condition of all of Scotland's native woodlands
in 2014.  Native woods can be semi-natural (self-sown) or planted.  They
are defined as woods in which over 50% of the canopy is made up of
species native to the region.
51.6% of the area’s woodland cover is Native Woodland (49,981.26 Ha),
and 1.2% is Nearly Native (1,131.23 Ha).  Private owners manage 65% of
the area’s forests and woodlands, and 35% is managed by Forestry and
Land Scotland.   
Ancient Woodland Inventory (AWI), NatureScot and The Woodland Trust
Ancient Tree Inventory (ATI)
The Ancient Woodland and Ancient Tree inventories provide information
on trees and woodland of high biodiversity value.  Woodlands that have
been continuously present in some form for at least 270 years are known
as ancient woodlands.  Map A4(6) to follow shows the inventories for the
Perth and Kinross Area.  
Scotland's National Forests and Land 
This interactive map provided via Scotland’s Environment Web shows
details of the National Forest Estate which is managed by Forest and Land
Scotland. 
PKC Interactive Heritage Map
The Council’s online interactive Heritage Map (See Map A4(7) to follow)
shows the location of tree groups, tree lines and individual trees across
Perth and Kinross that are protected by a Tree Preservation Order (TPO),
and those within a Conservation Area.  All trees within Conservation Areas
are protected from pruning, lopping, and felling.  
Historic Environment Scotland’s Portal
The HES Portal shows the location of those sites within the Perth and
Kinross Area contained on the Inventory of Gardens and Designed
Landscapes (GDLs).  These sites are grounds which have been ‘consciously
laid out for artistic effect.’  The most common type of site on the Inventory
is the estate landscape, however, there are other types of sites including
botanic garden collections, horticulturalist’s gardens, and gardens which

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offer rich and varied habitats for nature conservation and/or hold
important stocks of rare or champion trees, shrubs and plant material. 
There is a total of 41 Inventory of GDLs sites within Perth and Kinross. 
Historic Environment Scotland’s Portal provides detailed information
regarding the location of these sites, their special characteristics, and
reasons for designation.   Map A4(8) to follow shows the location of the
Inventory of Garden and Designed Landscape sites within Perth and
Kinross, and Table A1 provides detail regarding the level of interest of
those Inventory sites in terms of horticultural, scenic and nature
conservation value.

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Map A4(4):  National Forest Inventory for the Perth and Kinross Area

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Map A4(5):  Native Woodland Survey of Scotland for the Perth and Kinross Area

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Map A4(6): Ancient Woodland Inventory and Ancient Tree Inventor

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Map A4(7): Tree Preservation Orders within the Perth and Kinross Area

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Map A4(8):  Inventory of Gardens and Designed Landscapes Sites within the Perth and Kinross Area

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Table A4(1): Inventory of Gardens and Designed Landscapes (GDLs) Sites with Horticultural, Scenic or Nature Conservation Value
GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
Abercairny High level of horticultural interest.  The collection
of trees in the arboretum, although now somewhat
depleted, gives Abercairny high horticultural and
silvicultural value.
High level of scenic interest.  The
designed landscape has high
scenic value within the
surrounding area. 
Some level of nature conservation
interest.  The water features and
woodlands at Abercairny are of some
value for nature conservation.
Aberuchill
Castle 
Some level of horticultural interest.  There used to
be an interesting plant collection at Aberuchill,
however, little of this remains today.  It therefore
has some value for its place in the history of
horticulture.
Outstanding level of scenic
interest.  The policy woodlands
are very attractively planted and
make an outstanding contribution
to the surrounding scenery.
High level of nature conservation
interest.  The variety of habitats
provided within the estate gives
Aberuchill high value in this category. 
Balmanno Little level of horticultural interest.   Outstanding level of scenic
interest.  The garden of Balmanno
is concealed from the
surrounding landscape by the
garden walls, but these and the
Castle itself make an outstanding
contribution to the scenery.
Little level of nature conservation
interest.  The pond on the western
boundary, and the 18th century trees,
provide a little nature conservation
interest.
Battleby High level of horticultural interest.  The plant
collection had high Horticultural value in the
surveys made in the early 1970s.   A further, more
extensive survey made when plants are in flower
could assess the current value of the collection.
High level of scenic interest. 
Battleby has high scenic value
within the surrounding landscape.
Some level of nature conservation
interest.  The Battleby woodlands have
some value for nature conservation and
certain areas of the woodlands are being
managed to encourage the re-
establishment of ground flora
Blair Adam Some level of horticultural interest.  Although the
estate was extensively planted with woodland in
the 18th and 19th centuries, the trees which
survive now are, in the main, second-generation
trees. There are some first-generation trees in the
High level of scenic interest.  Blair
Adam occupies an area of mostly
parkland and woodland lying to
the east of the M90 motorway to
the north of Kelty Village.  The
Some level of nature conservation
interest.  There are no nationally
designated sites within the landscape. 
The area of undisturbed woodland

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GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
drives to Kiery Crags Lodge, East Lodge and in the
outer part of the Arboretum. These trees include
conifers, beech, lime and oak.
In terms of horticultural value, the walled garden,
which lies to the northeast of the house was laid
out in the 1750s by John Adam.  This was recorded
in the Gardener's Magazine of 1842 as having a
particularly rich collection of small herbs,
perfumery and medicinal plants and an excellent
collection of herbaceous plants. The garden is
currently being restored to its 19th century format.
The arboretum which was designed as the
southern part of the walled garden in the 1750s,
had specimen trees, including two silver firs and 27
sorts of evergreen shrubs planted to provide
winter colour. Some specimen trees survive here in
the outer section, but the majority are second
generation trees.
The wider parkland was formally laid out by
William Adam between 1733 and 1748. Some of
the beech and lime trees from this time remain.
The landscape was informalised by his son John
Adam from 1748-1792, and a number of woodland
enclosures were planted. The parkland was
extended to the south by William Adam from 1792-
1839 and more clumps of woodland were added.
Some trees from this time remain, mainly oak and
lime, but not in extensive numbers.   
parkland land provides some
contrast to the surrounding
agricultural land, particularly
when viewed from the east.  It is,
however, partly screened from
the public road by belts of trees
and is not extensive in area in
comparison to other Inventory
designed landscapes.
provide some nature conservation
interest.
Blair Castle Outstanding level of horticultural interest.  The
pinetum contains a collection of conifers which is
very important arboriculturally for the variety and
Outstanding level of scenic
interest.  The designed landscape
has outstanding scenic value. It
Outstanding level of nature conservation
interest.  The lime-rich area of Glen Tilt,
Tulach Hill, and other nearby areas are

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GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
size of the species. The site is given added
importance by the historic silvicultural significance
of the early pioneering forestry planting. This gives
Blair outstanding horticultural value.
occupies most of the valley of the
River Garry at this point and the
elements within it, notably the
parkland, the woodland clumps
and belts and the forestry
plantations all make a major
contribution to the scenery of the
area.
designated as a SSSI and gives Blair
outstanding nature conservation value.
Bolfracks Outstanding level of horticultural interest.  The
range of plants, especially the gentians, Primulas
and bulbs, gives the garden outstanding
horticultural value.
High level of scenic interest.  The
line of trees along the road and
those around the house give it
high scenic value.
Outstanding level of nature conservation
interest.  Bolfracks Wood is designated
as an SSSI, and gives the site outstanding
nature conservation value.
Braco Some level of horticultural interest.  The trees and
plantings give the designed landscape at Braco
some horticultural value.
High level of scenic interest. 
There are good views of Braco
from the surrounding public
roads which give this site high
scenic value.
High level of nature conservation
interest.  Braco Pinewood, a designated
SWT Listed Wildlife Site, lies adjacent to
the designed landscape north-west of
the castle.  Taken together with the
estate policies, there is high value
conservation value. 
Branklyn Outstanding level of horticultural interest. 
Branklyn has an outstanding collection of plants,
shrubs and trees. At the time of this assessment
(2017)] it holds three National Collections of Plant
Heritage: the Rhododendron subsect. Taliense
group; Cassiopes – e.g Cassiope wardii; and
Meconopsis (large flowered blue species and
cultivars of Himalayan poppy), with over 50
different types including particularly notable
examples such as Mecanopsis 'Dorothy Renton'.
Branklyn is also an important garden for primulas,
and for 'North' Lilies'.  In addition, Branklyn has
No scenic interest.  Branklyn does
not make a significant
contribution to the scenic quality
of the surrounding landscape. It is
a relatively small and secluded
garden. It complements rather
than contrasts with the wider
setting of villas and garden
grounds. There are limited inward
views into the garden.
Some level of nature conservation
interest.  Although there are no nature
conservation designations in place,
Branklyn is managed in a way to
encourage biodiversity. There are red
squirrels in the garden, and bug hotels
have been installed as a habitat for
insects, and as an educational tool.

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29 
GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
many important trees recorded in the database of
the Tree Register of the British Isles, including two
Britain and Ireland champions (Pinus Sylvestris
'Globosa'; Cryptomeria Japonica 'Compacta'); six
Scottish and seven county champions.                                                                               
Staff from the NTS maintain these collections to
ensure that they are in good condition. There is
regular contact with horticultural experts from
across the UK and further afield, for example
members of the 'Meconopsis Group'. A key priority
(2017) is to conserve the Cassiopes but further
research and restoration work is planned to
recreate part of the scree garden of moraine, and
the specialised planting which existed previously.
Plant labelling within the garden is kept up-to-date
and staff maintain an accurate record of the
planting scheme on a dedicated database. Active
propagation of the collection is ongoing, for
example, involving students in taking cuttings of
Cassiope, and in gathering seed.  Plant specimens
and seed from the garden are sold from the shop
on site.                                                                                                                                    
Branklyn has an important place in the history of
horticulture in Scotland, for example in Dorothy
Renton's pioneering use of peat, and in the
cultivation of rare plants. At the time of writing
(2017), Branklyn is one of the only gardens in
Scotland (one of three NTS gardens) still allowed to
use peat blocks, in order to conserve this historic
feature of the garden.

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30 
GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
Castle Menzies Little level of horticultural interest.  A few
remaining specimens of the arboretum provide a
little horticultural value at present.
Outstanding level of scenic
interest.  The castle is of
outstanding scenic value when
seen from the surrounding
countryside.
Little level of nature conservation
interest.  The curling pond, which is now
silted up, together with the woodlands,
provide little nature conservation value.
Cleish Castle High level of horticultural interest.  The estimated
age and completeness of the yew avenue give this
site high horticultural value.
High level of scenic interest.  The
views out of the site to the Cleish
Hills and the views into the site
give it high scenic value.
Little level of nature conservation
interest.  The nature conservation value
of this site is reduced by its coniferous
plantations.
Cluny House Outstanding level of horticultural interest.  The
garden has a rare and extensive collection of
plants, including notable collections of meconopsis
and primula, many of which are derived directly
from seed collected by the 1949 Ludlow and
Sherriff expedition to Bhutan. New species
continue to be supplied from seed collected in
Himalayan regions. Plants are propagated on-site
and made available to others through seed sales
and exchanges. At the time of reporting (2017)
seven champion trees are recognised within the
garden, three of which are national champions,
and the remainder county champions, while a
number of rare and threatened conifer trees have
been planted at Cluny as part of the Perthshire Big
Tree Country Conifer Conservation Programme.
Together this gives Cluny outstanding horticultural
value.
Some level of scenic interest. 
Cluny House gardens occupy a
sloping site on the western side
of Strathtay. While the garden is
designed to be inward looking, its
woodland canopy can be seen
from the surrounding area.
High level of nature conservation
interest.  Although there are no national
natural heritage designations Cluny
House merits high nature conservation
value. The garden is managed in a way to
promote wildlife and provides a habitat
for birds and red squirrels (a protected
species), as well as insects such as bees.
An area of the garden where native
wildfowers can flourish is under
development. Within the woodland
garden, a wide variety of funghi species
has been recorded.
Craighall
Rattray
No horticultural interest - there are no plant
collections at Craighall Rattray.
Outstanding level of scenic
interest.  The setting of the
mansion on the edge of a sheer
cliff-face above Ericht Gorge, and
Outstanding level of nature conservation
interest.  The ancient woodlands along
the Craighall Gorge are designated as an
SSSI and have outstanding nature

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31 
GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
with extensive views along it, is
impressive, and the view of the
castle and estate woodlands from
its surroundings gives it
outstanding scenic value.
conservation value for their botanical
and entomological interest.
Drumkilbo Some level of horticultural interest.  The plant
material in the gardens have some horticultural
value.
Some level of scenic interest.  The
mature woodland canopy of the
shelterbelt provides some
significance in the open
agricultural plain of Strathmore.
Little level of nature conservation
interest.  The woodlands of Drumkilbo
provide a little nature conservation
value.
Drummond
Castle
High level of horticultural interest.  The range of
bedding and herbaceous plants as well as several
fine trees in the park gives Drummond Castle GDL
high horticultural value.
High level of scenic interest.  The
designed landscape can be seen
from the A822 which, as it
borders the policies, is lined by
mature beech trees, giving
Drummond high scenic value.
Outstanding level of nature conservation
interest.  Part of Drummond Wood and
Loch Drummond has been designated as
a SSSI and this gives Drummond
outstanding nature conservation value.
Dunira Little level of horticultural interest.  While there
are records of interesting trees and plants in the
past at Dunira, there has never been an important
plant collection, but the Pinetum gives it a little
horticultural value.
Outstanding level of scenic
interest.  Dunira makes a major
contribution to the surrounding
scenery. 
High level of nature conservation
interest.  The moorland, woodland and
burnside habitats provide high value for
nature conservation.
Dunkeld House Outstanding level of horticultural interest.  Dunkeld
has outstanding horticultural value as it is the site
of one of the first larch plantations. It also has an
important collection of coniferous trees.
Outstanding level of scenic value. 
The designed landscape of
Dunkeld has outstanding scenic
value.
Some level of nature conservation
interest.  Dunkeld has some nature
conservation value on account of the
river and the woodlands which have
remained undisturbed for many years.
Dupplin Castle Outstanding level of horticultural interest.  The
collection of trees at Dupplin give this site
outstanding horticultural value.
Outstanding level of scenic
interest.  Dupplin Estate has
outstanding scenic value,
High level of nature conservation
interest.  The nature and variety of the
plantations and park trees give this site
high nature conservation value.

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32 
GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
particularly when viewed from
the south.
Errol Park Some horticultural interest.  The tree cover on this
site combined with the horticultural interest in the
garden give this site some value in this category.
Some level of scenic interest.  The
well-maintained plantations give
some scenic value.
Some nature conservation interest.  The
good spread of trees, particularly oak,
give this site some nature conservation
value.
Falls of Bruar Outstanding level of horticultural interest.  The site
has outstanding horticultural value because of its
place in Scottish silviculture history.
High level of scenic interest.  The
views of the site in relation to the
surrounding countryside give it
high scenic value.
Some level of nature conservation
interest.  There is some nature
conservation interest in the largely birch,
hazel and pine woodland in the gorge,
but the area is otherwise relatively
species poor.
Fingask Castle Some level of horticultural interest.  The age of the
older yew trees, and the range and size of the
topiary figures gives Fingask some horticultural
value.
Some level of scenic interest.  The
woodland canopy contributes to
the surrounding scenery
especially from the A85(T) and
gives this site some scenic value.
Some level of nature conservation
interest.  The flora in the 17th century
woodland and the undisturbed pastures
give Fingask some nature conservation
value.
Glendoick Outstanding level of horticultural interest.  The
outstanding and valuable collection of plants, and
particularly the ericaceous Rhododendrons, gives
Glendoick outstanding horticultural value.
Some level of scenic interest.  The
woodland canopy contributes to
some scenic value to the
surrounding scenery, particularly
viewed from the A85 trunk road.
Little level of nature conservation
interest.  The range of the woodland
flora, especially in the ravine and Wild
Garden, gives Glendoick a little nature
conservation value.
Gleneagles
Hotel and Golf
Courses
Some level of horticultural interest.  The collection
of trees and shrubs, particularly along the Golden
Path, give some value for horticulture.
Some level of scenic interest. 
Gleneagles was specifically
chosen by Donald Matheson as a
prime place for the hotel and golf
courses. The view out from the
site to the surrounding hills and
landscapes is outstanding, but the
low lying and gently undulating
contours of the courses and the
Outstanding level of nature conservation
interest.  The Gleneagles Hotel and Golf
Courses is outstanding in this criterion as
there is one SSSI on the site (Gleneagles
Mire).
There are a further 19 locations which
are recognised by the Gleneagles Hotel
as being of local importance for their

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33 
GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
screening of the Gleneagles Hotel
means that it is not especially
differentiated from the
surrounding landscape when
viewed from a distance.
scientific or nature conservation interest.
The golf courses are managed in a way
that gives priority to nature
conservation, with the clearing of
invasive species, for example.  A diverse
species of wildlife, including red squirrel
and otter exist on the site.
Grantully Castle Some level of horticultural interest.  The old trees,
in particular the yews and limes, give Grantully
some horticultural value.
Some level of scenic interest.  The
policy woodlands and the Castle
itself are of some scenic value.
Some level of nature conservation
interest.  The old woodlands provide the
site with some nature conservation
value.
Inchyra Some level of horticultural interest.  Inchyra has
some horticultural value due to the interest
provided by plants in the shrubbery and woodland
garden.
High level of scenic value.  The
parkland of Inchyra has high
scenic value when seen from the
A85(T) road.
Some level of nature conservation
interest.  The woodlands of Inchyra
provide some nature conservation value.
Invermay Little level of horticultural interest.  The age of the
yew hedge and the early 19th century woodlands
give a little horticultural value.
High level of scenic interest.  The
woodland canopy and the natural
landscape of Invermay provide
variety in the surrounding
landscape, especially when seen
from the A9. This gives Invermay
high scenic value.
High level of nature conservation
interest.  The flora in the 19th century
woodland along the Humble Bumble
Gorge gives Invermay high nature
conservation value.
Keillour Castle Outstanding level of horticultural interest.  Keillour
has high horticultural value due to the outstanding
botanical value of the plant collection.
Little level of scenic interest.  The
designed landscape at Keillour
has a little scenic value in the
surrounding landscape.
Some level of nature conservation
interest.  Keillour has some nature
conservation value provided by the
woodlands, burns and gorges of the
Keillour and Horn Burns.
Kinfauns Castle Some level of horticultural interest.  The remaining
trees in the arboretum are of some
horticultural/arboricultural value.
Outstanding level of scenic
interest.  The woodlands and
follies on the hills within the
Little nature conservation interest
provided by the woodlands.

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34 
GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
designed landscape are of
outstanding scenic value.
Kinross House Some level of horticultural interest.  The
interesting planting in the garden, especially the
herbaceous borders, give this site some
horticultural value.
High level of scenic value.  The
contribution of the woodland
canopy adjoining the Town,
which can be seen from the
motorway, gives Kinross House
high scenic values.
Outstanding level of nature conservation
interest.  The shoreline of Loch Level is
an SSSI and this gives Kinross House
outstanding nature conservation value.
Meggernie
Castle
Some level of horticultural interest.  The age of the
lime and Scots pine gives the grounds some
aboricultural value.
Outstanding level of scenic
interest.  The parkland and
woodland make an outstanding
contribution to the surrounding
landscape of the NSA.
Outstanding level of nature conservation
interest.  The remnants of the
Caledonian Forest give Meggernie
outstanding value for nature
conservation.
Megginch
Castle
High level of horticultural interest.  The age of
some of the plant material, particularly the yew
trees, the Banksian Rose, Wisteria and the
Camellia, as well as the ornate topiary, gives
Megginch high horticultural value.
Outstanding level of scenic value. 
The woodlands make a significant
contribution to the scenery in the
flat plain of the Carse of Gowrie
which give this site outstanding
scenic value.
Some level of nature conservation
interest.  The woodland flora and the
naturalised bulbs and flowers give
Megginch some nature conservation
value.
Meikleour High level of horticultural interest.  The beech
hedge, the 17th century trees, and the recent
planting of trees and shrubs give this site high
horticultural value.
Outstanding level of scenic
interest.  The designed landscape
and beech hedge provide an
outstanding contribution to the
scenery.
Outstanding level of nature conservation
interest.  The ancient woodland and
riverbank habitats give this site
outstanding nature conservation value.
Methven Castle Outstanding level of horticultural interest. 
Although many of the trees in the pinetum have
been lost, Methven is reputed to have been one of
the first pinetums in Scotland, and therefore has
outstanding horticultural value.
Outstanding level of scenic
interest.  The setting of the castle
on a height above the
surrounding approach roads and
the extensive woodlands give
Outstanding level of nature conservation
interest.  Methven Wood is an SSSI of
outstanding importance for nature
conservation.

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35 
GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
Methven outstanding scenic
value.
Monzie Castle High level of horticultural interest.  The larches,
planted in 1738 and amongst the earliest
introductions into Scotland, represent an
important point in arboriculture history and so give
the site high value in this category.
High level of Scenic interest. 
Monzie provides high scenic value
in its contribution to the local
landscape. 
High level of Nature Conservation
interest.  Monzie Wood, SSSI, lies
adjacent to the designated landscape,
north of Monzie Village.  Monzie Estate
policies contain a range of natural
habitats which gives the site high value
in this category.
Murthly Castle Outstanding level of horticultural interest.  The
range and size of the trees, particularly the
conifers, give Murthly outstanding horticultural
value.
Outstanding level of scenic
interest.  The extent of the policy
woodlands in the Tay Valley gives
this site outstanding scenic value.
High level of nature conservation
interest.  The ancient woodlands,
undisturbed pasture and riverbanks all
give this site outstanding nature
conservation value
Ochtertyre Little level of horticultural interest.  The remaining
trees from the 19th century planting in the gardens
provide a little horticultural value.
Outstanding level of scenic value. 
The designed landscape makes an
outstanding contribution to the
local scenery.
High level of nature conservation
interest.  The woodlands and
waterbodies provide high nature
conservation value.
Rossie Priory High level of horticultural interest.  Rossie Priory
has high horticultural/aboricultural value due to
the presence of the arboretum and planting in the
gardens.
Outstanding level of scenic
interest.  The policies of Rossie
Priory provide an outstanding
contribution to the surrounding
scenery.
High level of nature conservation
interest.  The waterbodies and
woodlands at Rossie have high nature
conservation value.
Scone Palace Outstanding level of horticultural interest.  The
collection of trees (especially those in the
pinetum), the associations with David Douglas and
the Douglas firs which he introduced, and the few
very ancient trees in the park and garden give
Scone outstanding horticultural value.
High level of scenic interest.  The
park and woodlands make a
significant contribution to the
views from Perth, especially from
the riverside.  The policies can
also be seen from two major
High level of nature conservation
interest.  The undisturbed pasture in the
park, the woodland flora in Scone Wood,
and the marginal flora along the burns
give Scone high nature conservation
value.

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36 
GDL Level of Horticultural Interest Level of Scenic Interest Level of Nature Conservation Interest
trunk roads and have high scenic
value.
Stobhall Outstanding level of horticultural interest.  Stobhall
has outstanding horticultural value as the topiary
garden provides a fine example of a small early
Scottish garden. Merit is also added by the
interesting range of plants grown in the woodland
garden since the 1950s.
Outstanding level of scenic
interest.  The woodlands, park
and lodge are of some Scenic
significance from the A93 but,
viewed from the Tay and its
opposite bank, Stobhall is of
outstanding scenic value.
High level of nature conservation
interest.  The well-established
woodlands and waterbodies of Stobhall
give it high nature conservation value.
Taymouth
Castle
Some horticultural interest.  The remnants of the
pinetum and the outstanding size of the remaining
trees gives this site some horticultural value.
Outstanding level of scenic
interest.  The designed landscape
covers the whole glen of the River
Tay and can be seen from both
roads, giving this site outstanding
scenic value.
Some nature conservation interest.  The
flora along the river and in the remnants
of the deciduous woodland gives
Taymouth some nature conservation
value.
The Hermitage High level of horticultural interest.  The Hermitage
has high horticultural/ arboricultural value for its
fine stands of Douglas fir and woodlands of mixed
species and ages, exhibiting considerable natural
regeneration
Little level of scenic interest.  The
Hermitage lies in a secluded
valley setting; however, the
woodlands provide a little scenic
contribution to the surrounding
landscape, which is within a
National Scenic Area.
High level of nature conservation
interest.  The woodlands of The
Hermitage are of high nature
conservation value.

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37 
Management of Existing Forestry, Woodland, and Trees
Scottish Forestry Map Viewer, Scottish Forestry
Scottish Forestry’s Map Viewer provides information on the management
of existing forestry, woodland, and trees, including long-term plans, felling
permissions, and re-stocking details. 
Forestry and Woodland Creation
National scale Land Capability for Forestry Map
The national Land Capability for Forestry Map identifies the potential for
land across Scotland to grow trees (including future forestry that would
support carbon sequestration activity) based on a number of factors, such
as soil, climate, and topography.  The map was produced by the Macauley
Land Use Research Institute and 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.
Table A4(2) and Map A4(9) 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 38.7% of
the total Council Area.  
Table A4(2): Breakdown of Land Capability for Forestry within the PKC
Area
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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38 
Map A4(9): Land Capability for Forestry in Scotland

Page 162

39 
Nature Scot, Carbon and Peatland Map (2016)
Nature Scot’s Carbon and Peatland Map shows the distribution of carbon
and peatland classes across Scotland.  It gives a value to indicate the likely
presence of carbon-rich soils, deep peat, and priority peatland habitat for
each individually mapped area, at a coarse scale.  The map categorises the
presence of carbon and peatland in various classes.  The top two classes on
the map, classes 1 and 2, are taken together to identify the nationally
important resource.
• Class 1: Nationally important carbon-rich soils, deep peat, and
priority peatland habitat; and areas likely to be of high conservation
value.
• Class 2: Nationally important carbon-rich soils, deep peat, and
priority habitat; and areas of potentially high conservation value and
restoration potential.
Map A4(10) to follow shows the location and extent of Class 1 and 2 soils
across the Perth and Kinross Council Area. 
Scottish Forestry Map Viewer and Scottish Forestry Public Register 
The Map Viewer provides information on Forestry Grant Scheme funding
target and eligibility areas within Perth and Kinross, and details of
successful funding.  More detailed information including maps, size and
species is provided on the Public Register. 
PKC Forest and Woodland Strategy (2020)
Our Forest and Woodland Strategy (FWS) Supplementary Guidance
provides a strategic framework for the development of forestry in the area
and includes a map of sensitivities and opportunities. The map categories
of preferred, potential, sensitive and unsuitable are used to inform forestry
and woodland creation proposals.   
Map A4(11) to follow highlights the opportunities for: forestry, forest
habitat networks, water management through planting, and enhancement
of existing woodland as identified in the Council’s FWS ‘Opportunities’
map.  Map A4(12) highlights where Class 2 and 3.1 Prime Agricultural Land,
along with Class 3.2, overlap with the FWS preferred and potential
opportunity areas.  
There are likely to be competing demands on our land across Perth and
Kinross, and it will be important to ensure the development of our Spatial
Strategy takes account of directing future land uses to the most
appropriate locations to help achieve sustainable development.
JHI Carbon Sequestration Study for the Perth and Kinross Council Area
(December 2021)  [Core Doc Ref: CD1]
The Council commissioned the James Hutton Institute (JHI) to undertake a
Carbon Sequestration Study of the Perth and Kinross Council Area.  The
study’s concluding report was submitted to the Council in December 2021. 
The project focussed 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 or reducing
greenhouse gas emissions.

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40 
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 most appropriate.

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41 
Map A4(10): Nature Scot Carbon and Peatland Map (2016) Nationally Important Soils Class 1 and 2

Page 165

42 
Map A4(11): Forest and Woodland Strategy (2020) Opportunities Map

Page 166

43 
Map A4(12): Land Capability for Agriculture (Prime Quality Land) and PKC Forest and Woodland Strategy (2020) Opportunities Map

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44 
Summary of Implications for the Proposed Plan:
Perth and Kinross Council Corporate Plan 2022-2027 
Delivery of the Corporate Plan’s Priorities will be underpinned by a set of
Key Principles and delivered through a range of Key Actions.  The Local
Development Plan is identified in Appendix 1 to the Corporate Plan as one
of the associated strategies which will help deliver the Council’s Corporate
Plan Priorities.  Developing our Local Development Plan 3 in alignment with
National Planning Framework 4, should help support the delivery of the
Council’s Vision for a Perth and Kinross ‘where everyone can live life well,
free from poverty and inequality’, all the Corporate Plan’s Priorities. 
However, Priorities 1, 3, 4 and 7 in particular should be delivered through
implementing NPF4 Policy 6.
National Policy Context
Scotland's Forestry Strategy 2019-2029, 
Scotland's Forestry Strategy Implementation Plan 2022-2025, 
Scottish Forestry’s, The Right Tree in the Right Place: Planning for
Forestry and Woodland
2020 Challenge for Scotland’s Biodiversity - A Strategy for the
conservation and enhancement of biodiversity in Scotland, 
NFI Woodland Ecological Condition Assessment Methodology, and 
The Scottish Government's Policy on Control of Woodland Removal
These documents are important for setting the national policy context
within which the Council’s review of our Forest and Woodland Strategy
(FWS) should be undertaken, as well as providing guidance for supporting
the contribution forestry and woodlands can make to Scottish Government
outcomes delivery via the development planning system, and on decisions
taken regarding new planting proposals, or proposals for development
which will affect our forest, woodland, and tree resources.  
The Objectives, Priorities and Strategic Drivers contained within Scotland’s
Forestry Strategy, and its associated Implementation Plan, will be used to
ensure our updated FWS is in alignment with national objectives and
priorities in order for the Perth and Kinross FWS and LDP3 Spatial Strategy
contribute to their achievement.  
The key aims and messages contained within the Scottish Biodiversity
Strategy will also be reflected across our LDP3 Spatial Strategy and the
FWS review to help protect and restore biodiversity, support healthier
ecosystems, better connect people with nature, and maximise the multiple
benefits our natural places and assets can offer.  
Our Strategic Environmental Assessment for our LDP3 and Forest and
Woodland Strategy will follow an Ecosystem Services approach at a river
catchment level. 
The review of our FWS should incorporate the NFI Woodland Ecological
Condition Survey information provided by Forest Research to highlight
where our woodland resource is classified as favourable, intermediate or
unfavourable to allow targeted action to help support improvements to
the overall condition of our forests and woodlands. 
The Guiding Principles of the Scottish Government’s Control of Woodland
Removal Policy will be reflected through the LDP3 Spatial Strategy and

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45 
reviewed FWS to help protect the woodland resources of the Perth and
Kinross Area.  
Scottish Water Sustainable Land Management and Guidance on Forestry
Activities near Scottish Water Assets, September 2017
Whilst Scottish Water’s guidance document is primarily geared towards
forest managers, it is a useful source of information regarding the potential
risks to drinking water supplies that forestry activities can bring, which will
be considered in more detail as part of the Strategic Environmental
Assessment for our Forest and Woodland Strategy review.  The ‘Drinking
Water Protected Areas’ datasets will form part of the environmental
baseline for the SEA of both LDP3 and FWS review, to identify those
locations where extra precautions, developed in consultation with Scottish
Water, will be required to avoid impacts on water quality and assets.  PKC
will also liaise with Scottish Water following the ‘Site Assessment’ exercise
for the Proposed Plan 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 that will then
form part of the site-specific developer requirements. 
Existing Forestry, Woodland, and Trees within Perth and Kinross
National Forest Inventory (NFI),
Native Woodland Survey of Scotland (NWSS),
Ancient Woodland Inventory (AWI),
Ancient Tree Inventory (ATI),
Scotland’s National Forests and Land (SE Web), and
PKC Interactive Heritage Map
Historic Environment Scotland’s Portal
The above-mentioned data sources are important resources in
understanding the current types and distribution of our existing woodland,
forest and tree assets across the Perth and Kinross Council Area.  This
information will be incredibly useful for our Forestry, Woodlands and Trees
spatial framework, the protection and enhancement of our existing assets,
and helping Scotland reach national tree planting targets by directing the
planting of the right trees in the right places.   
Gaps, Uncertainties or Key Issues Raised: 
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 scale
woodlands, tree belts and hedgerows may be omitted.  More detail on the
limitations of specific datasets is outlined below.   
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.

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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.   
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. 
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
National scale Land Capability for Forestry Map
This Land Capability for Forestry Map dataset provides information on the
potential for land across Scotland to grow trees.  This is incredibly useful
for our Forestry, Woodlands and Trees spatial framework and our LDP3
Spatial Strategy, helping Scotland reach national tree planting targets by
directing the planting of the right trees in the right places.  
By comparing the NFI, NWSS, AWI and ATI spatial data and our FWS
Opportunities Map, we can see that the planting of trees to date
corresponds well with those areas identified under the National scale Land
Capability for Forestry Map with potential to grow trees.  However, there is
likely to be scope to further focus and refine our FWS Spatial Framework to
further expand, protect and enhance forests and woodlands across Perth
and Kinross, including increase their resilience to the effects of a changing
climate; help reverse biodiversity loss, and at the same time deliver
multiple benefits (environmental, economic, and health and wellbeing) for
the people of the area and beyond.

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Nature Scot, Carbon and Peatland Map (2016)
NPF4 Policy 5: Soils refers, and has policy/spatial implications in relation to,
carbon-rich soils and peatland.  This dataset will help direct the Plan’s
Spatial Strategy away from the area’s most important soils and help
identify areas for safeguarding from inappropriate development (including
tree planting), as well as locations for potential restoration projects. It will
also directly inform the implementation of NPF4 Policy 5 in the decision-
making process.
Scottish Forestry Map Viewer, Scottish Forestry Public Register, PKC
Forestry and Woodland Strategy, and JHI Carbon Sequestration Study of
the Perth and Kinross Area
The information contained in the Scottish Forestry Map Viewer, our
existing Forest and Woodland Strategy, and the JHI Carbon Sequestration
Study commissioned for the Perth and Kinross Area, can support both the
development of our Spatial Strategy in terms of forestry, woodland, and
trees as well as the assessment of development proposals against relevant
policies including NPF4 Policy 6.  The information on the Public Register
will help us in targeting our engagement with landowners and managers in
the development of our Spatial Strategy. 
NPF4 and a range of other Scottish Government policy and guidance
identify forests, woodland, and trees as key assets to be protected and
expanded.  As such, the issues that have been identified to inform the site
selection process are the presence of existing forests, woodland and trees
and the opportunities to enhance and expand woodland coverage and
nature networks. 
Proposals in woodland should only be supported where there are clearly
defined additional public benefits, mitigation is demonstrated, and
compensation is proposed.
During site selection, proposals that aim to enhance and expand existing
forests, woodland, and trees and, by tree planting, enhance nature
networks should be supported, particularly where these prioritise
opportunities to improve and strengthen existing woodland fragments.
Through the development of our Proposed Plan, site selection should seek
to avoid pure woodland sites and consideration given to applying TPOs to
sites with significant trees or groups of trees when identified in the LDP.
By considering the existing forestry, woodland, and trees assets in our
area, as well as identifying potential opportunities for enhancement and
expansion via our LDP3 Spatial Strategy, we can help tackle the twin
climate and nature crises.   In developing our Spatial Strategy,
consideration will also need to be given to competing demands on our
land, such as where opportunities for tree and woodland planting overlaps
with our prime agricultural land resource, and where the greatest potential
exists for carbon sequestration through planting, to ensure we are
directing different land uses to the most appropriate locations to achieve
sustainable development and maximise benefits.   
Gaps, Uncertainties or Key Issues Raised: 
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

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National Planning Framework 4.  It is not anticipated that this review will
lead to significant changes 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.
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.

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Summary of Stakeholder Engagement:
Consultation on Perth and Kinross Council’s Draft Climate Emergency
Report and Action Plan (2019)
Public engagement took place from October 2020 through to January 2021
on the Council’s draft Climate Emergency Report and Action Plan (2019). 
The engagement exercise consisted of an online survey split into five series
of questionnaires and several thematic online sessions.  It was initially
scheduled to take place in early 2020 but was delayed due to the pandemic
outbreak and the Council’s emergency response to it.
The engagement survey received 480 responses while an approximate of
280 attendees took part to the online sessions. The feedback received
throughout the engagement survey was considered in the development of
the finalised Climate Change Strategy and Action Plan.
Participants were asked their views under the Land Use theme of the
survey on a range of topics, including biodiversity, greenspaces, open
spaces, planning controls, agriculture, and other land uses.  There were 67
responses overall to this theme.  
Feedback from the public was that it is their perception that current
policies are not enforced rigorously enough, which leads to tree and
biodiversity loss.   In response, the Council’s ‘Enforcement Charter’ has
recently been reviewed, and part of that review it was considered whether
appropriate priority is given to cases impacting on Perth and Kinross
Council priorities, such as climate change, trees affected by tree
preservation orders, and biodiversity.  A monitoring exercise will also be
conducted as part of the development of the new Local Development Plan
3 to assess the effectiveness of planning policies and planning conditions,
keeping in mind that for the most part, current LDP2 policies have been
superseded by national policies contained in NPF4.
A further, focused consultation and engagement process will be
undertaken in the future to help inform the development of the Council’s
review of our Forestry and Woodland Strategy.
Climate Action Plan – Priorities Review
During October 2024, workshop sessions were held with our Elected
Members and the Perth and Kinross Climate Commission.  The purpose of
these workshops was to review the Council’s current top priority
projects/actions for climate change (as identified in the Council’s Action
Plan).  The outcome of the sessions was an overall agreement to roll over
the existing ongoing Top 15 projects as well as add a further 10 actions to
the list of priorities.   The review and revision of the Council’s Forest and
Woodland Strategy for incorporation within LDP3 was identified as one of
the Top 25 Actions for the year ahead.  
Perth and Kinross LDP3 Big Place Conversation
The Council carried out its LDP3 ‘Big Place Conversation’ exercise during
most of 2023.  The exercise involved over 100 events across the Council
Area, and ranged from drop-in information sessions, meetings, and online
surveys to in person and online workshops sessions using the Place
Standard Tool.

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In relation to forestry, woodlands and trees there were a small number of
comments under the ‘Natural Spaces’ Place Standard theme, which
included the recognition that scenic landscapes in Perth and Kinross,
including woodlands, are highly valued for their beauty and ecological
significance.  Some participants also suggested the use of tree planting to
enhance biodiversity and naturalness in both urban and rural areas.  
Perth and Kinross Council’s Tay Forest National Park Bid and Consultation
Analysis report 
Consultation events were carried out as part of the development of the
Council’s Tay Forest National Park bid.  The consultation period ran for 8
weeks from 6th October to 1st December 2023.  A variety of engagement
methods were used and comprised a launch event, an online survey, five
community drop-in events, two targeted workshops for land managers and
environmental organisations, an online webinar and an in-person Q&A
session.  162 people attended the drop-in events in Dunkeld, Pitlochry,
Comrie, Aberfeldy and Crieff, where staff from PKC and Land Use
Consultants (LUC) were available to answer questions and record verbal
feedback.  Attendees were also able to record additional feedback on post-
it notes and were encouraged to participate in the online survey. 
The focused land manager event, held in Pitlochry (organised in
consultation with National Farmers Union Scotland and Scottish Land and
Estates and promoted to their members), was attended by around 40 land
managers.  The ‘Nature Voices’ online workshop was attended by 24
representatives, from 19 environmental organisations. 
The Consultation Analysis Report was produced by LUC.  In terms of key
points for consideration in the bid preparation, most respondents
considered trees and woodland as being one of the top special qualities of
the area, along with nature and wildlife, lochs/rivers, and scenery.  
Participants recognised the importance of encouraging the right type of
trees and woodland in the right place, and in particular in relation to
supporting sustainable farming and an integrated approach to land
management.  Encouragement of natural regeneration was also
highlighted as being important.  The associated benefits from trees and
woodland in relation to natural flood management was also
acknowledged. 
Perth and Kinross LDP3 Evidence Report Topic Papers
As previously highlighted elsewhere in this Evidence Report, the Council
produced and consulted on a series of Topic Papers which covered the
individual subject matters of NPF4’s National Planning Policies suite and
set out in detail the evidence the Council has gathered to help produce our
Evidence Report, and which we hope to use to prepare our LDP3 Proposed
Plan.  The papers were published for a 6 week period during July and
August 2024 during which time we welcomed the views of our key
stakeholders (who were contacted specifically via email regarding the
consultation exercise) and 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

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51 
included, alongside an explanation of why they considered any additional
sources of information to be relevant to the preparation of the Local
Development Plan.  The responses received on Topic Paper 007: Forestry,
Woodland and Trees, and how the Council has taken those responses into
account through the production of this Evidence Report are set out in the
‘Statements of Agreement/Dispute’ section to follow.
How the views expressed have been taken account of in the
Evidence Report?
The feedback received through the engagement on the Council’s Draft
Climate Change Strategy and Action Plan was used to refine the Strategy
and the list of actions contained within the final Action Plan.  The contents
of those documents, as well as the implications anticipated for the
Proposed Plan have been summarised under the ‘Tackling the Climate and
Nature Crises’ issue of this Evidence Report.  Those Top 25 Climate Action
Priorities identified at the most recent workshops held with Elected
Members and the Perth and Kinross Climate Commission which are
relevant to the Development Plan have been highlighted within this
Evidence Report as being relevant to the development of our LDP3 Spatial
Strategy, and where deemed appropriate local policy responses will be
developed, to help support their delivery.  It is worth noting that many of
the priority Land Use theme actions are statutory land use planning
requirements including the review of our Forestry and Woodland Strategy.   
The BPC exercise has given us an up-to-date awareness of the primary
concerns of our communities about their places, and by bringing the
results of the Place Standard sessions together we have a better
understanding not just about issues within specific settlements, or
localities, but a holistic overview of the Perth and Kinross Area as a whole.  
It has also helped to ensure that across the various policy issues included
within this Evidence Report the available evidence we have gathered is
appropriate and relevant to the concerns raised by our communities,
which in turn will ensure that the development of our Spatial Strategy
considers those concerns.  Although not many participants specifically
raised the subject of forestry, woodland and trees through the BPC
exercise, there was an overall sense that people value the important
contribution that trees and woodlands make to the landscapes of Perth
and Kinross, and that tree planting in both urban and rural areas could help
improve the look of our places and create more spaces for biodiversity. 
These benefits have already been reflected in this Evidence Report through
the summary of evidence provided for the Forestry, Woodland and Trees
issue.
The feedback provided as part of the Tay Forest National Park Bid
consultation events was helpful in confirming how much communities
value trees and woodlands, and how they view their contribution to
making the special qualities of the Perth and Kinross Area.  The comments
raised by participants in terms of the importance of planting the right tree
in the right place, particularly in relation to aiding sustainable farming,
integrated land management, and natural flood management solutions
supports the Scottish Forestry guidance and the UK Forestry Standard
evidence already reviewed under this issue.

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Statements of Agreement/ 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.   A summary of these comments, their status, and the Council’s response are provided in the table below.   
There was 1 response on the Forestry, Woodland and Trees issue which the respondent wished to be treated as a formal dispute to the Evidence Report (this
has been highlighted in red in the table), 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 (these have been highlighted in amber in the table). 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Anonymous Disagree – but
does not wish to
register as a
formal dispute
List of Evidence/Datasets: No comments made. 
Summary of Implications for Proposed Plan (PP): The
respondent indicated that they disagree with the summary
of implications of the Evidence for the Proposed Plan as
provided under Topic Paper 007 for the following reasons:
• Consistent with their responses on other topic papers,
they consider that addressing the challenges and
opportunities presented by climate change and the
transition to net zero, demographic changes
(particularly an elderly population), and the housing
market, require new approaches to policy development
and implementation, which may run counter to
previous strategies, often as a result of locational issues
and new innovations.
• Ensure new woodland creation schemes are not
constrained by previous policy approaches towards
protecting agricultural land, but rather assessed on
their merits (including skills development), impact and
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• PKC does not disagree with the suggestion that
addressing the challenges and opportunities
presented by climate change etc. will require
new approaches and will develop our LDP3
Spatial Strategy in alignment with the suite of
National Planning Policies contained within
NPF4, and other relevant national guidance,
including ‘The Right Tree in the Right Place:
Planning for Forestry and Woodland’. 
• Local authorities have a limited remit in
decision-making for new woodland creation
schemes, this process is regulated by Scottish
Forestry.  However, through the Council’s
existing Forest and Woodland Strategy (FWS),
and in the future review, PKC encourages the
creation of new and expansion of existing
woodlands in the right place to support a

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53 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
mitigation, and set against the changing market and
policy landscape for food production.
• In terms of development within woodland, LDP3 should
cover locational factors including, but not restricted to
high levels of rural deprivation linked to access to
quality and affordable homes, employment space, and
transport services (Topic boxes 3 and 4, and paragraph
2.31).
Further Comments: No further comments made.  
Formal Dispute: The respondent does not wish for their
comments to be registered as a formal dispute. 
range of themes in line with the National
Forestry Strategy.  PKC’s FWS identifies
preferred and potential areas for future
planting to meet the objectives of the national
strategy and UK Forestry Standards and its
Guidelines. 
• Box 3 of Topic Paper 007 provides a summary
of the importance of the ‘Land Capability for
Forestry Map’ to LDP3 as it gives us
information on the potential for land to grow
trees, and Box 4 reflects on the importance of
the information contained in Scottish
Forestry’s Map Viewer, the PKC FWS, and the
James Hutton Institute Carbon Sequestration
Study of the Perth and Kinross Council Area, as
evidence for the development of LDP3 in
respect of forestry, woodlands and trees. 
Paragraph 2.31 repeats NPF4 Policy 6, in terms
of development not being supported where it
results in any loss of ancient woodlands,
ancient and veteran trees, or adverse impact
on their ecological condition, or on native
woodlands, hedgerows, and individual trees of
high biodiversity value, or identified for
protection in the FWS.   Our LDP3 Spatial
Strategy will direct development to the most
sustainable locations taking account of the
policy outcomes and intent of NPF4’s National
Planning Policies, and any key policy
connections between them.  For individual
proposals for development within woodland,

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54 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
they will be assessed via the development
management process on a case-by-case basis
applying the relevant suite of planning policies. 
No action required for this Evidence Report. 
Anonymous Disagree – but
does not wish to
register as a
formal dispute
List of Evidence/Datasets:  The respondent indicated that
they strongly disagreed with the list of evidence and
datasets provided under Topic Paper 007.  They commented
that for PKC to have a coherent strategy on woodland
expansion in the county then a policy on deer control is
essential.  The evidence of problems pertaining to woodland
expansion and excessive deer numbers needs to be in this
document, and Nature Scot should be able to provide this
data.  They continue that it is also necessary to carefully
separate targets for broadleaves against a continued
expansion of monocultural coniferous forestry in the county. 
Public opinion is very much in favour of the expansion of
broadleaves, and this needs to be reflected in the evidence
provided here.  PKC should have a policy of objecting to the
expansion of coniferous forestry on biodiversity and
landscape grounds.
Summary of Implications for Proposed Plan (PP): The
respondent indicated that they strongly disagree with
summary of implications of the evidence under Topic Paper
007, for the Proposed Plan, for the reason that this evidence
seems to suggest that PKC will blindly approve commercial
forestry expansion as it has always been.  This is not
consistent with PKC’s biodiversity strategy.
Further Comments: Under the further comments section of
the consultation questionnaire, the respondent comments
that the land capability maps are “woefully inadequate”. 
PKC welcomes the respondent’s comments and
responds to the points raised within as follows:
• Local authorities do not have a legislative
responsibility to develop and implement a
policy on deer control.  Nature Scot has a legal
responsibility for the conservation, control and
sustainable management of all wild deer
species in Scotland.  The management of deer
populations in Scotland has a long-standing
tradition of a voluntary and collaborative
approach between local communities, land
managers and partners.  The independent
‘Deer Working Group’, appointed by the
Scottish Ministers, recommended in their
report to the Minsters changes to ensure
effective deer management in Scotland that
safeguards public interests and promotes the
sustainable management of wild deer.  In
response, the Scottish Government set up the
Strategic Deer Management Board bringing
together key agencies to co-ordinate, lead and
support deer management work to meet the
ambitions of the Scottish Biodiversity Strategy,
under four workstreams. 
• LDP3 and the FWS review will, in line with NPF4
Policy 6. ‘…identify and set out proposals for

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
They continue that trees (native and exotic) can grow up to
and beyond 600m altitude, and provide ‘Stirling University,
Sarah Watts’ as a reference.  It is the view of the respondent
that reports highlighting this fact need to be in this evidence. 
They continue that there is a strong desire by the public to
achieve woodland expansion via natural seeding and also to
equally value scrubby areas for biodiversity, which they
believe should be commented on in this document.
Formal Dispute: The respondent does not wish for their
comments to be registered as a formal dispute.
forestry, woodland and trees in the area,
including their development, protection and
enhancement, resilience to climate change, and
the expansion of a range of types to provide
multiple benefits.’  The FWS will continue to
identify ‘Preferred’ and ‘Potential’ indicative
areas for future planting, considering a range of
sensitivities, and proposals for woodland
restructuring, creation and expansion will be
assessed on a case-by-case basis taking account
of local sensitivities and constraints, and
criteria a) to d) of NPF4 Policy 6, as well as all
other relevant NPF4 national policies, including
those on Biodiversity and Natural Places.  
• PKC disagrees with the respondent’s comments
that “the evidence seems to suggest that PKC
will blindly approve commercial forestry
expansion as it has always been… [which is] not
consistent with PKC’s biodiversity strategy” and
is unable to identify which part of Topic Paper
007 would suggest this to the respondent. 
• The respondent has not provided a link to
Sarah Watts’ research work.  An online search
suggests they are referring to the PhD research
paper: High mountain trees: altitudinal records
recently broken for eleven different tree
species in Britain | British & Irish Botany which
used citizen science to ‘to document
observations of trees growing in Britain above
900 metres.’  An abstract of the paper provided

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56 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
on the Botanical Society of Britain and Ireland
Society’s archives acknowledges that ‘although
these findings are currently too restricted to
draw broad conclusions on the impacts of
climate warming and land management on tree
colonisation in mountain environments, long-
term data collection may allow an analysis of
drivers of change in the future.’  The research
project considered woodland and montane
scrub on Highland hilltop habitats and how
natural treelines can be restored.  Mountain
heaths and willow scrub, along with blanket
bog are priority habitats on the Scottish
Biodiversity List and are identified in Tayside
Biodiversity Action Plan, under the ‘Upland
Ecosystems’ section, with associated actions
for: restoring species populations and genetic
diversity; reducing pressures on biodiversity,
and investigating and supporting projects and
policy which create more native woodland and
forest cover, where appropriate.  These actions
will be reflected through our LDP3 and our FWS
review.  Those documents will also align with
NPF4 Policy 3: Biodiversity which states that
‘LDPs should protect, conserve, restore and
enhance biodiversity in line with the mitigation
hierarchy…[and] promote nature recovery and
nature restoration across the development plan
area…’.  Furthermore, NPF4 Policy 6: Forestry,
woodland and trees lends support to proposals
that enhance, expand and improve woodland

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
and tree cover, providing they meet criteria a)
to d).  
No action required for this Evidence Report. 
Earn Community
Council
Agree List of Evidence/Datasets: Agree
Summary of Implications for Proposed Plan (PP):
Respondent comments that they agree with the summary of
implications provided under Topic Paper 007: Forestry,
Woodland and Trees.
Further Comments: The respondent further comments that
the section is well laid out and information detailed easy to
understand, with the knowledge gaps understandable.
Formal Dispute: Not applicable.
PKC welcome’s the comments submitted by Earn
Community Council respect of the summary of
evidence and implications for the Proposed Plan
provided within Topic Paper 007: Forestry,
Woodland and Trees.
No action required for this Evidence Report.
Errol Community
Council
Neither List of Evidence/Datasets:  The respondent has indicated
that they neither agree nor disagree with the list of evidence
and data provided under Topic Paper 007 but does not
provide any further comments in respect of this. 
Summary of Implications for Proposed Plan (PP): The
respondent has indicated that they neither agree nor
disagree with the summary of implications of the evidence
for the Proposed Plan provided under Topic Paper 007 but
does not provide any further comments in respect of this. 
Further Comments:  No further comments made.
Formal Dispute: Not applicable. 
No action required for this Evidence Report. 
Gray Planning &
Development Ltd.
(on behalf of GS
Brown Ltd.)
Neither List of Evidence/Datasets:  Respondent has indicated that
they neither agree nor disagree with the evidence provided
under Topic Paper 007 but does not provide any comments
in respect of this. 
PKC welcomes the respondent’s comments and
responds that, whilst the creation of new
woodland and planting of trees in line with NPF4
Policy 6 is generally supported, this should be the
right species in the right place, in line with Scottish

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Summary of Implications for Proposed Plan (PP):
Respondent has indicated that they neither agree nor
disagree with the summary of implications of the evidence
provided under Topic Paper 007.  
Further Comments: Under the further comments field of the
questionnaire, the respondent notes at paragraph 2.33 of
the Topic Paper the comment about the pre-emptive felling
of woodland taking place prior to sites being considered
through the planning process.  The respondent comments
that the Evidence Report might also consider the opposite
proactive approach being taken by landowners (perhaps still
pre-emptive) to re-wood or plant new woodland as key
green infrastructure features for any future land
development for settlement extension, for new housing
development, or both.  They continue that given the key role
that landscape setting, enhancement of biodiversity and
trees, and the provision of blue green infrastructure is going
to be required by NPF4 in terms of cross-cutting policy
outcomes, then landowners and developers should be taking
proactive (and pre-emptive) steps to deliver and implement
woodland strategies as part of long term masterplanning for
their sites and assets. 
Formal Dispute: The respondent does not wish for their
comments to be registered as a formal dispute.
Forestry’s ‘The Right Tree in the Right Place:
Planning for Forestry and Woodlands’ and
following the UK Forestry Standard and its
Guidelines.   
The comprehensive masterplanning of a site,
considering local conditions and sensitivities is
regarded as the best way to achieve this, as
opposed to ad hoc pre-emptive planting to create
new boundaries, which may in turn result in
negative impacts on biodiversity, historic
environment assets, landscape, soils, the water
environment, and/or increase the impacts of
climate change on people, nature and
infrastructure.  
Furthermore, LDP3 will identify site specific
developer requirements for site proposals,
including where tree planting would be beneficial
to the site and/or the surrounding environs.  This
will also help improve nature networks/ecological
connections across the Perth and Kinross Area,
where they have been identified as part of a
coordinated and comprehensive spatial strategy
for improving such networks in line with NPF4
policies 3 and 4.
No action required for this Evidence Report. 
Historic
Environment
Scotland (HES)
Agree List of Evidence/Datasets: The respondent agrees with the
list of evidence and datasets provided under Topic Paper
007: Forestry, Woodland and Trees. 
Summary of Implications for Proposed Plan (PP): The
respondent agrees with the summary of implications of the
PKC welcomes HES’s comments on Topic Paper
007: Forestry, Woodland and Trees.  Whilst sites
on the Inventory of Gardens and Designed
Landscape have been recognised under the
‘Historic Assets and Places’ issue of this Evidence

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59 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
evidence for the Proposed Plan provided under Topic Paper
007.
Further Comments: Under the further comments section of
the consultation questionnaire, HES comments that
Inventory Gardens and Designed Landscapes Gardens are
grounds that are consciously laid out for artistic effect (such
as country estate landscapes, botanic garden collections,
urban parks and cemeteries) and are an important element
of our historic environment and landscape.
They continue that in considering whether or not a garden
and designed landscape is of national importance its cultural
significance is examined under seven headings. Of particular
interest to this topic paper are the headings of nature
conservation interest, horticultural interest and scenic
interest.  Further information on guidance on selection for
the Inventory of Gardens and Designed Landscape can be
found in Historic Environment Scotland’s Designation Policy
and Selection Guidance.
https://portal.historicenvironment.scot/downloads/gardens  
Formal Dispute: Not applicable.
Report for their contribution to the rich historic
environment of Perth and Kinross, the policy
connection between those Inventory sites which
have been designated for nature conservation,
horticultural, and/or scenic reasons and the
‘Forestry, Woodland and Trees’ policy had not
been made in Topic Paper 007.  Considering HES’s
comments, this Evidence Report issue has now
been updated to recognise the importance of such
sites to the evidence base for LDP3 and provide
the summary of level of interest for these criteria
for each of the 41 GDLs Inventory sites within the
Council Area.   Going forward it is expected that
those relevant Inventory sites will also form part
of the spatial strategies for our Forestry and
Woodland Strategy, Nature Networks, and Blue
Green Infrastructure. 
No further action required for this Evidence
Report.
Montagu Evans LLP
(on behalf of Loch
Developments Ltd.)
Neither List of Evidence/Datasets: The respondent neither agrees
nor disagrees with the list of evidence provided under Topic
Paper 007.
Summary of Implications for Proposed Plan (PP):
Respondent neither agrees nor disagrees with summary of
implications of evidence provided in Topic Paper 007. 
Further Comments: No further comments made.
Formal Dispute: Not applicable.
No action required for this Evidence Report.

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60 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Private Individual Dispute List of Evidence/Datasets: The respondent disagrees with
the list of evidence provided under Topic Paper 007.  They
comment that the maps are unreadable online, “so the
consultation is seriously flawed”, and continues that there
appears no joined up thinking between the biodiversity and
housing development.
Summary of Implications for Proposed Plan (PP): The
respondent indicated that they strongly disagree with the
summary of implications of the evidence to the Proposed
Plan provided under Topic Paper 007 as in their view “the
topic paper gives the clear impression that PKC supports
woodlands and biodiversity, however when there is a clash
between development PKC has no hesitation on supporting
the destruction of natural habitat and woodland.  Scone has
seen ancient trees, red squirrel habitat, wildcat habitat
destroyed for CTLR [Cross Tay Link Road] and North Scone
development.  Furthermore, the Murrayshall proposed
development will result in the loss of open greenspace and
impact biodiversity.”
Further Comments:  No further comments made.
Formal Dispute:  The respondent wishes for their comments
to be registered as a formal dispute as in their view Topic
Paper 007 “fails to represent the actual activities of PKC in
the arena.” 
PKC welcomes the respondent’s comments on
Topic Paper 007, and addresses the points raised
within as follows:
• It is recognised that the scale of the maps
presented as images embedded in the topic
paper is not ideal, but PKC would respond that
the purpose of providing the maps was to
demonstrate that we have access to the
relevant datasets in a spatial format, which
were reviewed and summarised as part of the
topic paper and this Evidence Report, rather
than to invite analysis of them at a granular
level for the purposes of location specific
comments, at this stage in the LDP3
preparation process.  However, where
available, hyperlinks were provided throughout
Topic Paper 007 to online interactive versions
of the maps which have zoom functionality to
allow closer scrutiny of the evidence if desired
by consultees. 
• In terms of their comments regarding “joined
up thinking between the biodiversity and
housing development”, PKC would respond that
the key connections between forestry,
woodland and trees and biodiversity (habitats
(including networks) and species) were
highlighted within the topic paper and have
now been further enhanced through suggested
additional sources of data and evidence from
other respondents.  Whilst the subject of

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61 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
forestry, woodland and trees has not been
explicitly linked to housing under Topic Paper
007, the summary of evidence provided does
recognise the multiple benefits that trees can
make to society, including quality of life and
sense of place, and refers to relevant policies,
including NPF4 Policy 6, which apply to the
development of LDP spatial strategies and
development proposals.
• PKC does support tree planting and biodiversity
protection and enhancement in line with
national policy and guidance on the subject,
and this is reflected through relevant LDP2
policies and our Forest and Woodland Strategy. 
Decisions taken on individual planning
application proposals are done so on a case-by-
case basis, considering all relevant matters, and
in line with the development plan unless
material considerations indicate otherwise.
No further action for this Evidence Report. 
Nature Scot Neither List of Evidence/Datasets: The respondent comments that
Map 5 is indicative and difficult to understand.  They
recommend including a graphic which supports practical
application with greater detail and clearer presentation. 
They also recommend that there could be reference to soils
and the need to avoid Class 1 and 2 soils for planting. 
Summary of Implications for Proposed Plan (PP): The
respondent comments that some key issues are poor
condition, fragmentation of existing woodland and ensuring
PKC welcomes Nature Scot’s comments on the
evidence reviewed under Topic Paper 007, and
responds to the points raised in the response as
follows:
• Map 5 of Topic Paper 007 is the ‘Opportunities’
diagrammatic map included within the current
Perth and Kinross Forest and Woodland Strategy
(FWS) and follows the style of the diagrammatic
presentation of information within that

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62 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
new woodlands of the right type and in the right places,
which they do not feel have been adequately addressed
under Topic Paper 007.  They would also welcome greater
emphasis on native woodland creation and connectivity, as
well as messaging about the right places for new planting. 
Furthermore, that the need for management of existing
woodland should also be stronger here given unfavourable
condition.  
Further Comments: No further comments made.
Formal Dispute:  The respondent does not wish for their
response to be registered as a formal dispute.
document.  However, it is underpinned by
clearer, more detailed GIS data, which is used in
the decision-making processes as shown in Map
A4(12) of this Evidence Report.  It is the
intention of PKC to move away from this style of
diagrammatic representation to a more detailed
map base for our FWS review.
• Reference to the importance of protecting Class
1 and 2 soils has been added to the Evidence
Report for the Forestry, Woodland and Trees
issue, along with Nature Scot’s Carbon and
Peatland Map (2016) for Classes 1 and 2. 
However, the ‘Soils’ issue of this Report explores
the subject matter in more detail. 
• The UK Forestry Standard has now been added
to this issue of the Evidence Report, providing a
greater emphasis on the key issues related to
forest and woodland resources, including
condition, fragmentation and loss, native
woodland creation, and sustainable forest
management. 
No further action required for this Evidence
Report. 
Savills (on behalf of
Dupplin Estate)
Neither List of Evidence/Datasets: The respondent indicated that
they neither agree nor disagree with the list of datasets and
evidence presented under Topic Paper 007 and have not
made any further comments in relation to this. 
Summary of Implications for Proposed Plan (PP): The
respondent indicated that they neither agree nor disagree
PKC welcomes the comments submitted by Savills
on behalf of Dupplin Estate.  In the development
of our LDP3 Proposed Plan we will consider
location specific projects and proposals and would
welcome Savills, on behalf of Dupplin Estate, to

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63 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
with the summary of implications of the evidence for the
Proposed Plan provided under Topic Paper 007 and have not
made any further comments in relation to this.
Further Comments:  In response to the further comments
section of the consultation questionnaire, the respondent
provided the following:
Dupplin Estate to the west of Perth is delivering extensive
woodland planting on the urban fringe, to support nature
networks, biodiversity, and carbon reduction. 
Dupplin is working with a number of adjacent landowners to
bring forward the 175 hectare "Perth Sustainability Park" on
the southwestern edge of Perth, which will deliver a new
parkland for the city with extensive tree planting, 
countryside access, renewable energy, natural flood risk
management, community woodland creation, and
potentially some enabling housing. This project will be a
landscape and natural capital led plan with countryside
access, biodiversity enhancement and wellbeing at its heart
as well as energy innovation. This parkland with its
spectacular high level views, will add to the recreational and
tourism assets of the city.  
Trees and woodland play an important role in mitigating
excessive carbon emissions.  It is important to maintain a
diverse habitat within woodland planting both to ensure
forestry remains commercial but also to reduce disease risk
and to provide a diverse woodland habitat.  An over zealous
drive to plant grassland with trees could have a detrimental
impact on landscape with marginal additional benefit on
carbon sequestration.
submit any relevant proposals as part of the LDP3
‘Calls for Ideas’ exercise in the future.
No action required for this Evidence Report.

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64 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Formal Dispute:  The respondent does not wish for their
comments to be registered as a formal dispute.
Savills (on behalf of
Scone Estate)
Neither List of Evidence/Datasets:  No comments made.
Summary of Implications for Proposed Plan (PP): No
comments made.
Further Comments: Under the further comments section of
the consultation questionnaire, the respondent highlighted
that their points raised in relation to the Climate and Nature
Crises Topic Paper also apply to forestry/woodland creation. 
To recap, those comments were that the [Scottish
Government’s] Local Development Planning Guidance states
that plans should be place based, developed in collaboration
and be robust.  They continued that NPF4 then states that
there should be certain climate and biodiversity related
initiatives outlined in LDPs, for example woodland creation. 
The respondent considered that it should be explicitly
recognised that Perth and Kinross landowners are critical to
achieving strategic scale environmental benefits that, in
turn, help achieve LDP aims, which they commented is down
to the scale of available land but also the potential to cluster
such initiatives to maximise benefits.  Furthermore, that
landowners, such as Scone Estate, are increasingly focusing
on integrated land management to better benefit the
environment and increase social value delivery, which they
believe is a “win-win for Perth and Kinross” and as such
should be reference within any final Evidence Report.  
Specifically in response to Topic Paper 007: Forestry,
Woodland and Trees, the respondent comments that Scone
Estate has planted over 318 acres of new woodland and a
PKC welcomes the respondent’s comments and
responds to the issues raised within as follows:
• PKC welcomes hearing about the ongoing work
of estates, like Scone Estate, in creating new
woodland and applying an integrated land
management approach.  Where appropriate,
the LDP3 Spatial Strategy will identify existing
proposals and future opportunities, and would
welcome Savills, on behalf of Scone Estate, to
submit any relevant proposals as part of the
LDP3 ‘Calls for Ideas’ exercise in the future.
• In line with responses provided to similar calls
by Savills, on behalf of Scone Estate, in
submissions on other LDP3 Topic Papers, for
the contribution of landowners to be explicitly
recognised by PKC as critical to achieving
strategic scale environmental benefits, PKC
responds that the development of our LDP3
Spatial Strategy and the narrative contained
within the Plan (both in discussing the overall
spatial strategy and location specific matters)
will recognise the need to follow the Scottish
Government’s Creating Places and Designing
Streets policy statements, and the Scottish
Government and COSLA’s Place Principle to
promote and develop a shared understanding
of place, and the need for communities, public
organisations, businesses and other key

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65 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
further 758 acres of mixed-use land that will be actively
managed wader habitat, assisting the Council with delivering
on its sustainability and biodiversity targets.  It is the
respondent’s view that estates, such as Scone, are well
positioned to deliver significant landscape scale projects
which can make a huge difference to carbon sequestration,
natural flood risk alleviation, protection of endangered
species, and biodiversity enhancement across Perthshire.  
They further comment on the reference on page 23,
paragraph 2.33 of Topic Paper 007 onwards to the need to
protect existing woodland, that there also needs to be
discretion, flexibility and a balanced approach to applying
policies of NPF4 to ensure that developments which are
beneficial in other ways are given due recognition, even if
there is a need for some tree loss.  They highlight the
content of the Chief Planner’s letter of 8 February 2023 on
‘Transitional Arrangements for National Planning Framework
4’ (NPF4) that NPF4 is designed to be “read and applied as a
whole” and “factors for and against developed will be
weighed up in a balance of planning judgement”. 
Formal Dispute:  The respondent does not wish for their
comments to be registered as a formal dispute.
stakeholders, including landowners, to work
together to achieve high quality successful
places, and better outcomes for people,
communities and nature.   Nationally land use
planning recognises the importance of working
collaboratively across all users and sectors to
create sustainable and successful places. 
Although landowners are not a legislatively
prescribed key stakeholder, they are widely
recognised as being an integral part of the
development planning process, through the
identification and implementation of
deliverable development opportunities which
can contribute to the achievement of multiple
benefits and wider outcomes for places,
communities and nature.  Our LDP3
development process will seek to continue to
work with key stakeholders across the Perth
and Kinross Area, including landowners and
their agents, to deliver sustainable, liveable and
productive places for now and the future, as
per our Development Plan Scheme and
Participation Statement.
• In response to the suggested need for
discretion, flexibility and a balanced approach
to applying NPF4 policies, PKC will continue to
read and apply NPF4 and its suite of national
planning policies as a whole, taking account of
all relevant considerations, based on the
location and details of the proposal.

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66 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
No action required for this Evidence Report.
Scottish Water Agree List of Evidence/Datasets: The respondent agrees with the
list of datasets and evidence presented under Topic Paper
007.
Summary of Implications for Proposed Plan (PP): The
respondent agrees with the summary of implications of the
evidence for the Proposed Plan set out under Topic Paper
007. 
Further Comments: Under the further comments section of
the consultation questionnaire, the respondent comments
that they are supportive of the Council’s Topic Paper 007:
Forestry, Woodland and Trees, and highlight that it should
be noted that forestry management activities must be
controlled and managed appropriately, as these works can
have a significant negative impact to soil and water
environments if not conducted properly – such as increasing
flood risk from run-off water.
Scottish Water further comments that they welcome early
consultation with their Sustainable Land Management Team
(protectdwsources@scottishwater.co.uk) to determine the
location of ‘Drinking Water Protected Areas’ as well as water
and/or wastewater infrastructure within the area of forestry
activities.  If Scottish Water drinking water source
catchments or assets are located within the area of forestry
activities, then adequate protection is required.  The
respondent would request that all activities are in
accordance with Forests and Water UK Forestry Standard
PKC welcomes Scottish Water’s comments and
responds to the points raised as follows:  
• The UK Forestry Standard has now been added
to this issue of the Evidence Report, providing a
greater emphasis on the key issues related to
forest and woodland resources, including
condition, fragmentation and loss, native
woodland creation, and the need for sustainable
forest management and design to avoid impacts
on soil and water environments.  The Council’s
adopted Forest and Woodland Strategy (FWS)
encourages compliance with the UK Forestry
Standard, and this message will continue into
the review of our FWS.   
• Whilst the Strategic Environmental Assessment
(SEA) for the adopted FWS took an ecosystem
services approach based on water catchments
areas, looking at existing identified pressures on
those catchments in SEPA’s Water Classification
Hub, it did not incorporate or consider ‘Drinking
Water Protected Areas’ within those areas
identified as being ‘preferred’ and ‘potential’ for
woodland expansion.  We welcome Scottish
Water flagging this dataset and have included
the spatial data as part of this issue for the
Evidence Report, it will also form part of the

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67 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Guidelines.  They also provide a link to the section of their
website where further advice and the list of precautions that
should be taken to protect assets can be found. 
(https://www.scottishwater.co.uk/About-Us/Energy-and-
Sustainability/Sustainable-Land-Management/Activities-
within-Our-Catchments)
Formal Dispute:  Not applicable. 
environmental baseline for our LDP3 SEA, and
the FWS review, and has key policy connections
with some of our Infrastructure issues
(Infrastructure First and Waste Water Treatment
and Water Supply).  The ground and surface
Drinking Water Protected Areas will also be
incorporated into the ‘Site Assessment’ exercise
for the consideration of site proposals for
inclusion in the Proposed Plan, and PKC will
liaise with Scottish Water regarding the
outcomes of that exercise to identify likely site-
specific developer requirements. 
No further action required for this Evidence
Report.
SSEN Transmission Agree, but with
suggestions
regarding policy
interpretation in
practice.
List of Evidence/Datasets: The respondent agrees with the
list of datasets and evidence presented under Topic Paper
007: Forestry, Woodland and Trees. 
Summary of Implications for Proposed Plan (PP):  The
respondent indicated that they agree with the summary of
implications of the evidence for the Proposed Plan provided
under Topic Paper 007.
Further Comments:  Under the further comments section of
the consultation questionnaire, the respondent suggests
that points A to D of NPF4 Policy 6 should not be taken or
quoted in isolation.  They continue that in particular Policy 6
b) i) regarding development which will result in the loss of
ancient woodlands, ancient and veteran trees, or adverse
impacts on their ecological condition, and/or adverse
impacts on native woodlands, hedgerows, and individual
trees of high biodiversity value, or identified for protection
PKC welcomes SSEN Transmission’s comments and
would respond that the Council will continue to
read and apply NPF4 and its suite of national
planning policies as a whole, taking account of all
relevant considerations, based on the location and
details of the proposal.  Decisions taken on
individual planning application proposals are done
so on a case-by-case basis, considering all relevant
matters, and in line with the development plan
unless material considerations indicate otherwise.
No action required for this Evidence Report.

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68 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
in the Forestry and Woodland Strategy; as it is the
respondent’s view that this should also take cognisance of
NPF4 Policy 6 criteria c) regarding “Development proposals
involving woodland removal will only be supported where
they will achieve significant and clearly defined additional
public benefits in accordance with relevant Scottish
Government policy on woodland removal.  Where woodland
is removed, compensatory planting will most likely be
expected to be delivered.”  The respondent continues that
whilst the aforementioned point is recognised in paragraph
2.35 of Topic Paper 007, it is their view that there should be
clearer link between the two parts highlighted from Policy 6
in NFP4 in the topic paper and recognition that these two
statements should be considered together.   They then
provide as an example, for national infrastructure or large
scale developments such as development of electricity
transmission infrastructure there will in many cases be
unavoidable impact on ancient woodland or other native
woodland from such linear developments. The balance of
public and environmental benefit must be considered in
each case though we agree there should be a general
presumption against supporting removal of highlighted
woodland types in most cases.
Formal Dispute:  The respondent does not wish for their
comments to be registered as a formal dispute.

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69

Page 193

Issue: Historic Assets and Places
Corresponding NPF4 Policy/Policies:
• National Planning Framework 4, Policy 7: Historic assets and places
• Other key NPF4 policy connections – 1: Tackling the climate and
nature crises, 2: Climate mitigation and adaptation, 4: Natural places,
6: Forestry, woodland and trees, 9: Brownfield, vacant and derelict
land and empty buildings, 10: Coastal development, 11: Energy,
14:Design, quality and place, 15: Local living and 20 minute
neighbourhoods, 16: Quality homes, 17: Rural homes, 18:
Infrastructure first, 20: Blue and green infrastructure, 22: Flood risk
and water management, 24: Digital infrastructure, 25: Community
wealth building, 27: City, town, local and commercial centres, 29:
Rural development, 30: Tourism, and 31: Culture and creativity.
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 008: Historic Assets and Places
(https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume
nts/TP008_HistoricAssetsandPlaces.pdf) 
Information required by the Act and NPF4 regarding the topic:
Section 15(5) of The Town and Country Planning (Scotland) Act 1997, as
amended: 
• The principal built heritage characteristics of the district.
Policy 7 of NPF4 expects the following from LDPs:
• LDPs, including through their spatial strategies, should support the
sustainable management of the historic environment.  
• They should identify, protect, and enhance valued historic assets and
places.
The policy intent for NPF4 Policy 7 is noted as:
• To protect and enhance historic environment assets and places, and
to enable positive change as a catalyst for the regeneration of places.
The policy outcomes for Policy 7 are:
• The historic environment is valued, protected, and enhanced,
supporting the transition to net zero and ensuring assets are resilient
to current and future impacts of climate change.
• Redundant or neglected historic buildings are brought back into
sustainable and productive uses.
• Recognise the social, environmental, and economic value of the
historic environment, to our economy and cultural identity
The Scottish Government’s Local Development Plan Guidance (May 2023)
under it’s ‘Step by step guide’ provides advice on relevant evidence for the
NPF4 policy topics to help planning authorities in considering the national
planning policies when preparing their Evidence Report.  With respect to
NPF4 Policy 7, the Guidance advises that planning authorities are expected
to take into account the locations of international and national
designations, including Scheduled Monuments; Category A Listed
Buildings; Inventory Gardens and Designed Landscapes; Inventory
Battlefield sites; and World Heritage Sites.  The locations of regional and
local designations such also be considered i.e., Category B and C Listed
Buildings; Conservation Areas; locally important Gardens and Designed
Landscapes; archaeological sites, and buildings and other historic assets

Page 194

which communities have identified in Local Place Plans to be of particular
significance.
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
• PKC Interactive Heritage Map
• Scottish Government Transforming Planning - Permitted Development
• Historic Environment Scotland’s Portal - Listed Buildings
• Buildings at Risk Register for Scotland
• PKC Historic Environment Record (HER)
• Historic Environment Scotland CANMORE record on ‘agricultural
cropmark’ sites – Perth & Kinross Council
Other Relevant Sources of Information
• PKC LDP3 Big Place Conversation
• Perth and Kinross LDP2 Design Charettes
• PKC 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.

Page 195

Summary of Evidence:
Perth and Kinross Council Corporate Plan 2022-2027 
Our Local Development Plan 3 (LDP3) will be prepared within the context
of the Council’s Corporate Plan, which sets out the Council’s vision for a
Perth and Kinross ‘where everyone can live life well, free from poverty and
inequality.’  It proposes a number of key priorities for the 5-year period
2022 to 2027.  It also reflects the principles of the Perth and Kinross Offer.   
The Corporate Plan identifies 7 priority areas which the Council feels it can
directly influence and have the most impact upon, and those which are
most important to delivering the Vision for Perth and Kinross.  
Delivery of the Corporate Plan’s Priorities will be underpinned by a set of
Key Principles and delivered through a range of Key Actions.  
Relevant Historic Environment Policies, Advice and Guidance
Our Past, Our Future: The Strategy for Scotland's Historic Environment
2023
This is the most recent national strategy superseding the previous Our
Place in Time (2014) document.  It sets out a national mission ‘to sustain
and enhance the benefits of Scotland’s historic environment, for people
and communities now and into the future.’  
The Strategy contains 3 Priorities and 6 Principles.  The Strategy’s Priorities
are:
1. Delivering the transition to net zero
2. Empowering resilient and inclusive communities and places
3. Building a wellbeing economy 
The Strategy’s Principles are:
1. We must put people at the heart of this strategy.
2. We must act on the climate and biodiversity crises.
3. We must protect and promote our historic environment.
4. We must work collaboratively across sectors.
5. We must work together to make good decisions.
6. We must nurture and grow an inclusive, diverse, and skilled
workforce.
The introduction to the Strategy on page 6 of the document recognises
that it has been developed at a time of ‘considerable change and
challenge’, due to issues around the after-effects of the Covid-19
Pandemic, rising costs for fuel and materials, an acute shortage of key
skills, and the negative effects of a changing climate.  These issues and
more require collaborative working across policy themes, sectors, and
groups (including our communities), as well as across national boundaries
in order to achieve the Strategy’s mission statement. 
Historic Environment Policy for Scotland (HEPS) 2019
HEPS is a policy statement which was produced by Historic Environment
Scotland for decision making for all of the historic environment.  It contains
6 policies which define how the historic environment should be managed.
It is a non-statutory policy statement, designed to support good decision
making, which means that it is not a legislative requirement to follow it,
but it should be taken into account whenever a decision will affect the
historic environment.   It is supported by detailed policy and guidance and
is a material consideration for planning proposals that might affect the
historic environment, and in relation to listed building and scheduled
monument consents.

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The policy statement contains a series of principles and policies for the
‘recognition, care and sustainable management of the historic
environment [and] …promotes a way of understanding the value of the
historic environment which is inclusive and recognises different views.’  
HEPS encourages ‘consistent, integrated management and decision making
to support positive outcomes for the people of Scotland.  It also supports
everyone’s participation in decisions that affect the historic environment.’
Managing Change in the Historic Environment Series
Historic Environment Scotland produced a series of guidance notes related
to ‘Managing Change in the Historic Environment'.  Each guidance note
looks at a different theme in respect of the key issues that might arise;
how to best deal with any such issues, and the rationale behind the advice. 
They are regularly reviewed and updated where relevant, following a
period of public consultation. 
Historic Environment Scotland Talking About Heritage Guide (2022)
The aim of the 2022 guide is ‘to help strike up a conversation about
heritage’ or to assist people to have their views heard as part of an
ongoing discussion.   The guide supports people to:
• Investigate Heritage – providing tips and tools around 4 broad areas
of interest1 to find out more about the heritage that matters to
people.
• Understand What’s Special About Heritage – a guide to considering
why heritage is important and what makes it special, including
considering cultural significance. 
1 Places, Buildings, Archaeological Sites and Landscapes; Habitat, Biodiversity and
Landform; People, Families and Communities, and Traditions, Stories, Songs and
Language.
• Share and Celebrate Heritage – examples of how to share with
others the heritage that is important to people.
• Protect and Care for Heritage – provides ideas and information on
how to recognise and care for heritage, including - using historic
environment registers; recognising heritage that matters to
individuals and communities; engaging with the planning system, and
looking after heritage.
Historic Environment Scotland Circular: Regulations and Procedures
The Circular was published in 2019 and covers the requirements of
secondary legislation (‘the Regulations’) relating to a number of pieces of
primary legislation on Scotland’s historic environment.  It also sets out the
processes identified in the Regulations in respect of Historic Environment
Scotland’s (HES) functions, including those in relation to their role in the
planning system and procedures for consulting them.
Guidance for Peatland Restoration and the Historic Environment in
Scotland
This Association of Local Government Archaeological Officers (ALGAO)
Guidance was written by Bruce Mann in 2022.  It aims to provide an
informed procedure to help safeguard the protection of heritage and
historic environment features which are located within peatland
restoration project sites in Scotland. 
Historic Land Use Assessment
Historic Environment Scotland’s Historic Land Use Assessment (HLA)

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Historic Environment Scotland’s Historic Land Use Assessment shows the
extent of changes that have occurred to the environment of the Perth and
Kinross Area over time.
The HLA 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.  The figures to follow show the HLA
coverage available for Perth and Kinross and main classification categories,
and Table 1 provides a breakdown of the key historic land uses across the
area.  
A clear distinction can be seen in Map 1 between moorland and rough
grazing, and woodland and forestry in the upland area, and agriculture in
the lowland areas. Map 2 shows that the land uses in existence since the
18th and 19th centuries to present day are mostly what is now evident on
the ground across the parts of Perth and Kinross which have been
assessed.  However, there is still some remaining evidence of Medieval
Towns scattered across the area at Abernethy, Alyth, Auchterarder, Coupar
Angus, Crieff, Dunkeld, Dunning, Errol, Longforgan, Meigle, Perth, and
Rattray. 
Table 1: Key Historic Land Use within Perth and Kinross
Historic Land Use Category Area (Km2)
Woodland & Forestry 806.6
Agriculture and Settlement 760.9
Moorland & Rough Land Grazing 503.7
Waterbody 87.0
Designed Landscapes 59.4
Built Up Area 45.5
Leisure & Recreation 33.9
Defence 19.1
Energy Extraction and waste 12.8
Rural Settlement 4.3
Transport 3.2
Spiritual & Ritual 0.4

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Map 1: Historic Land Use Assessment for the Perth and Kinross Area (Land Uses/ Function)

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Map 2: Historic Land Use Assessment for the Perth and Kinross Area (Time Periods)

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Perth and Kinross Heritage Trust (PKHT)
Perth City Heritage Fund (PCHF)
Since Perth regained its city status in 2012, Perth and Kinross Heritage
Trust have been actively encouraging the conservation of the city’s historic
buildings via the Perth City Heritage Fund (PCHF) scheme.  The aim of the
fund is to ‘encourage sustainable economic and social recovery within the
Perth Central and Kinnoull Conservation Areas by grant-assisting owners of
historic buildings with the costs of high-quality repairs to their homes using
traditional materials and best conservation practice.’  The Trust’s grant
programme particularly encourages applications for repairs to historic
tenements in multiple ownership; repairs to historic buildings used or
owned by local charities, and unused or underused historic buildings to
bring them back into active use.   The scheme also offers small grants to
help building owners repair their buildings in a range of different ways,
such as repairing sash and case windows, and roof and masonry repairs.
Community Heritage Grants Scheme.
PKHT also support communities across Perth and Kinross to conserve and
enhance the historic environment through their Community Heritage
Grants Scheme.   The scheme was launched in May 2021, initially
committed over £70,000 towards local heritage initiatives, but with a
further £70,000 made available in the fund it is hoped that it will support
more projects.  Proposals which fall into the following categories will be
considered by the Trust for financial support:
• Conservation of historic buildings or monuments in Perth and Kinross
that have established and generally unhindered public access.
• Community based recording, research, and interpretation of the
historic environment in Perth and Kinross. 
Completed PKHT Projects
The Trust has also delivered a number of projects in partnership with
others, either as the lead and supported by others, or through delivering
on specific activities and outputs in project which others have led on.  Their
projects are focused on the preservation and enhancement of the area’s
historic environment, and also increasing understanding of it.   Information
on a range of completed projects can be found on a dedicated page on
their website.  Some of the projects include: the King’s Seat Hillfort
Archaeology Project; A Regional Archaeological Research Framework; the
Tay Landscape Partnership Scheme; Historic Churchyards, and the Carpow
Longboat project.
PKHT Trails, Maps and Leaflets Information
The Perth and Kinross Heritage Trust also have a range of trails, maps, and
leaflets on their homepage to aid people in their exploration of the historic
environment of Perth and Kinross.  These include:
• The Perth Medieval Trail
• The Archaeology of the King’s Seat Hillfort, Dunkeld
• Perthshire Picts 1: Strathearn and Gowrie
• The Hillforts of the Tay Estuary
• Kilmagadwood: The Story of an Early Bronze Age Cemetery
• Historic Churchyards Leaflet; Alyth Churchyard Leaflet; Body Snatcher
Leaflet; Collace Churchyard Leaflet; Coupar Angus Churchyard Leaflet;
Meigle Churchyard Leaflet
As part of the Historic Churchyards Project, conservation work has been
undertaken at a number of important churchyard buildings along with a

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gravestone stabilisation programme.  Conservation friendly management
was also introduced with meadow fringes to improve biodiversity, in
partnership with the Council. 
Location of Historic Assets and Places in Perth and Kinross
PKC Interactive Heritage Map
The Perth and Kinross Area has a rich, strong, and varied human past,
which can be seen 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.
The tables and maps to follow outline some of the key statistics for the
Perth and Kinross Area’s built heritage assets and their distribution.   This
information can also be viewed on the Council’s online Interactive Heritage
Map. 
Managing Change in the Historic Environment
There are 36 Designated Conservation Areas within the Perth and Kinross
Council Area.  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.   
Table 2 to follow provides the list of our Designated Conservation Areas
and provides information on whether they have an existing Conservation
Area Appraisal, and if so in which year the appraisal was published.   Map 3
shows the distribution of Conservation Areas across the Perth and Kinross
Council Area.  
Permitted Development Rights
Review of permitted development rights (PDR)
Permitted Development Rights (PDR) are forms of development which can
be carried out without the requirement for planning permission.  PDR are
contained in the Town and Country Planning (General Permitted
Development) (Scotland) Order 1992 or the “GDPO”.  
The Scottish Government is currently undertaking a substantial phased
review of permitted development rights (PDR).  Phases 1 and 2 of the
review introduced some changes to PDR, during 2021 and 2023, which
may have implications for types of development which were previously
restricted for historic environment assets and within Conservation Areas. 
Specific limitations and conditions for different types of development are
listed under the recent amendments, which for the most part require prior
notification to, and prior approval from the planning authority where
proposals may affect a listed building (including its curtilage), or a
designated area, such as a site of archaeological interest, a historic garden
or designed landscape, or within a conservation area.  
Phase 3 of the review, which is mainly concerned with PDR for domestic
and non-domestic renewables equipment recently came into force on 24
May 2024.  The amendments under Phase 3 also contain lists of specific
limitations and relevant conditions which apply, under certain
circumstances, including the requirement for prior notification/ approval
for proposals which will impact upon heritage assets.

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It is important to note that even with these recent amendments to the
GDPO, Article 4 of the Order contains provisions which allow planning
authorities to make directions restricting PDR for specific types of
development or classes of development in specified locations.   Please see
the information to follow on Article 4 Directions and Regulation 11 Orders
in place within the Perth and Kinross Council Area.
Article 4 Directions and Regulation 11 Orders 
Some of our Conservation Areas have Article 4 Directions or Regulation 11
Orders in place.  These are additional controls for specific classes of
development and advertisement, respectively, which would otherwise be
considered as ‘permitted development’, i.e., development that does not
require planning permission.  Article 4 Directions can cover a range of
minor works and might include the replacement of doors and windows,
the erection of gates, fences, garages, sheds, porches, storage tanks, or the
installation of satellite antennae.   Table 2 also identifies whether one or
both of these controls are in place at each of the Designated Conservation
Areas, or not.

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Table 2: Designated Conservation Areas (CA) within Perth and Kinross
Designated CA CA Appraisal? Article 4? Reg. 11?
Aberfeldy  Yes (2008) Yes Yes
Abernethy Yes (2012) Yes Yes
Baledgarno No No No
Birnam No No No
Blair Atholl2 Yes (2007) No Yes
Blairgowrie Yes (2007) Yes Yes
Cleish3 Yes  No No
Comrie Yes (2010) Yes Yes
Coupar Angus Yes (2007) Yes Yes
Crieff Yes (2009) Yes Yes
Dunkeld Yes (2011) Yes Yes
Dunning Yes (2010) Yes Yes
Errol Yes (2009) Yes Yes
Forgandenny No No No
Fortingall No Yes Yes
Fowlis Wester No No No
Grandtully and Strathtay Yes (2008) Yes Yes
Designated CA CA Appraisal? Article 4? Reg. 11?
Inchture Yes (2015) Yes Yes
Kenmore Yes (2011) Yes Yes
Kinnesswood No No No
Kinross Yes (2010) Yes Yes
Kinrossie No No No
Knapp No No No
Longforgan Yes (2013) Yes No
Meikleour No No No
Muthill Yes (2011) Yes Yes
Moulin No No No
Perth Central Yes (2008) Yes Yes
Perth Kinnoull Yes (2010) Yes Yes
Pitcairngreen No No No
Pitlochry Yes (2007) Yes Yes
Rait Yes (2012) Yes No
Scotlandwell Yes (2009) Yes No
Spittalfield No Yes Yes
St. Fillans4 Yes (2011) Yes No
Wester Balgedie No No No 
2 Blair Atholl CA is located within the Cairngorms National Park Authority boundary –
for all planning matters Perth and Kinross Council consult with the National Park
Authority where necessary.  
3 Date unknown for Cleish CAA, potentially late 1990s.
4 Undertaken by Loch Lomond and the Trossachs National Park Authority

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Map 3: Location of Conservation Areas within Perth and Kinross

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Listed Buildings
Historic Environment Scotland’s Portal - Listed Buildings
The portal provides detailed information on the range of individual heritage
assets across local authority areas.  In terms of Listed Building assets, HES
records tell us that there are a total of 3054 Listed Buildings within the
Perth and Kinross Area.  Of those 3054 buildings, 160 are Category A
Listed; 1402 Category B Listed, and 1492 Category C Listed.   Map 4 to
follow shows the location of those various assets.  They can also be viewed
on the Council’s Interactive Heritage Map. 
Buildings at Risk Register for Scotland
The Buildings at Risk Register for Scotland has been in operation since
1990.  The Register is maintained by Historic Environment Scotland and
provides information on properties of historic or architectural merit across
the country that are considered to be at risk because they are either
vacant with no identified new use; are suffering from neglect and/or poor
maintenance; have structural problems; have been damaged as a result of
fire; are unsecured and open to the elements, and/or are under threat
from demolition.  
In May 2024 115 buildings within the Perth and Kinross Area were included
on the Register.  A detailed breakdown of those properties at risk is as
follows, and Map 5 shows their location:
• 100 properties are class at risk.
• 15 properties are in the process of being restored.
• 49 properties are categorised as being at moderate risk.
• 22 properties are categorised as being at high risk.
• 39 properties are categorised as being at low risk.
• 4 properties are categorised as being critical.
• 1 property is categorised as being at minimal risk.
• 16 Category A Listed Buildings are included on the Register.
• 54 Category B Listed Buildings are included on the Register.
• 22 Category C Listed Buildings are included on the Register.
In terms of the condition of the properties on the Buildings at Risk
Register: 14 are classified as ruinous; 48 in poor condition; 33 in fair
condition; 16 in very poor condition, and 4 are in good condition.

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Map 4: Location of Listed Buildings within Perth and Kinross

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Map 5: Location of Buildings on the Buildings At Risk Register within Perth and Kinross

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Designated Scheduled Monuments
The HES Portal and the Council’s online Interactive Heritage Map also
provide detailed information on the number, type, and location of
Scheduled Monuments across the area.  There are 683 Designated
Scheduled Monuments in the Perth and Kinross Area which have been
scheduled by Historic Environment Scotland under the Ancient
Monuments and Archaeological Areas Act 1979.  These monuments range
from deserted settlements, hut-circles and field systems, cairns, Roman
camps, forts, and fortresses to the remains of former ecclesiastical
buildings.  Map 6 on the following page shows the spatial distribution of
these assets.  
Gardens and Designed Landscapes
Those Gardens and Designed Landscapes (GDLs) included on Historic
Environment Scotland’s Inventory, are ‘grounds consciously laid out for
artistic effect’ which are ‘an important element of Scotland’s historic
environment and landscape.’  Nationally important sites are also selected
for inclusion under the terms of the Ancient Monuments and
Archaeological Areas Act 1979.    There are 41 sites within the Perth and
Kinross Area included on the Inventory of Gardens and Designed
Landscapes.
Map 7 to follow shows the location of both the GDLs sites within the Perth
and Kinross Area along with the Inventory of Historic Battlefield Sites. 
These designated sites can also be viewed via the HES Portal or the
Council’s online Interactive Heritage Map. 
Inventory of Historic Battlefields
Historic battles are important to our sense of identity, and the landscapes
on which these events took place are significant as they can tell us a lot
about the battle and the course it took, as well as containing the physical
remains and artefacts.  Battlefields are also remembrance sites.   National
important battlefields in Scotland are included on the Inventory of Historic
Battlefields if they meet the criteria published in Historic Environment
Scotland’s Designation Policy and Selection Guidance 2019.
There are 4 Inventory of Historic Battlefields Sites within Perth and Kinross. 
They are the Battle of Dunkeld; Battle of Dupplin Moor; Battle of
Killiecrankie, and Battle of Tippermuir.  As highlighted in paragraph 1.25,
the distribution of these sites can be seen on Map 7 to follow, and also via
the HES Portal and the Council’s online Heritage Map. 
Undesignated Archaeological Sites and Remains
In addition to the numerous designated assets across the Perth and Kinross
Area, there are also approximately 15,472 undesignated archaeological
sites or remains included on the Council’s Historic Environment Record
(HER).  This record is maintained by the Perth and Kinross Heritage Trust
and can be accessed online via a searchable interactive map.

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Map 6: Location of Scheduled Monuments within Perth and Kinross

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Map 7: Location of Garden and Designed Landscape and Historic Battlefields Sites within Perth and Kinross

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Other Relevant Sources of Information
PKC LDP3 Big Place Conversation
The Council carried out its ‘Big Place Conversation’ exercise to kick start
the LDP3 process across Perth and Kinross communities during most of
2023.  This was an extensive exercise involving over 100 events throughout
the Council Area.  The events ranged from drop-in information sessions,
meetings, and online surveys to workshops and online sessions using the
Place Standard Tool to capture the views of local communities about
different aspects of their places.   There were also targeted sessions held
with schools, service user groups, and minority groups.
Issues and priorities relating to historic assets and places identified
through the Big Place Conversation discussions included:
• historic buildings and monuments are integral to local heritage and
add to the character of places
• there was support for more secure funding for the upkeep and
preservation of historic assets
• historic buildings sometimes need better maintenance
• young people appreciated rural life and the historic character of
many settlements
Perth and Kinross LDP2 Design Charettes
Between 2014 and 2016, Perth and Kinross Council worked in partnership
with a number of local Community Councils to undertake a series of
community design workshops in key settlements across the area.  The
objective was to work with local communities and key stakeholders, in
identifying a town's strengths, weaknesses, as well as opportunities to help
mitigate the social, environmental, and economic challenges towns across
Scotland are facing.  In total, 5 charettes were undertaken for Aberfeldy,
Auchterarder, Bridgend, Blairgowrie, and Crieff.   
In the Aberfeldy Community Charette, 1 of the 4 Priorities was to ‘Make
more of Aberfeldy’s existing assets: enhance the riverside and make the
most of the town’s historic and cultural assets, including Lower Birks.’
As part of the Auchterarder Community Charette process, participants
identified the town’s historic buildings and townscape overall as being in
their top 5 ‘Community Likes’.  
Participants in the Bridgend Community Charette highlighted that poorly
maintained, vacant, and derelict buildings within the Conservation Area
could benefit from investment to improve the appearance of the buildings
and the streetscape overall and help bring buildings back into use. 
A number of buildings and spaces within the Blairgowrie Conservation Area
were identified as part of the Blairgowrie and Rattray Town Centre
Charette as having ‘potential to do more’ in order to improve the overall
quality and experience of the area.
Crieff’s town heritage was highlighted as being the top 5 of ‘Community
Likes’ as part of the Crieff Community Charette process.  Proposals to
encourage awareness and appreciation of this through a clearly marked
heritage trial throughout the town were discussed.   Culture and the
town’s environment were identified as some of the key principles for the
future of the place. 
PKC Placemaking Programme

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The Placemaking Programme linked to the Perth City Plan seeks to
enhance the quality, vitality and vibrancy of Perth City Centre and key rural
settlements, encouraging increased use and longer time spent in these
locations, contributing to sustainable economic growth.  A series of
initiatives have been identified to help create high quality public spaces,
deliver sustainable active travel routes, and promote use of the area’s
natural assets.  The priorities and principles the Council are committed to
are:
• Developing a strategy for traffic, access, and movement, which
prioritises the pedestrian.
• Creating a hierarchy of streets, public spaces, and walking/ cycling
routes.
• Improving the environmental quality of key streets/ public spaces,
promoting natural assets, and building architecture.
• Establishing a framework of green infrastructure.
• Creating attractive points of arrival and ensuring key landmarks,
natural assets and streets are better connected. 
Projects to be delivered under the Council’s Placemaking Programme
include - City Greening; Green Networks; Aberfeldy; Alyth; Golden Route;
Tay Street and South Street (Perth). 
Aberfeldy Square Regeneration
The Aberfeldy Square Regeneration proposal is a collaborative project
between Perth and Kinross Council, Aberfeldy Small Business Association,
and Aberfeldy Community Council, to regenerate the square in the town,
with the overarching aim of helping to support and sustain local economic
growth.  Proposals for the Square focus on reducing current parking
provision to create a level, flexible space which can be used to host current
and future music and cultural events.   The key principles and community
priorities identified as part of the Aberfeldy Community Charette process
were used to inform the initial ideas for the Square, as well as develop the
final proposal. 
Community Action Plans
There are currently 11 Community Action Plans (CAPS) in Rural Perth and
Kinross, for 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. There is also a
CAP development process due to start for Comrie once the necessary
funding has been secured.  Community Action Plans are community-led
and focus on identifying a common vision, key themes, priorities, and
actions needed to enhance a place over the period of the CAP and beyond.   
The importance of existing historic assets and characteristics to a place was
highlighted across all CAPs, as too was the opportunity to further develop
tourism and heritage experiences for the benefit of the local economy and
also to raise awareness of an area’s culture and heritage.

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Summary of Implications for the Proposed Plan:
Relevant Historic Environment Policies, Advice and Guidance
Our Past, Our Future: The Strategy for Scotland's Historic Environment
2023
The national strategy for the historic environment sets the overall
framework within which we should all be working collaboratively to help
deliver upon the document’s mission and priorities and principles.   These
key messages have already been translated into national planning policy
via NPF4.  The LDP3 Spatial Strategy should also reflect the priorities and
principles of the ‘Our Past, Our Future’ Strategy.
Historic Environment Policy for Scotland (HEPS) 2019
Whilst non-statutory, HEPS provides clear guidance on how decisions
affecting the historic environment should be approached to help protect
and promote our heritage assets and places.  The policies contained within
HEPS should be taken account of and translated into the Plan’s Spatial
Strategy with respect to the historic environment of Perth and Kinross.
Managing Change in the Historic Environment Series
The HES Managing Change series is an important resource for
understanding and dealing with specific issues related to historic
environment assets.  The application of these guidance documents is most
likely to be via the Development Management system in response to
planning proposals.  However, many elements of the guidance notes in the
series will be useful in informing our programme of review of Conservation
Area Appraisals.  It may also be relevant to refer to these documents for
some site specific developer requirements, and in discussions with our
communities about historic assets in their local area for the development
of Local Place Plans or Community Asset Transfer opportunities.  
Historic Environment Scotland Talking About Heritage Guide (2022)
The HES ‘Talking About Heritage’ guide is a useful tool to support
discussions around the historic environment which will be helpful for
heritage focused conversations with our communities as part of further
engagement work across the Perth and Kinross Area in developing the
Proposed Plan, and Conservation Area Appraisal reviews.
Historic Environment Scotland Circular: Regulations and Procedures
The HES Circular makes it clear the role Historic Environment Scotland has
in the planning system and procedures for consulting them.  PKC will
ensure there is early and continued engagement with HES with regards to
the development of LDP3 Spatial Strategy, its SEA and any related historic
environment appraisals or guidance documents.
Guidance for Peatland Restoration and the Historic Environment in
Scotland
The ALGAO guidance document provides a useful information source on
how to approach safeguarding the protection of heritage assets whilst
seeking to meet peatland restoration objectives.   This will be an important
resource when identifying our nature networks and considering links
between them and potential opportunities for restoration and/or
enhancement where appropriate.

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Historic Land Use Assessment
Historic Environment Scotland’s Historic Land Use Assessment (HLA)
The Historic Land Use Assessment provides a useful picture of how the
landscape of the Perth and Kinross Area has changed over time, helping us
to understand the processes which have shaped the landscape, and how
past events and decisions linked to land use continue to be visible today. 
This provides important context for the development of LDP3’s Spatial
Strategy as it demonstrates a key link between the evolution of the Perth
and Kinross landscapes over a long period of time, with the natural
landscape character of the area as defined within Nature Scot’s Landscape
Character Assessments.  
Gaps, Uncertainties or Key Issues Raised:  Historic Environment
Scotland’s Historic Land Use Assessment is not available for the entire PKC
Area.  However, it does provide a picture for the most populated areas. 
Perth and Kinross Heritage Trust (PKHT)
The Perth and Kinross Heritage Trust
The Perth and Kinross Heritage Trust’s (PKHT) information on heritage
grants will be a useful source of reference which can be relayed onto
property owners and community groups who wish to maintain and/or
improve heritage assets, on available funding opportunities, via further
engagement sessions for LDP3.    
Information on completed PKHT and partners projects and key relevant
elements contained within the trails, maps and leaflets resources on their
website should be reflected, where appropriate, in the LDP3 Spatial
Strategy and Conservation Area Appraisals, or other historic environment
planning guidance that may be developed in association with LDP3.    
Location of Historic Assets and Places in Perth and Kinross
These historic environment related data sources provide us with
information on the location, type, and status of our heritage assets within
Perth and Kinross to 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.  Those properties contained on the Buildings at Risk Register
should be considered as part of our Settlement Audit exercise and where
appropriate identified as opportunities for sustainable reuse in line with
NPF4 Policy 9: Brownfield, vacant and derelict land and empty buildings. 
Gaps, Uncertainties or Key Issues Raised:  
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.
Other Relevant Sources of Information
PKC LDP3 Big Place Conversation
The Place Standard approach has been a very useful tool in helping us to
start a conversation with our local communities about their places and
understand their views on how the different elements of those places are
performing for the people who use them.  The results will not only help to
inform the development of the LDP3 Spatial Strategy, particularly through

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our Settlement Audit work, but also other Council plans and strategies,
such as our Local Transport Strategy – The Mobility Strategy.  
Perth and Kinross LDP2 Design Charettes
Although some time has lapsed since these 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.   The charette reports should be
considered as part of the Settlement Audit work for the Proposed Plan to
understand which elements have or have not been realised to date, if they
are still relevant, and where LDP3 can help support the implementation of
the key priorities identified within them. 
Gaps, Uncertainties or Key Issues Raised:  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 also how those issues and actions compare to the
feedback gathered through the Big Place Conversation. 
PKC Placemaking Programme, Aberfeldy Square Regeneration, and
Community Action Plans
These community led documents provide an important source of
information about our places, and the key priorities and aspirations of our
communities for the future of their places.   It is important that these
characteristics, along with relevant environmental, physical, cultural, and
socio-economic characteristics are taken account of in the development of
the Spatial Strategy for LDP3, to help deliver sustainable, well designed,
and high-quality places where our historic assets are safeguarded. 
Localities Profiles – LDP3 Proposed Plan Settlement Audit
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
Historic Assets and Places required under NPF4 Policy 7.   The template has
yet to be developed but will be in place prior to work beginning on the
Proposed Plan.

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Summary of Stakeholder Engagement:
Big Place Conversation 
The Council carried out its ‘Big Place Conversation’ exercise to kick start
the LDP3 process across Perth and Kinross communities during most of
2023. This was a substantial exercise involving over 100 events throughout
the Council area. The events ranged from drop-in information sessions,
meetings, and online surveys to workshops and online sessions using the
Place Standard Tool to capture the views of local communities about
different aspects of their places. The results of the BPC are summarised as
part of a separate report on the outcomes and findings across the different
locality areas.
LDP3 Evidence Report Topic Papers
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 week during
July and August 2024.  As part of our consultation process for LDP3 Topic
Papers we welcomed the views of our key stakeholders (who were
contacted specifically via email regarding the consultation exercise) and
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 LDP.
Statements of Agreement/ Dispute 
Ten responses were received on our Historic Assets and Places topic paper,
one of which came from a respondent that did not provide their name or
contact details.
Six of the respondents expressed that they neither agreed nor disagreed
with the evidence, and many provided examples to assist with highlighting
the importance of historic assets and places.
A summary of these comments, their status, and the Council’s response
are provided in the table below.
One respondent on the Historic Assets and Places issue wished their
comments to be treated as a formal dispute to the Evidence Report. That
comment, and the Council’s response has been highlighted in red in the
table.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Perth and Kinross
Heritage Trust
Disagree but
does not make a
formal dispute.
List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): Additional information supplied in
respect of PKHER; the ALGAO public benefit; other NPF4
policies that also reference the Historic Environment. 
Additional comments to raise awareness of new PKHT
guidance documents to support local development;
comments on the updating, maintenance and enhancement
of the Historic Environment Record; more policy emphasis on
bringing redundant buildings back into use; other PKHT
resources to support the LDP; references to regional research
framework and PAN2/2011: Planning and archaeology 
More emphasis on public benefit outcomes; undesignated
archaeological sites (including map); retention of listed
buildings for bringing back into use 
Further Comments: In Scotland HES manages around 2.5% of
historic assets as scheduled monuments, the remainder are
for Local Authorities to manage. Would be helpful to include
PKHT’s role as archaeological advisors to PKC. Suggestions for
highlighting positive economic impact of historic assets 
Formal Dispute: No 
The Perth and Kinross Heritage
Trust’s comments and additional
information will be used in the
preparation of the Proposed Plan.
Its role as archaeological advisors
to the Council is particularly
valued.
Errol Community
Council
Neither agree
nor disagree
List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Formal Dispute: No 
No action required

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Historic
Environment
Scotland
Agree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): Welcome recognition that this topic area
has a number of key connections across multiple topic areas. 
Further information supplied in respect of Historic
Environment designations and casework; buildings at risk;
grants; communities; and tourism and economy relating to
Perth and Kinross 
Formal Dispute: No 
Historic Environment Scotland’s
additional information will be used
to prepare the Proposed Plan
Loch
Developments Ltd
Neither agree
nor disagree
List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Formal Dispute: No 
No action required
Anonymous  List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): Raises 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. 
Further Comments: suggest maps could be clearer and some
more precise wording about when Cairngorms National Park
Authority is consulted on planning matters. 
Formal dispute: No 
The respondent’s comments have
helped inform the summary of
evidence section of the report, and
comments relating to the
timetable for Conservation Area
appraisal will be taken into
account.
Scottish Water Neither agree
nor disagree
List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): Neither agree nor disagree 
Formal Dispute: No 
No action required

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Private Individual Dispute List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): The protected area along the Sidlaw
ridge above Scone appears to be missing along with the
towers including Dunsinane Hill fort. Scone Cross.
Consideration to the WW2 building at Scone / Perth airfield 
however this may be the quality of the maps 
Formal Dispute: Yes 
The respondent’s comments relate
to whether specific Heritage Assets
have been identified on the maps
contained in the Topic Paper. It is
acknowledged that due to scale
and resolution not all heritage
assets will be easily visible or
clearly identifiable at all scales.
However, the specific features
identified by the respondent will
be checked and verified when
preparing site-specific maps for the
Proposed Plan. 
Conclusion on dispute: the
grounds of dispute relate to the
most effective way to display site
specific pieces of evidence and will
be addressed at Proposed Plan
stage. The respondent’s comments
are acknowledged and will be
taken into account at the
preparation of the Proposed Plan
stage. The dispute is therefore
considered resolved. 
Earn Community
Council
Agree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Formal Dispute: No 
No action required

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Scone Estate Neither agree
nor disagree
List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments in respect of evidence and
datasets. 
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, weighing up factors for
and against proposed development. 
Formal Dispute: No 
Agreed
Dupplin Estate Neither agree
nor disagree
List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments in respect of evidence and
datasets. 
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, weighing up factors for
and against proposed development. Example given of need
for relaxation of listed building constraints to reduce carbon
emissions associated with historic assets. 
Formal Dispute: No 
Agreed that NPF4 needs to be
applied as a whole.

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Issue: Green Belts
Corresponding NPF4 policy:
• National Planning Framework, Policy 8: Green Belt
• Other key NPF4 policy connections - 1: Tackling the climate and
nature crises; 2: Climate mitigation and adaptation 3: Biodiversity;
4: Natural Places; 6: Forestry, woodland and trees; 7: Historic assets
and places; 9: Brownfield, vacant and derelict land and empty
buildings; 11: Energy; 13: Sustainable transport; 14: Design, quality
and place; 15: Local living and 20 minute neighbourhoods; 16:
Quality homes; 17: Rural homes; 18: Infrastructure First; 20: Blue
and green infrastructure; 21: Play, recreation and sport; 22: Flood
risk and water management; 24: Digital infrastructure; 26: Business
and industry; 29: Rural development; 30: Tourism; 33: Minerals 
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 009: Green Belts 
https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume
nts/TP009_Green%20Belt.pdf 
Information required by the Act and NPF4 regarding the topic:
Section 15(5) of the Town and Country Planning (Scotland) Act 1997, as
amended:
• The principal physical and environmental characteristics of the
district 
Under Policy 8 NPF4 expects Local Development Plans to:
• Consider using green belts, to support their spatial strategy as a
settlement management tool to restrict development around towns
and cities
• Identify or review green belts as part of the preparation of LDPs,
detailed green belt boundaries should be based on evidence and
should be clearly identified in plans 
Policy intent for Policy 8:
• To encourage, promote and facilitate compact urban growth and
use the land around our towns and cities sustainably. 
Policy outcomes for Policy 8:
• Development is directed to the right locations, urban density is
increased and unsustainable growth is prevented.
• The character, landscape, natural setting and identity of settlements
is protected and enhanced.
• Nature networks are supported and land is managed to help tackle
climate change. 
The Scottish Government’s Local Development Plan Guidance (May 2023)
under it’s ‘Step by step guide’ provides advice on relevant evidence for the
NPF4 policy topics to help planning authorities in considering the national
planning policies when preparing their Evidence Report. 
With respect to NPF4 Policy 8, the Guidance advises that planning
authorities should take into account any green belt review / study of any
existing or potential green belts. 
Other relevant information suggested for consideration include Local
Landscape Character Assessment. 
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]

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• 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]
• LDP2
• Scottish Vacant and Derelict Land Survey 2023
• NatureScot National Landscape Character Assessment
• LDP2 Landscape Supplementary Guidance 2020 
Summary of Evidence:
Establishing a Green Belt around Perth
The green belt in Perth and Kinross was first designated in the Perth and
Kinross Structure Plan 2003. This Plan instructed the Perth Area Local Plan
to define in detail the inner and outer boundaries of the green belt based
on the need to: 
• Allow for long term expansion to the west along the A85 corridor
for business uses
• Sustain the existing separation and identity of Scone
• Provide village envelopes around Aberdargie, Almondbank,
Glencarse, Kinfauns / Walnut Grove, Pitcairngreen, Rhynd and
Scone to accommodate planned development
• Accommodate long term growth to the north west
• Ensure that any developments which are permitted demonstrate a
significant environmental enhancement within the Green Belt 
These criteria were informed by the Perth Green Belt Study in June 2000
which concluded that there was a strong case for establishing a Green Belt
around Perth. 
This need for a green belt was continued in the first TAYplan Strategic
Development Plan and the detailed boundaries were first identified in
LDP1 (which superseded the Perth Area Local Plan). The LDP1 Examination
Reporter concluded that: 
• The proposed green belt boundary allowed for very significant
strategic releases to the west and northwest of Perth which were
intended to satisfy most of the City’s requirements for housing land
and make a significant contribution towards other development
needs within the Plan period and beyond. 
• In addition to site allocations, significant land was to be excluded
from the green belt where smaller scale development might be
permitted or where the need for further allocations could be
considered in a subsequent plan. 
• In other settlements, such as Scone and Luncarty, the proposed
boundary was drawn to offer potential for significant settlement
expansion during the Plan period and potential for further growth
beyond that. 
• There was no evidence that the inner boundary had been drawn
too tightly or that it would encourage development that should take
place in Perth to do so in inappropriate locations beyond the outer
green belt boundary. 
• The green belt boundaries proposed were consistent with the then
Strategic Development Plan and accorded with the purposes of
green belt designation set out in Scottish Planning Policy which was
the precursor to NPF4. 
• Generally, the proposed boundaries followed clearly identifiable
features which were likely to endure in the long term although the
boundary was less distinct along the western edge and the Perth
West development site.

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LDP1 Green belt boundary 
Green Belt Boundary Changes through LDP2
A number of changes to the green belt boundary were considered through
the preparation of LDP2. These changes were assessed through the SEA
process which concluded that the preferred alternative was one which
made two key changes in the boundary at Perth West and the North of
Scone. 
At Perth West the boundary change was to follow the proposed Perth City
settlement boundary which would make the green belt boundary more
robust following the edge of the Lamberkine woodland block. To the north
of Scone, the change was to allow for a rationalised boundary which
followed the route of the Cross Tay Link Road (CTLR). A number of
additions were also proposed to the boundary in order to fill in existing
gaps which would contribute to limiting urban sprawl and framing the
settlement boundaries more clearly.

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Preferred alternative green belt boundary identified in LDP2 SEA 
Source: LPD2 SEA – note, this included changes which had been proposed through the Main Issues Report (MIR)

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Whilst most of the proposed changes were agreed by full Council, it was
ultimately decided to retain the original LDP1 boundary to the North of
Scone rather than amend it to follow the CTLR route. The Council
considered it was important to retain the existing boundary in this location
to provide assurance to the public that the green belt is a fixed approach
to land management around Perth and that changes to it are only made to
reflect long term strategies within the LDP. It was acknowledged, however,
that once built the CTLR would be a permanent boundary in comparison to
the existing boundary in LDP1 which was delineated by commercial
woodland. This approach was agreed and confirmed by the LDP2
Examination Reporter who concluded that ‘there should be no change to
the green belt boundary [to the North of Scone] in the proposed plan at
present, particularly as the CTLR has yet to be completed’.
LDP2 Green belt boundary

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Review of Green Belt Boundary
The NPF states under policy 8 that ‘green belts should be identified or
reviewed as part of the preparation of LDPs’. The LDP Guidance expects
that if the plan already contains an existing green belt, then the planning
authority should review whether the existing boundary remains
appropriate. One of the respondents to the Topic Paper considered that
the review should also consider whether a green belt is still the most
appropriate way to effectively manage development. Although not
explicitly stated in the LDP Guidance it is considered appropriate to include
this within the scope of the review. 
The green belt boundary in Perth and Kinross was identified through LDP1
(adopted 2014) and reviewed through the preparation of LDP2 (adopted
2019). A further review will be carried out ahead of the preparation of the
proposed plan LDP3. In carrying out a green belt review or study, the LDP
Guidance identifies the issues which planning authorities may wish to
consider, to inform any extension or review of precise green belt
boundaries, or the removal of land from the green belt. These are
considered briefly below and will form the basis for the green belt review.
The review will be carried out ahead of the site selection process for the
proposed plan once the local housing land requirement, and the existing
deliverable supply and / or need for new sites to be allocated, has been
identified. 
Existing major uses
The Guidance suggests identifying any existing settlements, major
education and research uses, major businesses and industrial operations,
airports and Ministry of Defence establishments, and any other significant
areas of brownfield, vacant and derelict land within the current green belt
boundary. 
As highlighted above, the existing green belt boundary was drawn to take
account of existing villages and towns and their relationship with Perth
city. The review will consider whether there are other major land uses or
businesses which should also now be identified with a view to ensuring an
appropriate balance between the protection of the quality, character,
landscape setting and identity of settlements, and the need to support the
local economy and local businesses. In relation to brownfield, vacant and
derelict land, the most up to date Scottish Vacant and Derelict Land Survey
dates from 2023. For the preparation of the Proposed Plan the most up to
date survey data will be used. 
Settlement boundaries
Reviewing existing settlement boundaries allows the identification of any
required boundary changes as a result of development having taken place.
This will be carried out as part of the Settlement Audit for the Plan area
and will include an assessment of planning applications to identify any
necessary changes to the green belt boundary. 
Landscape Character Assessment
The landscape character types in Perth and Kinross as defined by
NatureScot in their National Landscape Character Assessment are set out
in Section 2: Profile of the Perth and Kinross Area. In addition, LDP2
supplementary guidance on Landscape identified 11 Local Landscape Areas
across Perth and Kinross. One of these, the Sidlaw Hills LLA partly overlaps
with the green belt boundary. The supplementary guidance identifies the
special qualities and forces for change in this LLA and identifies objectives
going forward. It is being considered whether there is scope for carrying
out a further review of LLAs in advance of the preparation of the proposed
plan. 
Clearly identifiable visual boundary markers
As noted above, the LDP1 Examination Reporter found that the green belt
boundaries which were originally proposed followed clearly identifiable
features. The only point of concern at that time was that the boundary was
less distinct along the western edge and the Perth West development site.
This issue was resolved in the boundary changes through LDP2 to reduce
the green belt area to create the Perth West development site. The

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Reporter noted that ‘the proposed green belt boundary which follows a
field boundary near Blackruthven Farm in the proposed plan would
eventually be made more robust through additional planting as part of
[the] allocation’. 
At Scone, work is progressing on the CTLR and it is currently programmed
to complete in Spring 2025. 
Development pressure within existing green belt boundary
Under NPF policy 8 planning authorities are to consider the use of green
belts to support their spatial strategy as a settlement management tool to
restrict development around towns and cities. The Perth and Kinross green
belt has been in place since the adoption of LDP1 in 2014. During the
preparation of LDP2 both the boundary and the policy were reviewed.
Since then around 60 full planning applications for development or change
of use have been received within the designated green belt area. Whilst
two large-scale mixed-use developments have been approved in principle,
the vast majority of consents have been for smaller scale developments.
For example, the alteration or extension of existing dwellinghouses, the
change of use or new build to create single dwellinghouses, small scale
business or agricultural developments, or development relating to
infrastructure or recreation. A comprehensive analysis of development
pressure within the existing green belt will be undertaken as part of the
review. 
The green belt’s contribution to NPF4’s policy outcomes
The Local Development Planning Guidance suggests that consideration
should be given to the contribution the green belt can make to NPF’s
Green Belts policy outcomes that: 
• Development is directed to the right locations, urban density is
increased and unsustainable growth is prevented.
• The character, landscape, natural setting and identity of settlement
is protected and enhanced.
• Nature networks are supported and land is managed to help tackle
climate change. 
The first two of these are well established criteria for designating green
belts. The new emphasis on supporting nature networks and helping tackle
climate change reflect the increased priority in NPF4 to tackling the climate
and nature crises as highlighted in NPF policy 1. In this there are linkages
with the Tackling the Climate and Nature Crises issue discussed at
Appendix A. 
Big Place Conversation
Issues and priorities relating to the green belt identified through the BPC
Place Standard discussions included: 
• Natural spaces – there has been a gradual loss of natural spaces due to
development on greenfield sites, including on green belt land. A need
to safeguard the environment with effective policy measures, such as
protecting green belt land, was suggested. 
• Housing and community – a need to prioritise brownfield development
and protect green belt land was suggested. 
Summary of Implications for the Proposed Plan:
Key implications for the Proposed Plan are that the spatial strategy will
need to consider whether the green belt designation is still the most
appropriate way to effectively manage development in this area and, if so,
whether there is need to release from the 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

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delivery of a just transition approach to climate change, nature networks
and landscape character. 
Gaps, Uncertainties or Key Issues Raised:
Green belt review 
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 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. 
Summary of Stakeholder Engagement:
Big Place Conversation 
The Council carried out its ‘Big Place Conversation’ exercise to kick start
the LDP3 process across Perth and Kinross communities during most of
2023. This was a substantial exercise involving over 100 events throughout
the Council area. The events ranged from drop-in information sessions,
meetings, and online surveys to workshops and online sessions using the
Place Standard Tool to capture the views of local communities about
different aspects of their places. The results of the BPC are summarised as
part of a separate report on the outcomes and findings across the different
locality areas. 
LDP3 Evidence Report Topic Papers
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 week during
July and August 2024.  As part of our consultation process for LDP3 Topic
Papers we welcomed the views of our key stakeholders (who were
contacted specifically via email regarding the consultation exercise) and
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 LDP.

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Statements of Agreement / Dispute:
12 responses were received on our Green Belts Topic Paper, two 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, 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. A summary of these comments, their status, and the Council’s
response are provided in the table below. There were four responses on the Green Belts issue which the respondents wished to be treated as a formal
dispute to the Evidence Report. Those responses have been highlighted in red in the table. 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Nature Scot Not stated List of Evidence/Datasets: 
The table setting out data links (Section 1.5) is clear, and it is
useful to have this early on in the topic paper. 
Summary of Implications for Proposed Plan (PP): 
We welcome the holistic and proportionate section on the
implication for the Proposed Plan in Section 3. 
Further Comments:
Good to see nature networks and landscape character
considered in this paper. Perhaps these could be reference in
Section 3 Implications for the Proposed Plan. 
Formal Dispute: No 
Comments have helped inform the
Summary of Implications for the
Proposed Plan section of the
Evidence Report. 
Scottish Water Neither List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Formal Dispute: No 
No action required

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Earn Community
Council
Agree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Further Comments: 
Whilst not directly related, reference needs to be made to
increased traffic in the Perth West boundary area and in
particular, the frequent congestion at Broxden. 
In Scone have reservations about the wisdom of PKC
retaining the original North Scone LDP1 boundary and
waiting for the CTLR route to be completed which will itself
make a permanent boundary. 
Note absence of Big Place Conversation report which is
unfortunate. 
Formal Dispute: No 
Comments relating to Perth West
are considered under Place Based
Comments. 
Comments on the boundary at
Scone can be taken into account in
the green belt review. 
The BPC report is now available.
Errol Community
Council
Neither List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Formal Dispute: No 
No action required
Private Individual Disagree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP):
The maps are unreadable on-line. 
PKC have consistently ignored the green belt around Scone
making any commitment meaningless, and the topic paper
fails to identify what the village 'envelope' scale is. 
The problems of map legibility for
the Topic Paper consultation are
acknowledged and we will look at
how this can be improved in the
Evidence Report. 
The green belt review will consider
whether any changes to the

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Formal Dispute: The respondent wishes their comments to
be recorded as a formal dispute 
boundary are necessary because of
development having taken place.
This will include a review of
existing settlement boundaries as
part of a settlement audit. 
Conclusion on dispute:
It is considered that the grounds of
dispute have been addressed and
the dispute is therefore resolved. 
Homes for
Scotland
Disagree List of Evidence/Datasets: No comments 
Summary of Implications for Proposed Plan (PP): 
The previous formal green belt review was undertaken some
time ago and the national policy context regarding green
belts has changed. NPF4 and the LDP Guidance take a
different approach to green belt than the previous Scottish
Planning Policy, and it is essential that green belts are
comprehensively reviewed in the new policy context.   
A key change in context is that the green belt review
considers NPF4 outcomes, which includes delivering the Local
Housing Land Requirement and the potential of the current
green belt to accommodate sustainable development. The
approach outlined in the Topic Paper does not allow for the
local authority to robustly evidence which land is best placed
to support the numerous new housing allocations that may
be required across Perth and Kinross. 
Further Comments: 
NPF requires greenbelts to be
‘identified or reviewed as part of
the preparation of LDPs’ (NPF
policy 8). Since its identification in
LDP1 (2014), the green belt
boundary in Perth and Kinross has
already been reviewed once
through the preparation of LDP2
(2019). 
A further review of the boundary
will be carried out to inform the
Proposed Plan in line with
Schedule 8 of the Local
Development Planning Guidance.
The Evidence Report sets out the
existing information and data
sources which will be used to
inform that review. It is
acknowledged that the Topic Paper

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
It is important for the Topic Paper to recognise the need for
evidence to be kept up to date and any plan and decisions
must be able to be made in this context, where appropriate. 
Formal Dispute: Homes for Scotland wish to formally dispute
this issue on the grounds that a green belt review must be
carried out. 
could have stated this more
clearly. The Evidence Report will
therefore emphasise that a review
will be carried out in light of the
new policy context and priorities
set out in the NPF, including
meeting the finalised housing and
employment land requirements,
during the plan preparation
process. 
Conclusion on dispute:
It is considered that the grounds of
dispute have been addressed and
the dispute is therefore resolved. 
Savills on behalf of
Scone Estate
Disagree  List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Further Comments: 
The original designation of the Green Belt was in 2003. The
Perth Green Belt Study was written nearly 12 years ago, and
the role of the Green Belt has since gone through various
changes. Essential that any review is comprehensive and asks
core questions regarding the continued value of the Green
Belt. Perth will face significant challenges for future
allocations of housing if it retains the Green Belt in its current
form. 
Scone Estates should be identified as an existing major
business within the green belt. The green belt designation
Comments relating to a green belt
review are considered in the
response to Homes for Scotland
above. 
As suggested, the Evidence Report
will also specifically refer to the
need to consider whether there
are major land uses or businesses
which should be identified, in
addition to the existing villages and
towns which were taken into
account in defining the original
boundary, in order to help achieve
a suitable balance between

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
that blankets the Estate is unnecessary and hampers the
Estates' ability to plan effectively to diversify and safeguard
the Estates business and thus to best conserve the strategic
asset the Palace and associated policies provide. Scone is
likely to host nature networks and if there is a desire to
extend these it is also necessary to allow the Estate to invest
in development that can assist in paying for such schemes to
be implemented. 
It would be useful to understand precisely how and when
settlement boundary amendments and the green belt review
will be undertaken and how stakeholders will be invited to
participate. 
There are many other devices available to the Planning
Authority to effectively manage development without
needing to resort to a Green Belt. For example, a strong
spatial strategy which allocates generous amounts of land,
Housing in the Countryside policies, and other designations
of key landscape assets. The current policy does not achieve
a suitable balance between the protection of the quality,
character, landscape setting and identity of settlements and
the need to support the economy and local businesses and
puts an extra and unnecessary hurdle in the way of
development opportunities. The investment in the CTLR
could also be better leveraged if the Green Belt was removed
or its policies revised in its vicinity to allow for diversified
projects.   
Formal Dispute: Savills on behalf of Scone Estate wish to
formally dispute this issue on the grounds that PKC should
protection and supporting the local
economy. 
Information will be made available
in due course as to how interested
parties can participate in the
review. 
The green belt review section
above highlights that the review
will be used to inform both the
addition or removal of land from
the green belt, as well as the
continuing relevance of the green
belt as a means of managing
development. 
Comments on the effectiveness of
the current policy are noted. Policy
8 Green Belt is one of the more
detailed policies in the NPF and it is
considered that it will most likely
remove the need for a local level
policy in LDP3. 
Conclusion on dispute:
It is considered that each of the
grounds of dispute have been
addressed and / or incorporated
into the Evidence Report and the
dispute is therefore resolved.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
take a root and branch approach to the review of the green
belt and consider whether it remains relevant. 
Page 9 of the Topic paper asserts that existing major
businesses should be identified within a green belt boundary
when considering a review. As such, Scone Estates should be
identified as a major business. 
Savills on behalf of
Dupplin Estate
Neither List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Further Comments: 
The original designation of the Green Belt was in 2003. It is
essential that any review is comprehensive and asks core
questions regarding the continued value of the Green Belt.
Perth will face significant challenges for future allocations of
housing if it retains the Green Belt in its current form. The
restrictions on development which NPF4 creates means that
Perth city in particular is significantly constrained by prime
agricultural land and by flood risk. The Green Belt adds an
unnecessary extra level of restrictions. PKC will find it
extremely challenging to find enough development land into
the future. 
There are many other devices available to the Planning
Authority to effectively manage development without
needing to resort to a Green Belt. A strong spatial strategy
which allocates generous amounts of land, including a range
of sites which have low infrastructure costs as well as the
larger strategic development sites, should be a strong
protection against erosion of the setting of Perth. Also,
Comments relating to a green belt
review are considered in the
response to Homes for Scotland
and Scone Estate above. 
Specific comments on the
boundary can be taken into
account in the green belt review.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Housing in the Countryside policies can be used effectively to
both promote and manage development in the rural
hinterland. Other designations of key landscape assets such
as National Scenic Areas, Special Landscape Areas and
Gardens and Designed Landscapes can be used very
effectively to protect these assets.  The current policy does
not achieve a suitable balance between the protection of the
quality, character, landscape setting and identity of
settlements and the need to support the economy and local
businesses and puts an extra and unnecessary hurdle in the
way of development opportunities.   
One specific change which would assist in the creation of a
more robust boundary and make more flexible space for
Perth would be moving the greenbelt to the south side of the
M90. However, Dupplin would encourage PKC to take a root
and branch approach to the review of the green belt and
consider whether it remains relevant. 
Green Belts should be vibrant places where urban areas
transition towards the countryside.  The ability to utilise the
greenbelt for recreation and well-being as well as biodiversity
is an important aspect of the urban fringe. 
Formal Dispute: No 
Montagu Evans on
behalf of Loch
Developments Ltd
Neither List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Formal Dispute: No 
No action required

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Ristol Consulting Disagree – does
not want to
register as
formal dispute
List of Evidence/Datasets: No comments 
Summary of Implications for Proposed Plan (PP): 
Consistent with our submissions on climate adaptation, green
belt, infrastructure, business and housing, welcome the
scope of the topic papers and, in the preparation of the new
LDP, encourage the development of integrated energy,
mobility and digital infrastructure to deliver a just transition
approach to climate adaptation. 
Policy drives change and as such, a spatial framework which
actively focuses on decarbonising heat and transport through
smart local energy neighbourhoods for existing and planned
developments, a network of mobility hubs and collocating
uses would enable scalable change to materialise within the
10-year plan period. 
Further Comments: 
If green belt policy is continued into the review LDP, please
explore the application of housing in the countryside policy
particularly for the criteria of building groups and infill. The
contribution these criteria make to local, rural housing is
invaluable whilst the adverse impact on the intent and
outcome is negligible and can be assessed through wider non
green belt policies on amenity and environment. 
Formal Dispute: No 
Comments on the Implications for
the Proposed Plan are considered
under Appendix D Infrastructure –
Transportation. 
In relation to LDP green belt policy,
Policy 8 Green Belt is one of the
more detailed policies in the NPF
and it is considered that it will
most likely remove the need for a
local level policy in LDP3. It will,
however, be for the Proposed Plan
to consider whether there is
justification for local level policies
relating to the application of
housing in the countryside policy in
the green belt. 
Not provided Disagree List of Evidence/Datasets:  The wording ‘large-scale’ has been
removed from the Summary of

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
There does not appear to be any on the ground assessment
of areas impacted / covered by the green belt. This should
come before any consideration of the green belt. 
The settlement of Craigend should be omitted from the
green belt and identified as a settlement with a settlement
boundary around it. This is a gap / uncertainty within the
evidence gathered. Assessment should include consideration
of the value of Craigend to the green belt. 
Summary of Implications for Proposed Plan (PP): 
Only refers to release of 'large-scale areas of land for planned
growth'. It should also refer to small and medium growth and
to newly identified settlements and settlement boundaries. 
Formal Dispute: The respondent wishes their comments to
be recorded as a formal dispute on the grounds that 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. 
Implications for the Proposed Plan
section of the Evidence Report. 
Comments relating to Craigend are
considered under Place Based
Comments. 
Although the formal dispute refers
specifically to Craigend, this
appears to be based on the
argument that a green belt review
should have been carried out as
part of the Evidence Report. It has
therefore been included as a
formal dispute under this issue.
Comments relating to a green belt
review are considered in the
response to Homes for Scotland
above. 
Conclusion on dispute:
It is considered that each of the
grounds of dispute have been
addressed and / or incorporated
into the Evidence Report and the
dispute is therefore resolved. 
Not provided Disagree  List of Evidence/Datasets: 
Disagree that urban areas have to be more densely
populated in order to protect green belt. Many urban areas
Is it suggested that the term
‘compact urban growth’ used in
the Evidence Report has a subtly

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
have issues that are not going to be improved by more dense
housing, e.g. surface water and sewer flooding. New villages
/ towns would be a better solution as these can be designed
in a sustainable manner. 
Summary of Implications for Proposed Plan (PP): No
comments 
Formal Dispute: No 
different meaning to ‘more densely
populated’ and will take into
account issues such as flooding
when considering the potential for
growth. 
Whilst the NPF refers to the
resettlement of previously
inhabited areas, there is no
provision for new towns or villages. 
It is not considered that any
changes need to be made to the
Evidence Report.

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Issue: Brownfield, Vacant and Derelict Land and Empty
Buildings
Corresponding NPF4 policy:
• National Planning Framework, Policy 9: Brownfield, vacant and
derelict land and empty buildings
• Other key NPF4 policy connections - 1: Tackling the climate and
nature crises; 2: Climate mitigation and adaptation; 7: Historic
assets and places; 12: Zero waste; 14: Design, quality and place; 15:
Local living and 20 minute neighbourhoods; 16: Quality homes; 17:
Rural homes; 18: Infrastructure First; 20: Blue and green
infrastructure; 21: Play, recreation and sport; 22: 23: Health and
safety; 26: Business and industry; 27: City, town, local and
commercial centres; 29: Rural development; 31: Culture and
Creativity. 
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 010: Brownfield, Vacant and Derelict Land, and Empty
Buildings 
https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume
nts/TP010_Brownfield%20VD%20and%20Empty%20Buildings.pdf 
Information required by the Act and NPF4 regarding the topic:
Section 15(5) of the Town and Country Planning (Scotland) Act 1997, as
amended:
• The principal physical and environmental characteristics of the
district 
Under Policy 9 NPF4 expects Local Development Plans to:
• Set out opportunities for the sustainable reuse of brownfield land
including vacant and derelict land and empty buildings. 
Policy intent for Policy 9:
• To encourage, promote and facilitate the reuse of brownfield,
vacant and derelict land and empty buildings, and to help reduce
the need for greenfield development. 
Policy outcomes for Policy 9:
• Development is directed to the right locations, maximising the use
of existing assets and minimising additional land take.
• The contribution of brownfield land to nature recovery is
recognised and opportunities for use as productive greenspace are
realised where appropriate.
• Derelict buildings and spaces are regenerated to improve wellbeing
and transform our places. 
The Scottish Government’s Local Development Plan Guidance (May 2023)
under it’s ‘Step by step guide’ provides advice on relevant evidence for the
NPF4 policy topics to help planning authorities in considering the national
planning policies when preparing their Evidence Report. 
With respect to NPF4 Policy 9, the Guidance advises that planning
authorities should take into account details of areas of brownfield land
including vacant and derelict land and empty buildings, Vacant and Derelict
Land Survey returns, and Buildings at Risk Strategies. 
Other relevant information suggested for consideration include Brownfield
Urban Capacity Studies.

Page 240

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
• PKC Reusing Empty Properties
• PKC Elected Member Briefing – Vacant and Eyesore Property
Taskforce Update 
Summary of Evidence:
Scottish Vacant and Derelict Land Survey 2023
The map below shows the locations of vacant and derelict sites across
Perth and Kinross identified by the scale of the site. 
Key statistics from the 2023 survey are: 
• There were 24 hectares of derelict land across 44 sites (SVDLS table
2)
• There were 26 hectares of urban vacant land across 14 sites (SVDLS
table 2)
• The total derelict land area increased by 12% from 21 hectares in
2017 to 24 hectares in 2023 (SVDLS table 6)
• The total urban vacant land area reduced by 31% from 38 hectares
in 2017 to 26 hectares in 2023 (SVDLS table 12)
• The total derelict and urban vacant land area reduced by 15.4
• 5% from 59 hectares in 2017 to 50 hectares in 2023 (SVDLS table 5)
• 43% of the derelict land in Perth and Kinross (15 sites) is located
within settlements whilst 57% (29 sites) is in the countryside (SVDLS
table 7) 
Overall, less 0.01% of the Perth and Kinross area is derelict land (SVDLS
Annex 3) which would suggest that it is not a significant issue for the area.
Although the overall land area is small, however, a key planning
consideration is the percentage of the Perth and Kinross population which
are living near to derelict land (SVDLS table 9): 
• 65% are living 1,000m+ from derelict land
• 24% are living 500m – 1,000 from derelict land
• 11.5% are living less than 500m from derelict land
• 7.6% have been living less than 500m from land which has been
derelict long-term (prior to 2008) 
Having an up to date and accurate record of vacant and derelict land
within the area helps identify the scale of the problem and any issues
relating specifically to Perth and Kinross which may require a local policy
response in LDP3. It will also assist in the identification of potential
development sites for the Proposed Plan.

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Location of Vacant and Derelict Sites in Perth and Kinross 
Crown copyright [and database rights] 2024 OS AC0000805756. You are permitted to use this data solely to enable you to respond to, or interact with,
the organisation that provided you with the data. You are not permitted to copy, sub-licence, distribute or sell any of this data to third parties in any form.

Page 242

Buildings at Risk Register for Scotland 
The Buildings at Risk Register (BARR) produces information to understand
threats to the historic environment and opportunities for building and
community regeneration. An At-Risk building is typically a disused heritage
building in need of repair and re-use or re-purposing. 
There are 95 At-Risk buildings in Perth and Kinross, of these: 37 are
classified as residential buildings, 14 are churches or chapels, 11 are
farming-related such as steadings or barns, and the remainder include
buildings such as military sites, schools, industrial structures, transport
infrastructure, commercial buildings, and funerary memorials. 
The majority are in Perth division (26) followed by Highland (23) and
Eastern (22) Strathearn (22) and Kinross (2). Half (47) are in rural locations,
19 in urban areas, 15 in small towns and 14 in rural settlements. Nearly 40
settlements have, or are near to, at least one At-Risk building. There are
significant clusters in Crieff (9), Kenmore (9), Perth (8), and Blairgowrie (7).
Around 90% of buildings are now long-term At-Risk having featured on the
Register for approaching 10 years or more. 
Poor condition is the most frequent (45%) assessment of an At-Risk
building in Perth and Kinross, and nationally. Across BARR rural buildings
are more likely to be in poorer condition than those in settlements and this
pattern is evident across Perth and Kinross. 45% of rural buildings were
assessed at Very Poor or Ruinous condition, for settlement buildings this
reduces to 15%. 
Across BARR the percentage of At-Risk buildings in areas of comparatively
more deprivation (SIMD Deciles ranked 1-3) is around 17%. In Perth and
Kinross, it is 8%. All the buildings are in three data zones, two in Central
and South Inch, and one in Blairgowrie West. 
There may also be other disused heritage buildings which do not appear on
the register. 
Society for the Protection of Ancient Buildings Survey of Thatched
Buildings in Scotland
This survey was carried out in 2014-15. Thatched buildings are recognised
as a traditional and valued aspect of the historic environment in Scotland
and the low, thatched crofter’s cottage was once a familiar site in rural
areas. Such buildings require regular maintenance, and they deteriorate
rapidly once abandoned. The number of thatched buildings in Scotland has
diminished dramatically since the mid-19th century when other more
durable materials became available. 
In Perth and Kinross 31 buildings were surveyed of which 21 were found to
still have their thatch remaining. The main concentration of thatched
buildings in Perth and Kinross are in the village of Dull which has nine, with
a further five in Aberfeldy and four in Rait. The vast majority of the
buildings surveyed were occupied and in residential use although this
number may well have changed in the intervening. At the time of the
survey one building was listed as vacant, and two as ruins. 
Church of Scotland Properties for Sale
The Church of Scotland Central Properties Department has responsibility
for redevelopment of church property and managing existing properties.
Properties which become surplus to requirement and are being offered for
sale are listed on the Church’s website. Whilst it is unlikely that large
numbers of buildings will become available (currently there are only two in
Perth and Kinross) some of those which do may be complicated and
expensive to redevelop and are therefore at a higher risk of lying vacant.

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PKC Housing Land Audit 2023
The 2023 Housing Land Audit provides information on the implementation
of the current development plan spatial strategy, some of which is on
brownfield land. The annual audit does not currently include in the
published version the proportion of the housing land supply which is on
brownfield land. This data has, however, been collected in the housing
land database and is presented in the following chart. The greenfield
figures are skewed somewhat by the inclusion of the large strategic land
allocations to the west and northwest of Perth. 
Source: Perth and Kinross Housing Land Database 
The chart below shows the total capacity of sites by the year they
completed split by greenfield and brownfield (please note these are total
site capacities not annual completions). 
Source: Perth and Kinross Housing Land Database 
The annual audit provides information on planning applications and their
implementation. This, together with the more detailed information in the
housing land database, allows the Council to understand what percentage
of development is on brownfield land, and to assess whether the Local
Housing Strategy aim to deliver 50% of affordable houses on brownfield
sites is being achieved. The audit can also help identify legacy brownfield
sites which are not progressing. 
0 5000 10000 15000 20000
Greenfield
Brownfield
Total capacity of
Greenfield / Brownfield sites
at 2023
Total supply Allocated supply
0
100
200
300
400
500
600
700
800
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
Total capacity of completed sites by
Greenfield / Brownfield split
Brownfield Greenfield
Linear (Brownfield) Linear (Greenfield)

Page 244

Perth and Kinross City and Town Centre Retail Study
The Study includes an assessment of the health and vitality of Perth city
centre and Aberfeldy, Alyth, Auchterarder, Blairgowrie, Coupar Angus,
Crieff, Dunkeld, Kinross and Pitlochry town centres. Key to the
consideration of this topic is the breakdown of retail and other floorspaces
in the centres, including the change in vacant floorspace. 
Centre 2016 vacant
sqm gross
2022 vacant
sqm gross
Difference
2016-22
%
change
Perth 18,470 21,321 +2,851 15
Auchterarder 320 762 +442 138
Blairgowrie 610 2,146 +1,536 252
Crieff 3,720 4,422 +702 19
Kinross 1,250 687 -563 -45
Pitlochry 1,480 2,100 +620 42
Source: Perth and Kinross City and Town Centre Retail Study 
Although the biggest increase in vacant floorspace has been in Perth, this
only amounts to a 15% change. Proportionately the biggest increase has
been in Blairgowrie where the amount of vacant floorspace was around
3.5 times higher in 2022 than it was in 2016. The only centre which has
reduced its vacant floorspace between 2016 and 2022 is Kinross. 
Local Housing Strategy Framework 2022-27 and Action Plan
The LHS identifies an action to maximise the potential to generate more
homes through brownfield regeneration which encourages mixed
developments and change of use for vacant properties (LHS Action 1.3).
The aim is to deliver 50% affordable homes through brownfield
regeneration and change of use for vacant properties, and to maintain a
53% / 47% split between urban and rural areas. Key to achieving this is
developing a register of potential brownfield regeneration sites, and a
register of potential sites that would be suitable as housing subject to
change of use. 
PKC Reusing Empty Properties and Elected Member Briefing – Vacant
and Eyesore Property Taskforce Update
PKC recognises that disused shops and offices and long-term empty homes
can have a damaging effect on the local community and economy. Poorly
maintained empty homes detract from the quality of the local
environment and can attract anti-social behaviour. Leaving properties
empty contribute to the shortage of affordable housing and increases the
pressure for development on greenfield sites. 
The benefits of bringing properties back into use include:
• Increasing the available housing for local people
• Community regeneration and improving community wellbeing and
pride
• Sustaining rural communities
• Discouraging anti-social behaviour / crime and allowing other
residents to feel safe
• Restoring confidence in local property markets 
The Council’s Empty Homes Initiative provides grants to enable unused
properties to be used again. 
The PKC Vacant and Eyesore Property Taskforce brings together various
Council services and was created to focus on targeted properties within
settlement centres, or other prominent locations, across Perth and Kinross
that are either empty or subject to significant physical impairment. 51
buildings are currently actively being considered, ranked in terms of
priority, although the list of properties is reviewed on an on-going basis.

Page 245

Encouraging the reuse of empty properties or the repair of buildings
suffering from neglect brings in more footfall for local businesses and adds
to the vitality, amenity and civic pride of the area. All of this brings
significant benefits to our local centres, including improved economic
performance. 
Of the 51 properties actively being considered, nine have a development
proposal being implemented with funding in place, 13 have a development
proposal being developed / building safeguarding work or a meanwhile use
in place, and on 17 the Council have engaged with the owner. The
remaining 13 have had no engagement from the owner. 
Projects in progress or under discussion include:
• a 2-bedroom city centre flat for affordable rent
• studio apartments
• flats providing affordable housing and emergency accommodation
for young people exiting care
• the successful compulsory purchase of a property to be sold for an
open market house
• the creation of community space
• property conversion to office and flat
• the demolition by the Council of dangerous buildings
• discussions with owners on conversion of their property to
residential use 
Big Place Conversation
Issues and priorities relating to brownfield, vacant and derelict land and
empty buildings identified through the BPC Place Standard discussions
included: 
• Streets, squares and buildings – vacant and derelict sites are a common
issue that have a negative impact on the safety, appearance, and
vitality of local communities. The repurposing of some vacant and
derelict sites has brought a range of benefits to local communities
including improved safety, aesthetics, and delivery of new commercial
or residential opportunities. More repurposing of vacant and derelict
sites for high demand uses given local contexts, such as community,
commercial or residential purposes, was suggested. 
• Feeling safe – vacant and derelict buildings raise safety concerns.
Improving the appearance of, and stronger enforcement around, key
buildings and land was suggested including the reuse of vacant and
derelict properties. 
• Care and maintenance – some specific buildings and public places
appear derelict or unkempt. The redevelopment of key vacant and
derelict buildings and building on brownfield land rather than
greenfield were suggested. 
• Natural spaces – A need to safeguard the environment with effective
policy measures, including promoting brownfield regeneration, was
identified. 
• Homes and community – a need to prioritise brownfield development
was suggested. 
In addition to the above, comments were also gathered through the BPC
relating to specific locations. These will be used in preparing the Proposed
Plan. 
Summary of Implications for the Proposed Plan:
The currently available evidence in relation to brownfield, vacant and
derelict land and empty buildings in Perth and Kinross indicates that the

Page 246

overall proportion of such land is low. This is positive in terms of visual and
environmental impact but does mean that the contribution of such sites
towards meeting overall land requirements could be limited. 
There will also be key localised impacts which the Proposed Plan will need
to consider in developing a spatial strategy. Firstly, the impact on the
percentage of the population which is living near to derelict land. In
particular the 11.5% of the population of Perth and Kinross who are living
within less than 500m of derelict land. 
Second is the significant increase in retail vacancies in some town centres.
This is particularly stark in Blairgowrie and Auchterarder although all of the
key centres excluding Kinross have seen an increase in retail vacancy rates. 
NPF4 expects LDPs to set out the opportunities for the sustainable reuse of
brownfield land including vacant and derelict land and empty buildings.
The national framework also seeks to maximise the use of existing assets
and minimise additional land take. The identification of sites and strategies
for the potential reuse of brownfield, vacant and derelict land and empty
buildings will therefore impact on the spatial strategy for the Proposed
Plan. 
In assessing brownfield sites, consideration will need to be given to the
marketability and viability of these sites to ensure that those which are
allocated for development can and will be delivered, and that the overall
contribution from brownfield sites towards meeting land requirements is
realistic. Consideration will also need to be given to how to deal with those
buildings which have fallen out of use, but which may be particularly
complicated and / or expensive to redevelop or repurpose. 
Whilst the SVDLS is an existing source of information on vacant and
derelict land, alongside the other sources identified above, the Council’s
own Urban Capacity Brownfield Study will provide a more comprehensive
record of all land and buildings which have the potential for re-use or
redevelopment. 
In preparing the spatial strategy for the Proposed Plan there will also be
linkages to other topics including: 
• 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
• Blue-green infrastructure networks and the potential of some
brownfield sites to establish nature-based solutions, for example,
for surface water management
• Flood risk and the potential to bring brownfield land to uses that
support the management of increasing flood risk from climate
change
• 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
• City, town, local and commercial centres and the increasing number
of vacant units which some centres are experiencing 
Gaps, Uncertainties or Key Issues Raised:
Identification of sites 
Not all brownfield land and vacant buildings will be included within the
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 NPF 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.

Page 247

Key to achieving LHS 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: 
• green sites with few constraints and the potential for delivery in 1-2
years
• amber sites with a small number of significant constraints (or a
large number of small constraints) that make feasibility less certain
and where further assessment would be clarified via a planning
application
• 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
particular 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. 
Summary of Stakeholder Engagement:
Big Place Conversation 
The Council carried out its ‘Big Place Conversation’ exercise to kick start
the LDP3 process across Perth and Kinross communities during most of
2023. This was a substantial exercise involving over 100 events throughout
the Council area. The events ranged from drop-in information sessions,
meetings, and online surveys to workshops and online sessions using the
Place Standard Tool to capture the views of local communities about
different aspects of their places. The results of the BPC are summarised as
part of a separate report on the outcomes and findings across the different
locality areas.

Page 248

LDP3 Evidence Report Topic Papers
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.  As part of our consultation process for LDP3 Topic
Papers we welcomed the views of our key stakeholders (who were
contacted specifically via email regarding the consultation exercise) and
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 LDP.

Page 249

Statements of Agreement / Dispute:
11 responses were received on our Brownfield, Vacant and Derelict Land and Empty Buildings Topic Paper, three 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. A summary of
these comments, their status, and the Council’s response are provided in the table below. One respondent on the Brownfield, Vacant and Derelict Land and
Empty Buildings issue wished their comments to be treated as a formal dispute to the Evidence Report. That response has been highlighted in red in the
table. 
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
NatureScot Agree List of Evidence/Datasets: 
Table setting out data links (Section 1.5) is clear, and it is
useful to have this early on in the topic paper. 
Summary of Implications for Proposed Plan (PP): 
Welcome the holistic and proportionate section on the
implications for the Proposed Plan in Section 3. 
Further Comments: 
The inclusion of policy connections is a useful addition to
help ensure read across between topic papers. We strongly
support the link to biodiversity here. However, we
recommend including all of the connections set out in NPF4. 
Formal Dispute: No 
Agreed. All policy links now
included
Historic
Environment
Scotland
Agree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Further Comments: 
The Summary of Evidence section
of the Evidence Report has been
amended to reflect the more

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Welcome inclusion of the Buildings at Risk Register and have
provided additional analysis and commentary on this, and a
dataset for use under licence. 
Efforts are made to ensure that the Register is up to date, but
there may be disused heritage buildings in Perth and Kinross
that do not appear on the Register. Evidence gathered within
the Vacant and Derelict Land Register, SPAB Thatched
Building Survey, and the Empty Homes service could help
identify these sites.  Additionally, the Church of Scotland’s
extensive estate review may result in more churches
becoming redundant in Perth and Kinross. 
Formal Dispute: No 
detailed and up-to-date
information provided by HES.
Scottish Water Agree List of Evidence/Datasets: No comments 
Summary of Implications for Proposed Plan (PP): 
Strongly encourage approaches to bring vacant and derelict
land to uses that support the management of increasing
flood risk from climate change. Vacant and derelict land use
to establish nature-based solutions and blue-green
infrastructure networks, as an alternative to traditional
development, is something Scottish Water will work with
partner agencies to explore. 
Further Comments: 
Supports the high-level aims laid out in the topic paper. 
Applicants must consider Scottish Water’s Surface Water
Policy when designing for brownfield sites and appropriate
Scottish Water’s comments have
helped inform the Summary of
Implications for the Proposed Plan
section of the Evidence Report.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
above ground sustainable surface water drainage must be
incorporated into early design of new developments as
connection to combined networks is not promoted 
Formal Dispute: No 
Errol Community
Council
Disagree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): 
There is insufficient data to determine what is considered
vacant and derelict in the Errol Community Council Area. The
map in section 2 suggests there is some derelict land but it is
not clear where these areas are. The impacts have not been
fully outlined, sufficient for us to understand them at this
stage. 
Formal Dispute: No 
The Brownfield, Vacant and
Derelict Land, and Empty Buildings
Topic Paper set out the data
sources which will be referenced in
the Evidence Report. The Evidence
Report ‘should include a
proportionate summary of the
baseline data and information. This
early stage is to establish what to
plan for, with specific locations
being the focus of the later
Proposed Plan. Site specific
matters should not be included in
the Evidence Report’ (Local
Development Planning Guidance
para. 83).
Earn Community
Council 
Agree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Further Comments: 
Note the results of the Brownfield Study not expected until
summer 2025. 
Formal Dispute: No 
No action required

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Homes for
Scotland
Disagree List of Evidence/Datasets:
The 2023 Housing Land Audit provides information on the
implementation of the current spatial strategy, some of
which is on brownfield land, and should be included as
evidence. The Audit also provides information on planning
applications and their implementation which allows the
Council to understand what percentage of development is in
brownfield sites and whether the Local Housing Strategy
Framework 2022-27 aim to deliver 50% of affordable homes
on brownfield sites is being met. Additionally, legacy
brownfield sites can be identified and where relevant given
further assessment as part of a future 'Call for Ideas’
exercise. 
It is vital to highlight the need for the spatial strategy in the
next LDP to consider both sustainable and marketable
locations for new developments. If a sustainable site is not in
a marketable location, it is unlikely to be delivered and the
housing requirement will not be met. Any information being
used to support a spatial strategy must be up to date. 
Summary of Implications for Proposed Plan (PP): 
It is welcomed that the Council recognise that there may be
benefits for biodiversity rather than redeveloping a
brownfield site. In addition to this the topic paper on Blue
Green Infrastructure along with the Urban Capacity
Brownfield Study, that the Council propose to undertake,
require to take cognisance of the fact that brownfield sites
could also provide opportunities for surface water
management. 
Homes for Scotland’s comments
have helped inform the Summary
of Evidence, and the Summary of
Implications for the Proposed Plan
sections of the Evidence Report.
The 2023 Housing Land Audit has
been included as evidence.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Further Comments: 
All allocated sites must be clearly deliverable and viable. The
socio-economic benefits of home building cannot be
understated. Members contribute millions of pounds
annually to infrastructure investment across the district and
their role as a principal funder of future investments must be
fully recognised, as should their role in the journey towards
net zero through the delivery of increasingly energy efficient
homes as well as local living neighbourhoods. 
Formal Dispute: Homes for Scotland have indicated that they
do not wish to formally dispute this issue subject to greater
recognition of the Housing Land Audit as a source of evidence
and potential for brownfield sites. 
Savills on behalf of
Scone Estate
Neither  List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Further Comments: 
An over reliance on brownfield sites will cause PKC significant
issues in finding sufficient new development land. 
Formal Dispute: No 
Comments have helped inform the
Summary of Implications for the
Proposed Plan section of the
Evidence Report.
Savills on behalf of
Dupplin Estate
Neither List of Evidence/Datasets: No comments 
Summary of Implications for Proposed Plan (PP): No
comments 
Further Comments: 
Comments have helped inform the
Summary of Implications for the
Proposed Plan section of the
Evidence Report.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
An over reliance on brownfield sites will cause PKC significant
issues in finding sufficient new development land. Across
Perth city, there is a minimal amount of brownfield land and
SEPA's heightened flood risk restrictions means that much of
Perth city would not be able to be developed in any case.
These various data fields should be carefully overlaid to make
sure that sufficient development land is allocated. 
Formal Dispute: No 
Not provided  Disagree List of Evidence/Datasets:
Topic Paper is an inaccurate assessment of the brownfield
land in the PKC Area. It appears to be predominantly based
on the SVDLS - which is out of date, was not properly
consulted on (many people not aware it exists) and does not
include the full extent of Brownfield sites across the PKC
Area. It does not, for example, include the largest brownfield
site in PKC – Errol Airfield. 
Tayside Landscape Character Assessment may also be a
useful reference. 
Summary of Implications for Proposed Plan (PP): 
‘The currently available evidence in relation to brownfield,
vacant and derelict land and empty buildings in Perth and
Kinross indicates that the overall proportion of such land is
low’ requires to be reviewed and possibly revised, once the
true extent of Brownfield land across the PKC area is properly
considered. Reference requires to be made to the largest
Brownfield/Derelict Brownfield site in the PKC Area – Errol
Airfield. 
The Brownfield, Vacant and
Derelict Land, and Empty Buildings
Topic Paper set out the data
sources which will be referenced in
the Evidence Report. The Evidence
Report ‘should include a
proportionate summary of the
baseline data and information. This
early stage is to establish what to
plan for, with specific locations
being the focus of the later
Proposed Plan. Site specific
matters should not be included in
the Evidence Report’ (Local
Development Planning Guidance
para. 83). It is not therefore
appropriate to make reference to
specific sites at this stage. 
It is, however, acknowledged that
not all brownfield land and vacant

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response 
NPF4 puts a significant emphasis on developing brownfield
sites ahead of greenfield. Accordingly, if the extent of
brownfield / derelict land is not properly calculated the
implication would be that the evidence used to produce LPD3
is incorrect and not taking cognisance of NPF4's priority. 
Furthermore, it opens the LDP process to be challenged. 
Formal Dispute: The respondent wishes their comments to
be treated as a formal dispute on the following grounds: 
1. The accuracy of the total brownfield / derelict area across
the PKC area out with urban areas (24 hectares)
2. The extent of brownfield / derelict land at Errol Airfield (it
would surpass the 24 hectares over the total PKC Area)
3. The omission of any reference to Errol Airfield - the largest
brownfield site in the PKC area 
buildings will be included in the
SVDLS and this is identified as a
gap in the data. Reference is made
to the register of potential
brownfield regeneration sites
which is currently being developed
and which will consider a wider
range of sites than the SVDLS. This
register will also help inform the
Proposed Plan. 
Regarding Landscape Character
Assessment, this will be included
within the Profile of the Perth and
Kinross Area of the Evidence
Report. 
The Implications for the Proposed
Plan section indicates that, based
on the currently available
evidence, the overall proportion of
brownfield, vacant and derelict
land and empty buildings in Perth
and Kinross is low. This statement
is considered appropriate. The
Implications section also, however,
acknowledges that the Urban
Capacity Brownfield Study will
provide a more comprehensive
record of all sites. As suggested in
the comments, an additional

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
reference will be made in this
section to the priority NPF gives to
brownfield reuse over greenfield. 
Conclusion on dispute:
Each of the grounds of dispute
have been addressed and / or
incorporated into the Evidence
Report. The dispute is therefore
considered resolved. 
Not provided Disagree List of Evidence/Datasets: No comments 
Summary of Implications for Proposed Plan (PP): 
Vacant sites when they come up should be looked at as an
opportunity to reduce existing and future flood risk within
urban areas. They might provide opportunities to build in
underground storage for surface waters and excessive foul
waters to reduce surcharging from manholes in the built-up
areas of communities. 
Further Comments: No 
Formal Dispute: No 
Comments have helped inform the
Summary of Implications for the
Proposed Plan section of the
Evidence Report.
Not provided  Agree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Further Comments: 
Note the results of the Brownfield Study not expected until
summer 2025.
No action required

Page 257

Respondent Agree or
Dispute
Summary of Comments PKC’s Response 
Formal Dispute: No

Page 258

Issue: Coastal Development and Aquaculture
Corresponding NPF4 Policy/Policies: 
• NPF4 - policy 10 coastal development, and 32 Aquaculture and
policy 10 coastal development
• Other key NPF4 policy connections – 1 Tackling the climate and
nature crises 2 Climate mitigation and enhancement, 3 Biodiversity,
4 Natural Places, 7 Historic assets and places, 11 Energy 14 Design,
quality and place, 15 Local Living and 20 minute neighbourhoods,
18 Infrastructure first, 19 Rural development, 20 Blue and green
infrastructure, 21 Play, recreation and sport, 22 Flood risk and water
management, 23 Health and Safety, 25 Community wealth building,
26 Business and industry,  30 Tourism
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 011: Coastal Development and Aquaculture
(https://consult.pkc.gov.uk/communities/topicpapers/supporting_doc
uments/TP011_Coastal.pdf)
Information required by the Act and NPF4 regarding the topic:
In line with the requirements of the Act 15 (5) this paper will have regard
to:
• principal physical, and environmental characteristics of the district in
relation to its coast
In line with the requirements of Regulation 9, this paper will have regard
to:
• the national marine plan
• any regional marine plan
Additionally, under NPF4 Policy 10, NPF4 expects Local Development Plans
to:
• consider how to adapt coastlines to the impacts of climate change. This
should recognise that rising sea levels and more extreme weather events
resulting from climate change will potentially have a significant impact on
coastal and islands areas, and take a precautionary approach to flood risk
including by inundation
• Spatial strategies should reflect the diversity of coastal areas and
opportunities to use nature-based solutions to improve the resilience of
coastal communities and assets. LDP spatial strategies should identify
areas of developed and undeveloped coast and should align with national,
sectoral and regional marine plans.
Additionally, under NPF4 Policy 32, NPF4 expects Local Development Plans
to:
• guide new aquaculture development in line with National and Regional
Marine Planning
• minimise adverse environmental impacts, including cumulative impacts,
that arise from other existing and planned aquaculture developments in
the area while also reflecting industry needs
The Scottish Government’s Local Development Plan Guidance (May 2023)
under it’s ‘Step by step guide’ provides advice on relevant evidence for the
NPF4 policy topics to help planning authorities in considering the national
planning policies when preparing their Evidence Report. Under Policy 10,
this guidance expects Local Development Plans to:

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• prepare, or review for spatial implications any Coastal Change
Adaptation Plans (CCAPs), where available
• reflect the diversity of coastal areas and opportunities to use nature-
based solutions to improve the resilience of coastal communities and
assets
Whilst under Policy 32, NPF4 expects Local Development Plans to:
• consider baseline information on existing aquaculture sites, and
projected growth demand
• consider key environmental constraints 
•  consider baseline information on the number of existing sites and levels of
employment
• potentially identify aquaculture areas with key constraints, and areas for
potential growth
• where appropriate, seek to consider areas where both terrestrial and
marine environments overlap and where potential developments in both
environments could co-exist.
Links to Evidence:
Flood risk information
• SEPA medium future flood risk 2080 coastal flood risk mapping
• SEPA Flood Risk and Land Use Vulnerability Guidance
• Planning Information Note 4 (PIN4) SEPA position on development
protected by a flood protection scheme
• Tay Flood Risk Management Plan
• Tay Local Flood Risk Management Plan
• Climate Change Master Action Plan 2024 (Core Doc Ref: CD6)
• Climate Change Risk and Opportunity Assessment (August 2024)
• 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)
• Big Place conversation summary report
• Big Place conversation Carse of Gowrie summary report
Aquaculture information:
• Scottish Coastal Observatory Data  
• Marine Scotland National Marine Plan
• Marine Scotland National Marine Plan 2
• Nature Scot’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 & Locational Guidelines

Page 260

Summary of Evidence:
Principal physical, and environmental characteristics of the district
The Inner Tay Estuary is a valuable resource in terms of its landscape,
nature conservation, recreation and tourism and employment benefits.
The influence of spring tides penetrates inland to about 4 km beyond
Perth, but saline conditions occur only as far upstream as Newburgh. The
reedbeds in the Tay Estuary are the largest continuous stand of this habitat
anywhere in Britain.1
The coast faces a range of development pressures and future threats from
sea level rise and flood risk. The current Perth and Kinross Local
Development Plan (LDP) 2019 identifies appropriate opportunities for
development within the settlements that lie along this coastline and its
policies allow limited development outwith these settlements with
additional controls applied within the Perth Greenbelt which covers areas
from the edge of Perth to Inchyra/Balhepburn to the west, and within
environmental designated and flood risk areas. 
In terms of key environmental constraints, abstraction will need to be
carefully managed in the context of climate change to protect water levels
and in 2018 the River Ericht in Blairgowrie saw some of its lowest ever
water levels. Following discussions, SEPA worked to minimise the amount
of water taken from the river via the lade by working with fish farms in the
area. Applications for new finfish facilities, and SEPA abstraction
applications, will need to be carefully managed in the context of climate
change, to protect water levels. 
1 Tayside biodiversity partnership, Section2Coast1.pdf (taysidebiodiversity.co.uk)
GIS data from Marine Scotland on Shellfish water protected areas. This is
not relevant to the Proposed Plan as there are no Shellfish waters
protected areas within PKC. Additionally, information on sea lice from any
risk assessment framework and any relevant mitigation measures will not
be relevant to the Proposed Plan due to presumption against finfish farms
on east coast.
Flood risk information
SEPA Future Flood Maps - SEPA medium likelihood future flood risk 2080
coastal flood risk mapping and SEPA medium likelihood future flood risk
2080 river 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. 
Planning information note 4 SEPA position on development protected by a
flood protection scheme supports interpretation of NPF4 policy 22 Flood
risk and water management. This note will be referred to when
undertaking site assessments for the Proposed Plan.
SEPA Flood Risk and Land Use Vulnerability Guidance
supports interpretation of NPF4 policy 22 Flood risk and water
management. This note will be referred to when undertaking site
assessments for the Proposed Plan.
Strategic Environmental Assessment | Scottish Environment Protection
Agency (SEPA) provides a template for Strategic Environmental Assessment

Page 261

site assessment which will be used at Proposed Plan stage (although
additions may be added as necessary).
Tay Flood Risk Management Plan published by SEPA this sets out the
actions needed to reduce overall, and avoid an increase in flood risk flood
risk. The Proposed plan will support its implementation. 
Tay Local Flood Risk Management Plan published by Perth and Kinross
Council this sets out in more detail how the actions of the Tay Flood Risk
management plan will be achieved. The Proposed plan will support its
implementation.
Perth and Kinross Council Strategic Flood Risk Assessment (Core Doc Ref:
25) has been prepared to support the Flood Risk and Water Management
topic paper. Please refer to the Flood Risk and Water Management Issue in
Appendix B8 for more information.
Coastal planning
Perth Harbour Business Plan Update and Future Options Appraisal
committee report February 2023 which presented a preferred option for
its cessation as a commercial port. This was agreed subject to testing the
market for interest in a potential long lease opportunity whilst the formal
consultation requirements are being met. This clarifies that regeneration
of the harbour should be considered through the Proposed Plan.
Dynamic Coast webmaps broad planning tool makes necessary
assumptions about our future climate and management action. If there are
areas affected this information can be used to inform site selection, and
settlement summary text in the Proposed Plan. 
Mapping coastal erosion disadvantage in Scotland (dynamiccoast.com)
paper which couples anticipated erosion risk with consideration of the
social vulnerability of Scotland’s coastal communities, to produce Coastal
Erosion Disadvantage maps. This paper is not relevant to the preparation
of the Proposed Plan as Perth and Kinross is considered tidal/estuarine and
it does not feature in any of the maps and tables which consider coastal
erosion vulnerability or disadvantage. 
Coastal Change Adaptation Guidance supports Local Authorities to
develop their Coastal Change Adaption Plans (CCAP). PKC has received
funds to prepare a Coastal Change Adaption Plan. 
Climate Change Master Action Plan (Core Doc Ref: CD6) has an adaptation
plan that is integrated with our mitigation plan. This can be viewed under
the “Climate Resilience” Delivery Theme. The Proposed Plan will support
Natural Flood Risk Management and Flood Protection measures identified
to assist with the delivery of this Action Plan.
Climate Change Risk and Opportunity Assessment (August 2024) is a risk
and opportunities register, in response to the increasing risks and impacts
of current and future climate change considering risks to the organisation
and area. The Proposed Plan will support delivery of the Flood Protection
measures identified. 
TAYplan Strategic Development Plan (SDP) 2016-2036 identified the
Perth and Kinross coastline as having unspoiled areas. See extract in (Core
Doc Ref: CD8) as this plan is no longer available online. This may be relevant
to the identification of undeveloped coastal areas in the Proposed Plan.
Assessment of the coastline carried out for the Perth and Kinross
Structure Plan approved June 2003 which identifies that there are no areas

Page 262

of isolated/unspoiled coastline. See extract in (Core Doc Ref: CD7) as this
plan is not available online. This may be relevant to the identification of
undeveloped coastal areas in the Proposed Plan.
Aquaculture Information
Marine Scotland National Marine Plan 2015 supports development and
activity in Scotland’s seas while incorporating environmental protection
into marine decision making to achieve sustainable management of marine
resources. 
Marine Scotland National Marine Plan 2 consultation ended January 25th
2024. This plan will provides appropriate policy context for marine
planning, and given the limited area and local context in LDP3 is not
necessary.
Scottish Coastal Observatory Data  holds monitoring data collected as part
of the Scottish Coastal Observatory. Data will be added to the Forth and
Tay section as regional marine planning is taken forward. Not relevant to
the Proposed Plan at the moment and timescales for the regional marine
plan are unknown.
Marine Scotland’s Planning & Locational Guidelines is not relevant to the
Proposed Plan as there is a presumption against finfish farms on east
coast. 
NatureScot’s planning and development guidance on marine aquaculture
and other relevant data is mostly relevant to marine proposals with
landscape guidance for lochs, and shore-based facilities. This guidance is
not relevant for the Proposed Plan but it could be used at planning
application stage.
SEPA revised regulatory framework and sector plan is mostly relevant to
marine fish farming it sets out how SEPA s propose to regulate the finfish
aquaculture sector. This will not be relevant to the Proposed Plan due to
the presumption against any proposals on the east coast.
GIS data from Marine Scotland on Shellfish water protected areas. This is
not relevant to the Proposed Plan as there are no Shellfish waters
protected areas within PKC.
Information on sea lice from any risk assessment framework and any
relevant mitigation measures will not be relevant to the Proposed Plan
due to presumption against finfish farms on east coast.
Summary of Implications for the Proposed Plan:
Flood risk
The Strategic Flood Risk Assessment (SFRA) provides the flood risk
information needed to inform the Proposed Plan. Flood risk is considered
more fully in the Flood Risk and Water Management issue in Appendix B5. 
PKC will base the LDP site assessment on the SEA checklist prepared by the
key agencies to assess potential Proposed Plan allocations, although there
are likely to be some additions. 
The SFRA will primarily support the Local Development Plan in responding
to the spatial implications of NPF4 Policy 22 by promoting avoidance as a
first principle and reducing the vulnerability of existing and future
development to flooding as set out within the relevant SEPA Flood Risk

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Management Strategy and the Local Flood Risk Management Plans. The
Strategic Flood Risk Assessment and SEA site assessments will analyse
flood risk as per NPF4 policy 22. 
Coastal Planning 
Following the Council's decision in 2023 to close Perth Harbour, Transport
Scotland is assessing a Revision Order for Scottish Ministers' consideration.
Until the Order is confirmed, Perth and Kinross Council remains the
Statutory Harbour Authority, meaning that at present, the harbour
remains open for commercial traffic. On sites such as Perth Harbour where
there are policy tensions between brownfield/regeneration and flood risk,
there will be close liaison with Perth and Kinross Flood team and SEPA to
fully understand the nature of the risk, and the appropriate response,
using the most up to date guidance available at the time. 
Becoming ‘sea level wise’ is required of the planning system in order to
adapt to future risks. A small area at Kingoodie was identified as having a
coastal erosion risk in LDP2 based on the National Coastal Change
Assessment at that time. However, no areas are now shown at risk in the
more recent Dynamic Coast webmaps Future Erosion 2100 High emissions
scenario. This mapping will not inform site selection, nor settlement
summary text in the Proposed Plan, unless it is updated, and updated
mapping indicates areas at risk.
Mapping coastal erosion disadvantage in Scotland (dynamiccoast.com)
paper couples anticipated erosion risk with consideration of the social
vulnerability of Scotland’s coastal communities, to produce Coastal Erosion
Disadvantage maps. This paper is not relevant to the preparation of the
Proposed Plan as Perth and Kinross is considered tidal/estuarine and it
does not feature in any of the maps and tables which consider coastal
erosion vulnerability or disadvantage.
Perth and Kinross Council does not have a Coastal Change Adaptation Plan
in place. However, there is climate change adaptation is integrated within
the Climate Change Master Action Plan mitigation plan. This can be viewed
under the “Climate Resilience” Delivery Theme.  Based on the Dynamic
Coast webmaps, and observing there are no areas at risk from coastal
erosion, there does not appear to be significant concerns related to this
coastline. 
There is a changing national policy context with regard for the classification
of our coastline. Whilst Scottish Planning Policy (SPP) 2014 referred to the
developed coast, areas subject to significant constraint, and unspoiled
coastline, NPF4 only refers to the undeveloped coastline. The TAYplan
Strategic Development Plan (SDP) 2016-2036 identified its coastline as
having unspoiled areas within it whose nature and extent would be
defined through the Local Development Plans. The Reporter considering
this matter during Examination of the Local Development Plan 2019 agreed
with Perth and Kinross Council and considered there is no remote or
unspoiled coastline.
Aquaculture Planning 
Marine Scotland National Marine Plan 2015 supports development and
activity in Scotland’s seas while incorporating environmental protection
into marine decision making to achieve sustainable management of marine
resources, whilst the Marine Scotland National Marine Plan 2 consultation
ended January 25th 2025.

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Scottish Coastal Observatory Data holds monitoring data collected as part
of the Scottish Coastal Observatory. Data will be added to the Forth and
Tay section as regional marine planning is taken forward. This is not
relevant to the Proposed Plan at the moment and timescales for the
regional marine plan are unknown. Marine Scotland’s Planning &
Locational Guidelines is also not relevant to the Proposed Plan as there is a
presumption against finfish farms on east coast. 
NatureScot’s planning and development guidance on marine aquaculture
and other relevant data is mostly relevant to marine proposals with
landscape guidance for lochs, and shore-based facilities. This guidance is
not relevant for the Proposed Plan but it could be used at planning
application stage.
SEPA revised regulatory framework and sector plan is mostly relevant to
marine fish farming it sets out how SEPA s propose to regulate the finfish
aquaculture sector. This will not be relevant to the Proposed Plan due to
the presumption against any proposals on the east coast.
There is a limited coastline, and a limited aquaculture industry presence
within Perth and Kinross. Therefore, there has been no need for a local
aquaculture policy in the current Local Development Plan 2.
There are some freshwater finfish operators, focused on both the
freshwater hatchery or freshwater adult growth stages. There have been a
handful of planning applications for freshwater finfish facilities over the
past 25 years, so there may continue to be some limited growth in this
sector. There are 8 fish farm sites operating within Perth and Kinross:
Frandy Hatchery (tanks and hatchery), St Mungo’s Trout Farm (tanks and
hatchery,) College Mill Almondbank (tanks and raceways), Sundial Cottage,
Guildtown (hatchery and tanks), Kindrochet Fish Farm (hatchery, ponds
and raceways), Loch Earn (fish cages); Loch Tay (fish cages); Blairgowrie
West Mill (freshwater tanks and hatchery). There are also two terrestrial
marine aquaculture sites at, Braelin Water, on the North Queich. There is
also the SOAFD Salmon Research Unit Cromwell Park, Almondbank. The
SOAFD Board is made up of salmon fishery owners or their
representatives. The Board has offices and a hatchery and employs water
fisheries officers and biologist. Their work includes enforcement, river
management, conservation and scientific research.
Gaps, Uncertainties or Key Issues Raised: 
Flood risk
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.
Also, should the Proposed Plan consider 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. This should happen prior to
allocation in the Proposed Plan. During preparation of the Proposed Plan
PKC will require the developer/landowner to prepare an FRA where there
is a potential risk of flooding within a site, to determine if it is suitable for
allocation. This will require an FRA if the site includes any 200 year plus
climate change or 1,000 year flood risk areas, whichever is the greater

Page 265

extent, as identified in the SFRA, taking account of both SEPA and flood
study mapping.
Coastal Planning
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. 
NPF4 Policy 10 Coastal Development states that, ‘Development proposals
in undeveloped coastal areas will only be supported where they: i. are
necessary to support the blue economy, net zero emissions or to
contribute to the economy or wellbeing of communities whose livelihood
depend on marine or coastal activities.’ The implications for potential
development within any undeveloped coastal areas identified would be
significant in Perth and Kinross as these estuarine communities do not
depend on marine or coastal activities for their livelihood. 
The straightforward interpretation is that the undeveloped coastline of the
SPP 2014 and the Perth and Kinross Structure Plan 2003, would have the
same definition as the undeveloped coastline of NPF4 in 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, it is unclear if NPF4’s intention is
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.
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 later definition, then the Proposed Plan could identify its
undeveloped coast accordingly and potentially define this as either 1km
inland (to align with the outer distance used by the Dynamic Coast for
mapping of assets and vulnerability) or 0.5 km 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.
Unfortunately, responses to the topic paper engagement did not clarify the
definition of undeveloped coastline, and this matter will need to be
followed up with Nature Scot, and Scottish Government whilst preparing
the Proposed Plan.

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Based on the Dynamic Coast webmaps, and observing there are no areas
at risk from coastal erosion, there does not appear to be significant
concerns related to this coastline. However, PKC has received funding for a
Coastal Change Adaption Plan, and if it is available timeously it will inform
the Proposed plan.
Blue green infrastructure mapping is also being prepared to support the
Proposed Plan and this will synthesize biodiversity, food growing, natural
flood risk management, active travel, and local living opportunities into
both strategic scale and settlement-based mapping and analysis. This will
identify existing green and blue infrastructure to be protected, within our
coastal areas, and opportunities to increase and improve green and blue
infrastructure, and networks which connect areas for people and nature.
More information on this can be found in the Blue and Green
Infrastructure Issue in Appendix B3.
Aquaculture Planning
There is a continuing presumption against further marine finfish farm
developments on the north and east coasts to safeguard migratory fish
species. It is anticipated that there could be some limited growth of the
aquaculture industry, but there is not much existing activity and there is
limited potential, so a light touch, relying on national policy and guidance
is appropriate. 
The NPF4 policy framework, and 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 in LDP3 a local
policy is not necessary.
Summary of Stakeholder Engagement: 
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 week during
July and August 2024.  As part of our consultation process for LDP3 Topic
Papers we welcomed the views of our key stakeholders (who were
contacted specifically via email regarding the consultation exercise) and
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.
The consultation on this topic paper included a wide range of organisations
with an interest in coastal issues, and notably included the Tay Estuary
Forum who bring together organisations and individuals with a common
interest in the welfare and sustainable use of the Tay Estuary and adjacent
coastline, Marine Scotland, and the James Hutton Institute.

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The Big Place Conversation engagement did not directly ask questions on
coastal specific concerns; however, flood risk affects coastal communities.
The Big Place conversation summary report has a feeling safe indicator,
where participants consider how safe do people feel in their place. A
summary of the comments on this topic identifies that flood risk cause
safety issues. This is not experienced evenly across the Council area, and is
affected by previous flood events, and concerns about ability to lessen
their impact on communities, or parts of their community. Where it was
mentioned, it understandably tended to have a significant impact on
feeling safe. Suggestions were made in response to these concerns, to
improve drainage and flood protection, and to develop community
resilience including rapid response teams. The Carse of Gowrie ward
includes the coastal area within Perth and Kinross. The ward summary
report highlights that there is no central climate change group for the area.

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Statements of Agreement/ Dispute 
5 responses were received on our Coastal Development & 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 highlighted other potential implications for the Proposed Plan or made further comments. A summary of these comments, their status, and the
Council’s response are provided in the table below.
Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Errol
Community
Council
Neither List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): Errol Community Council neither agree nor
disagree with the list of evidence/datasets, and neither agrees
nor disagrees with the implications for the Proposed Plan.
Further Comments: None
Formal Dispute: Errol Community Council does not indicate
whether they want to make a formal dispute. 
Appreciate at this stage that there can be some
uncertainty for stakeholders. There will be further
engagement as PKC prepare the Proposed Plan. 
Nature Scot Neither  List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP):  Nature Scot neither agree nor disagree with
the list of evidence/datasets, and neither agrees nor disagrees
with the implications for the Proposed Plan.
Further Comments: Nature Scot considers here could be more in
the ‘Implications for the Proposed Plan’ on climate change and
biodiversity. Also it could include the policy connections set out in
NPF4 (p. 52) and expand on these in context of PKC.
Formal Dispute: Nature Scot does not indicate whether they want
to make a formal dispute. 
Appreciate at this stage that there can be some
uncertainty for stakeholders. There will be further
engagement as PKC prepare the Proposed Plan.
The implications for the Proposed Plan with regard to
climate change, and biodiversity, are perhaps less
significant within PKC than for local authorities with more
extensive coastal areas, or with more coastal changes
predicted in the Dynamic Coast mapping. This will be
further considered for PKC, at the Proposed Plan stage,
but based on the Dynamic Coast webmaps, there are no
areas at risk from coastal erosion within PKC. There is
funding available for the preparation of a Coastal Change
Adaption Plan, and if it is available timeously it will inform
the Proposed plan. However, the blue and green network

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
and nature network mapping work, will also consider our
coastal areas, and a cross reference to this work would be
useful, and has been added.
Noted the policy connections as set out in NPF4 have
been added to this Issue. 
Montague
Evans on
behalf of Loch
Developments
Ltd
Neither List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): Loch Developments Ltd neither agree nor
disagree with the list of evidence/datasets, and neither agrees
nor disagrees with the implications for the Proposed Plan.
Further Comments: None
Formal Dispute: Loch Developments Ltd does not have a formal
dispute
Appreciate at this stage that there can be some
uncertainty for stakeholders. There will be further
engagement as PKC prepare the Proposed Plan. 
Scottish
Water
Neither List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): Scottish Water neither agree nor disagree
with the list of evidence/datasets, and neither agrees nor
disagrees with the implications for the Proposed Plan.
Further Comments: Scottish Water notes the content of topic
paper No.011: Coastal Development and Aquaculture but has no
further comments to add currently.
Formal Dispute: Scottish Water does not have a formal dispute
Appreciate at this stage that there can be some
uncertainty for stakeholders. There will be further
engagement as PKC prepare the Proposed Plan. 
Earn
Community
Council
Agree List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): Earn Community Council agree with the list
of evidence/datasets and agrees with the implications for the
Proposed Plan
Further Comments: Earn Community Council note that until the
closure of Perth Harbour is confirmed, there will be no Proposed
Plan prepared for its regeneration. Also, the definition of a coastal
zone is queried i.e. should it be from Perth itself or where the
River Earn meets the Tay?  Given the recent flooding of Oct 2023
Note feedback for the Proposed Plan stage about where
the coastal zone should start, it is agreed that flood risk
will be an important consideration in where the coastal
extent should be defined.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
within Perth City – the definition of coast requires careful
consideration in the LDP3 Plan.  Where high rainfall and high tides
occur Perth/Bridge of Earn will remain at the risk of flooding. 
Formal Dispute: Earn Community Council does not have a formal
dispute

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Issue: Energy, Heating and Cooling (Including Infrastructure: Energy
Supply Systems)
Corresponding NPF4 Policy/Policies:
• NPF4 Policy 11 (Energy)
• NPF4 Policy 18 (Infrastructure) – specifically relating to the supply
of energy
• NPF4 Policy 19 (Heat and Cooling)
• Other key NPF4 policy connections:
o Policy 1 – Tackling the climate and nature crises
o Policy 2 – Climate mitigation and adaptation
o Policy 3 – Biodiversity
o Policy 4 – Natural places
o Policy 5 – Soils
o Policy 7 – Historic assets and places
o Policy 8 – Green Belts 
o Policy 9 – Brownfield, vacant and derelict land, and empty
buildings
o Policy 12 – Zero Waste
o Policy 13 – Sustainable Transport
o Policy 14 – Design, quality and place
o Policy 20 – Blue and green infrastructure
o Policy 25 – Community wealth building
o Policy 26 – Business and industry
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 012: Energy, Heating and Cooling 
Information required by the Act and NPF4 regarding the topic:
In line with the requirements of the Act, the following is noted:
• The infrastructure of the district in terms of systems for the
supply of energy,
• How that infrastructure is used,
• Particular land available for the development and use of facilities
for renewable sources of energy.
Under NPF4 Policy 11 (Energy), LDPs are expected to:
• seek to realise their area’s full potential for electricity and heat
from renewable, low carbon and zero emission sources by
identifying a range of opportunities for energy development.
Under NPF4 Policy 18 (specifically relating to the supply of energy), LDPs
are expected to:
• be informed by evidence on infrastructure capacity, condition,
needs and deliverability within the plan area, including cross
boundary infrastructure,
• set out the infrastructure requirements to deliver the spatial
strategy, informed by the evidence base, identifying the
infrastructure priorities, and where, how, when and by whom
they will be delivered,
• align with relevant national, regional and local infrastructure
plans and policies.
Under NPF4 Policy 19 (Heat and Cooling), LDPs are expected to:

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• take into account the area’s Local Heat and Energy Efficiency
Strategy (LHEES); and
• the spatial strategy should take into account areas of heat
network potential and any designated Heat Network Zones
(HNZ).
This section also provides information relating to the policy subject of
energy, heat and cooling as contained in the ‘Local Development Planning
Guidance’ (2023, p.51, 67-71). This includes information relating to the
NPF4 Policy Advice and considerations referenced in the Evidence Report
Guidance for NPF4 Policies 11, 18 (energy) and 19.
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
• PKC Corporate Plan (2022-2027)
• PKC Climate Change Strategy and Action Plan
• PKC Local Area Energy Plan (LAEP)
• PKC Local Heat and Energy Efficiency Strategy (LHEES)
• PKC 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 Govt Energy statistics
• PKC Map - location of renewable energy proposals
• SSE Renewables - planned upgrades
• SGN - gas network
• Scottish Govt Hydrogen Action Plan
Future Opportunities – renewable energy and decarbonised heat
• PKC LHEES Strategy and Delivery Plan
• PKC Green Assets Map
• Onshore Wind Policy Statement
• Hydrogen in Scotland
• Scottish Enterprise hydrogen sites study
• Scottish Water renewable energy opportunities guide
• PKC community projects

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Constraints and Environmental Considerations
• PKC Landscape Guidance
• PKC Landscape Capacity Study - Wind
• NatureScot Landscape Sensitivity Study Guidance
• Perth and Kinross Local Development Plan (2019)
• Fourteenth Annual Report on the Operation of Section 72 of the
Climate Change (Scotland) Act 2009
• Scottish Govt New Build Heat Standard
• PKC draft Supplementary Guidance for Renewable and Low Carbon
Energy
• Chief Planner letter (2024)
• Good Practice Principles for Community Benefits from Onshore
Renewable Energy Developments

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Summary of Evidence:
National and Local Policy Context
In 2019, the Scottish Government declared a climate emergency. The
Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 aims to
ensure that Scotland’s contribution to climate change will end within a
generation, being fully net-zero by 2045 (compared to a 1990 baseline). An
update to the Scottish Government Climate Change Plan 2018-2032
followed on from this, which directs the pathway for the targets set within
the Climate Change Act. In 2023, the Scottish Government published the
Draft Energy Strategy and Just Transition Plan which includes a draft route
map of actions to support a flourishing net zero energy system that
supplies affordable, resilient and clean energy for Scotland. In April 2024, a
Scottish Government announcement was made to remove annual targets
and the interim 2030 target for carbon emission reductions. 
Following consultation on the Heat in Buildings Strategy in 2021, the
Scottish Government set out ambitions for net zero buildings through the
Heat in Buildings Bill which was consulted on between November 2023 and
March 2024. The Bill sets out proposals to make new laws around energy
efficiency of our homes and buildings and the way we heat those buildings.
The Heat Networks (Scotland) Act 2021 also sets out provisions for the
deployment of heat networks across Scotland, including requirements
around heat network zoning where these have most potential.
At the local level, the following priorities from the Perth and Kinross
Council Corporate Plan (2022-2027) are of relevance: 
• Developing a resilient, stronger and greener economy.
• Tackling climate change and supporting sustainable places.
• Working in partnership with communities.
The following key actions contained in the Corporate Plan link
directly to the policy topic of energy/heat:
• Improve the energy efficiency of our Council housing stock and
public buildings, and encourage our partners and private
householders to consider where they can make
improvements.
• To conserve and enhance the biodiversity of our natural
environment.
• To adopt to and mitigate the impact of climate change on the
way we operate.
• Support and promote business growth, business and place
innovation and investment in both our urban and rural areas.
• Invest in innovative green power and smart technology
solutions to reduce reliance on electricity from the national
grid and create opportunities for business growth and
regeneration.
• Develop and expand our approach to working with
communities to identify local actions and priorities and deliver
on these together.
Perth and Kinross Council has declared a climate emergency and prepared
a Climate Change Strategy and Action Plan. The Climate Change Strategy

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sets out 6 overarching principles that will shape the Council’s long-term
approach to climate change:
• Achieving Net Zero aligned with the Paris Agreement and the
Scottish Government Targets, with the ambition of achieving
them sooner.
• Building a more resilient Perth and Kinross.
• Ensuring climate action is fair and benefits all and we deliver a
green recovery to Covid-19.
• Enhancing biodiversity to help avoid an ecological emergency.
• Engaging and empowering children and young people to take
action on climate change.
• Empowering our communities and businesses to take climate
action in line with the Perth and Kinross Offer.
The Council’s Action Plan sets out the necessary action to make both the
Perth and Kinross Council area and the Council itself net zero and climate
resilient. Specific actions are included under eight thematic areas including
buildings and energy. The Council also prepares Annual Climate Action
Reports and Action Plan Updates as part of monitoring the progress of the
Action Plan. 
The Council – with support from consultants Arup – published a Local Area
Energy Plan (LAEP) in February 2024. The LAEP provides an understanding
of the nature, scale, rate, and timings of changes needed for the transition
to a net zero energy system within Perth and Kinross. The LAEP includes a
series of potential pathways for the area’s energy transition including
priorities and actions around whole building retrofits, heat networks,
decentralised heat pumps in rural areas, transport related actions, and a
shift in the energy system towards local generation to balance local supply
and demand. 
In a joined-up approach, the Council’s LAEP has been prepared in
alignment with the Local Heat and Energy Efficiency Strategy (LHEES). The
LHEES Strategy and Delivery Plan – a new statutory duty for local
authorities – provides a strategy for the long-term decarbonisation and
improvement of energy efficiency for all buildings. The LHEES includes a
Delivery Plan that sets out key actions in the short term to support
priorities identified by the Council and stakeholders. Further consideration
of the LAEP and LHEES are provided later in the document.
In terms of domestic buildings, the Council’s Local Housing Strategy (2022-
2027) has one of its four main priorities to “deliver quality homes with
affordable warmth, zero emissions and SMART technology” including
setting a road map for the reduction of domestic carbon emissions. As
noted further in the LAEP/LHEES section below, the Council also has a
green investment programme across its non-domestic property portfolio.
Energy Infrastructure
National Grid is the National Energy System Operator (ESO) for the United
Kingdom. Scottish and Southern Energy Networks (SSEN) are the
Transmission (SSEN-T) and Distribution (SSEN-D) Network Operators
(TNOs/DNOs) within the Perth and Kinross Council Area.

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National Grid
As Electricity System Operator for the UK, National Grid are responsible for
balancing the national electricity grid. Part of the role of National Grid is to
ensure that the grid is future-proofed in terms of both supply and demand.
National Grid recently announced plans for ‘Beyond 2030’ which includes
outline proposals for onshore and offshore grid infrastructure upgrades in
the 2030s to accommodate offshore wind energy generation as part of the
ScotWind programme. Working with the Transmission Network Operators
across the UK, detailed infrastructure projects including routes will be
further developed.
In line with the Energy Act (2023), National Grid has become the new
National Energy System Operator (NESO) under a reformed energy system
governance structure. There are also OFGEM proposals for Local Energy
system governance reform including the introduction of Regional Energy
Strategic Planners (RESPs). 
Electricity Transmission and Distribution Networks
Scotland’s Transmission network has a strategic role to play in supporting
delivery of the UK and Scotland’s Net Zero targets. Further information is
available on the Transmission Network and the role of SSEN-T.
Existing SSEN transmission network infrastructure includes data on the
tower, overhead lines, substation, and pole infrastructure that SSEN-T
currently manages. SSEN-T has the operational role in managing the
capacity of existing infrastructure and managing upgrades/new
connections. The capacity of existing infrastructure and generation
availability is available on the network map tool. 
SSEN-T’s Pathway to 2030 projects include future plans for the
transmission network to help deliver net zero. For the PKC area,  there are
future plans for the Central Highlands and East Coast areas. 
SSEN Transmission has a projects map that outlines key projects across its
operational area. Within the PKC area, the following key projects are
outlined:
• Beauly Denny 400kV Upgrade (Transmission reinforcement)
• East Coast 400kV Upgrade (Transmission reinforcement)
• Alyth 275kV substation and reactive compensation
(transmission reinforcement)
• Alyth – Tealing Overhead Line 400kV Upgrade (reconductoring
of Overhead Line)
• Tealing – Westfield Overhead Line 400kV Upgrade
(reconductoring of Overhead Line)
• Abernethy Substation Extension (transmission reinforcement)
• Kinardochy Substation (transmission reinforcement)
• Errochty Grid Supply Point (GSP, transmission reinforcement)
SSEN Transmission also responded to the BEYOND 2030 report published
by National Energy System Operator (NESO) which may have implications
for PKC including potential work to the Alyth-Kincardine transmission line.
Scotland’s Distribution Network plays an important role in distributing
electricity from the transmission network to people’s homes and

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businesses. Further information is available on the Distribution Network
and the role of SSEN-D.
Existing SSEN distribution network infrastructure includes data on asset
management including information on substations and grid/bulk supply
points. The data portal also includes information (embedded capacity,
SHEPD Long Term Development Statement, and SEPD Long Term
Development Statement) to inform consideration of existing capacity and
opportunities for future connections to the distribution network. 
In terms of generation capacity, the SSEN-D data portal indicates that
there are partially constrained grid supply points (GSPs) at: Perth
(Burghmuir), Coupar Angus, Tummel Bridge, and Rannoch; and constrained
GSPs at: Braco, Abernethy, and St Fillans. Across the PKC area, substations
vary in terms of connecting for generation capacity including
unconstrained, partially constrained, and constrained.
In terms of network capacity, the SSEN-D data portal indicates that Braco
and Tummel Bridge GSPs are constrained for distribution, with the
remaining GSPs all unconstrained: Abernethy, Perth, Coupar Angus, St
Fillans, and Rannoch. All substations in the PKC area are unconstrained in
terms of network capacity.
The capacity of the network also needs to be reviewed in relation to the
Long Term Development Statement and Embedded Capacity Register, to
check what the capacity of the infrastructure is as well as to confirm what
is already planned to be connected.
SSEN-D’s Distribution Network Future Energy Scenario (DFES) Report
(2024) supports future forecasting, network analysis and investment
planning to aid in the long term planning of the distribution network. The
SSEN DFES Report (2024) for the North of Scotland licence area considers a
wide range of potential impacts on the distribution network including
responding to net zero targets and implications on the grid from new
developments. The DFES Report for the North of Scotland (2024) outlines
the following expected scenarios for 2030:
• Significant increase in renewable generation (solar, wind and
hydropower) with onshore wind deployment expected to account
for the majority of the projected increase in connected capacity
• Sources of demand including the uptake of EVs and installation of
heat pumps expected to increase significantly by 2030.
• Energy/battery storage capacity to significantly increase with a
significant pipeline of new sites.
• Demands from new developments across the North of Scotland
area.
SSEN Distribution is also developing Strategic Development Plans (SDPs)
for each Grid Supply Point (GSP) on the network. SDPs provide a blueprint
of long-term electricity system needs that allow SSEN-D to work with other
stakeholders to design and build the local markets and networks they need
to decarbonise their power needs. Each SDP is consulted upon and
refreshed on an annual basis to ensure they reflect latest understanding of
customers’ needs. These SDPs shape the subsequent stages of the strategic
planning process, where detailed options are developed for delivering
identified network and system needs.

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To support strategic planning for net zero, SSEN-D – in collaboration with
key stakeholders including PKC – has developed the Local Energy Net Zero
Accelerator (LENZA) tool. The tool provides granular data and modelling
tools to support informed decision-making, including information on
network typology and capacity, building stock, and energy consumption.
The LENZA tool will be used as the platform to support the Local Area
Energy Plan / Local Heat and Energy Efficiency Strategy project delivery,
aligning with strategic investment decision making and DFES scenarios. 
In terms of cross-boundary infrastructure, Scottish Power Energy Networks
(SPEN) operate the transmission and distribution infrastructure network in
the South of Scotland region. SPEN will be a key stakeholder to consider
any cross-boundary infrastructure issues.
Existing Renewable Energy Generation
Using the UK Government Department for Energy Security and Net Zero
statistics, Table 1 below outlines the installed renewable energy
generation data for the PKC area in 2023:
Table 1: Renewable Energy Installed Capacity in PKC area (2023)
Renewable Energy Source Installed Capacity (MW)
Photovoltaics (solar) 39.7
Onshore Wind 319.9
Hydro 277.8
Anaerobic Digestion 2.8
Landfill Gas 3.4
Plant Biomass 1.6
The Council maps the location of renewable energy proposals submitted
through the planning process. This map includes proposals for wind,
biomass and solar. This information provides a useful baseline of the
renewable energy proposals submitted, and the planning status of these
proposals. This information is also included in the LENZA tool. 
The Council’s LAEP (p.22) also includes a summary and map of existing
renewable energy generation assets, see Map 1 (included at the end of this
document).
Due to the large rural area and natural resources available in the PKC area,
there are several existing renewable generation assets that are feeding
into the energy system. Perth and Kinross’ renewable energy asset mix is
primarily hydroelectric plants, onshore wind sites and solar PV. 
Hydroelectric schemes include Breadalbane (100.3 MW), Rannoch (44
MW), Tummel Bridge (34MW), and Pitlochry (15 MW). SSE Renewables
have planned upgrades to existing sites. Early plans for a large-scale
pumped hydro storage facility (Corrievarkie Hydro) in the north of the
Highland Perthshire area are also being developed. 
Wind installations include Griffin Wind Farm (204MW), Calliachar
(32.2MW), Drumderg (36 MW), Tullymurdoch (14.4MW), and Lochelbank
(9.6 MW). Several large-scale wind proposals are also in the process of
being considered or at pre-application stage including:
• Craighead, Brunthill and Windburn wind farms, located in the
Ochil Hills

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• Glentarken and Glen Lednock wind farms, located in the hills
north/north-east of Loch Earn
There is a mix of rooftop and ground mounted solar PV installations in the
PKC area. A 13 MW ground mounted solar PV farm located in Errol was
Scotland’s largest solar farm at time of construction. A number of solar
farm proposals have also been consented including Keithick Farm (nr
Coupar Angus), Bardrill Farm (nr Blackford), Carey and Cordon Farms (nr
Abernethy), Binn Farm (nr Glenfarg), and Standingfauld Farm (nr Muthill).
Several large-scale proposals are also currently being considered, at appeal
or at pre-application stage including Kinnon Park Farm (Methven),
Kinrossie, and Coupar Angus.
The Council is also experiencing an increasing number of proposals for
battery storage developments, typically located close to existing/planned
substations, and/or forming hybrid proposals i.e. adjacent to other
generation sources. Examples include schemes at Keithick, Coupar Angus,
Alyth, Rannoch, Longforgan, Tibbermore, and Abernethy. The ‘Green
Assets’ map (as included in the TP012) outlines existing/future planned
grid-balancing battery storage developments.
Heat supply options for potential heat networks are also likely to be a key
consideration in the future e.g. energy from waste, wastewater, water
sources. 
Gas Infrastructure Network
The gas network in Scotland is operated by SGN. The existing gas network
includes data on the various pipe infrastructure including low to regional
high pressure pipes.
Most of the Council area is supplied by the gas network, however there are
areas, particularly in rural locations, where properties are off gas grid. As
noted on page 18 of the LAEP, SGN “operate the gas network in the area,
which currently supplies 63% of homes in Perth and Kinross.” This is lower
than the Scottish average – in terms of proportion of gas heated homes –
and is most likely due to the number of rural properties across the PKC
area. Properties off the gas grid will typically use one or more alternative
forms of heating including: oil, LPG, electric storage, and/or biomass.
As part of the transition to net zero, demand for unabated natural gas is to
be phased out and replaced by low carbon and ultimately renewable
energy sources. This will require the transition of natural gas connections
to low carbon alternatives.
The Scottish Government’s Hydrogen Action Plan notes that hydrogen will
not play a central role in the overall decarbonisation of domestic heat. The
gas industry is testing options for blending hydrogen into the gas network
up to the limit that can be safely used in existing appliances. Future plans
for the gas network will be informed by the UK Government decision on
the future role of hydrogen, expected in 2026, as well as PKC plans for the
decarbonisation of heat.
Heat Networks
There are no known district heating schemes within the PKC area. There
are a number of communal schemes including for social housing e.g.

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Carpenter Court and Scott Street (Perth), and private enterprises e.g.
Strathallan School, Meikleour House. 
Future opportunities - renewable energy and decarbonised heat
‘Whole Energy Systems’ approach to Energy Planning 
The Council has jointly prepared a LAEP and LHEES to support a strategic
‘whole systems’ approach to energy planning. Figure x provides a helpful
overview of the remit of both documents. 
Figure x: Overview of LHEES and LAEP 
The LHEES – covering heat and energy efficiency as key components of the
‘whole energy system’ approach – is embedded within the LAEP. It is
intended that the Council’s approach to strategic energy planning will be
presented through one shared Delivery Plan given the interconnectedness
between the two documents. 
Local Area Energy Plan (LAEP)
The objectives of the PKC LAEP are:
• To set a well-defined pathway to a resilient, net zero local
energy system that meets future demand across all energy
vectors.
• To engage with and empower the local community to deliver
the energy transition, supporting the creation of local jobs.
• To increase local ownership and participation in the net-zero
energy system.
• To develop the evidence base to coordinate energy planning
and investment across electricity, heat, and transport to
maximise efficiencies and recognises the linkages between
energy vectors.
• Ensuring a just transition that makes the benefits of the new
energy system affordable and accessible for all, reducing fuel
poverty and supporting rural energy consumers.
The LAEP also sets out a vision for an ‘optimised system for 2045’ setting
out a high ambition, net-zero energy system for the PKC area, which is
centred around demand reduction, electrification of heat and transport,
and smart local energy generation. The LAEP uses four transition pathways

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(deployment models) to identify the impact the rate of change of the
energy system has on emissions and energy consumption: business as
usual, regulatory standards, public sector lead, and high ambition. The
LAEP outlines that the Council should aim to follow as closely as possible to
a High Ambition scenario. Figure x below outlines the priority intervention
areas in Perth and Kinross needed to meet the ‘high ambition’ scenario.
Figure x: Local Area Energy Plan – Priority Intervention Areas 
The following actions/recommendations are considered to be of particular
relevance to the preparation of the Proposed Plan in relation to
energy/heat:
• Action 2.2 - Engage with SSEN on impact of heat pumps and
heat networks.
• Action 2.4 - Continue to explore strategic heat network
feasibility across Perth City.
• Action 2.6 - Monitor the development of the UK Hydrogen
industry.
• Action 5.3 - Reassess potential suitability for renewables.
• Action 5.4 - Engage regularly with Scottish and Southern
Electricity Networks (SSEN).
• Action 5.6 Support Community Energy Schemes.
Local Heat and Energy Efficiency Strategy (LHEES)
The preparation of a Local Heat and Energy Efficiency Strategy and Delivery
Plan is a new statutory duty for local authorities. The Council published
their LHEES Strategy and Delivery Plan in 2024. The LHEES includes a vision,
5 strategic priorities (aligned with the LAEP) and actions to shape the first
PKC LHEES and accompanying Delivery Plan (2024-2029). The PKC LHEES is
driven by Scotland’s overarching statutory targets for greenhouse gas
emissions reduction and fuel poverty.
The overarching vision of the PKC LHEES is:
“by 2045, our homes and buildings will be more energy efficient
and with more decarbonised heat sources providing more
affordable warmth and no longer contributing to climate change.”
Section 3 of the LHEES Strategy provides a useful baseline of domestic and
non-domestic properties, and fuel poverty likelihood, across the PKC area.

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Key statistics in relation to the status of domestic and non-domestic
properties are noted below:
• 69% of domestic properties will need energy efficiency
retrofitting by 2023.
• 58% of domestic properties have an EPC rating of D-G, which is
higher than the national average of 51%.
• 63% of domestic properties are currently served by the gas
grid, while 36% are known as being off-gas grid.
• Fuel poverty and Extreme Fuel Poverty likelihood levels in PKC
are higher than the national averages.
• The estimated total heat demand of all non-domestic buildings
in PKC is approximately 810GWh/yr.
• 13% of all non-domestic buildings’ heat demand is under
control of the Council.
To help achieve the vision and outcomes set out, the LHEES includes two
strategic priorities that forms the basis of the Strategy and Delivery Plan:
• Priority 1: Decarbonising heat within a transitioning energy
system focusing on heat networks and heat pumps.
• Priority 2: Improving buildings’ energy efficiency aiming for
affordable warmth and regulatory compliance.
Priority 1 is of particular relevance for the preparation of the Proposed
Plan regarding the deployment of heat networks and strategic heat
network zoning. Strategic priority 1a is centred around ‘Delivering
decarbonised heat within a transitioning energy system – heat network
zones’. The LHEES has identified indicative heat network zones, noting that
due to the nature of the PKC area, the potential for heat networks in the
local authority area is limited to a few urban areas and towns. The
potential heat network zones (as shown in Figures 10.1, 11-13 in the LHEES
document) include:
• Perth City Centre 
• Perth Inveralmond Industrial Estate
• Perth College/UHI
• Perth Academy
• Auchterarder
• Kinross
• Blairgowrie
A range of actions have been included to support the further
analysis/development of the heat network zones. A key action is to
formally designate any heat network zones, as required by the Heat
Networks (Scotland) Act 2021.
More generally, the two strategic LHEES priorities are underpinned by a
range of ‘delivery priorities’ to support the Delivery Plan actions. The first
delivery priority ‘potential heat network zones’ is of particular relevance to
the preparation of the Proposed Plan.
Perth City - Strategic Heat Network Project
In addition to the above, a detailed study has been undertaken into the
feasibility of a heat network in Perth City Centre. PKC has received
additional funding through the Scottish Government’s Heat Network
Support Unit (HNSU) to further develop this project. The Strategic Heat

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Network project will explore a concept design for a large-scale, city-wide
heat network through expansion and refinement of identified zones as well
as the role of a city-wide heat network as a key anchor project for the
delivery of a wider strategic energy programme. 
Smart Perth and Kinross
The Council’s Smart Investment team have developed a ‘Smart Perth and
Kinross’ prospectus. The vision identifies that:
• Perth and Kinross will be Net Zero and Beyond by 2045 or
sooner.
• Perth will be the most sustainable city in Europe.
• Perth and Kinross economy will be Net Zero, high value and
innovation driven.
The vision will be delivered by:
• Building on our key green energy assets,
• Developing key clusters/projects,
• Delivering key green energy and low carbon smart
investments.
The Investment Prospectus includes ‘Green Assets’ (dated 2020) which
includes existing renewable energy assets within the PKC area, potential
future strategic opportunities, and how PKC performs in comparison to
other local authorities in the UK. See Map2 (included at the end of this
document).
The Prospectus also includes further detail of low carbon/green energy
investment opportunities at:
• Binn Eco Park and the Abernethy Cluster (Map 3)
• Perth West, Broxden and Perth City Cluster (Map 4)
Key smart investments across the region are also identified (Map 5),
including:
• Perth and Kinross Smart Energy Programme: create a smart
local energy system complementing grids and driven by data
and economic opportunities.
• Project Sandstone: private green electricity network from Binn
Eco Park/Abernethy to Perth City.
• Green hydrogen initiative: harness green electricity to produce
green hydrogen for heat and transport.
• Binn Eco park: develop a Centre of Excellence for Circular
Economy. 
• PKC Housing and Estate Green Investment Programmes across
the region.
An Energy from Waste plant is currently under construction at Binn Eco
Park, as part of a joint agreement with the Council. Future opportunities
for the transmission of heat/electricity from Binn Eco Park is also
recognised.
The Smart Perth and Kinross programme will be supplemented by the
establishment of a long-term Strategic Energy Partnership between the
Council and relevant private sector partner(s), which is intended to
develop and deliver strategic energy and low carbon projects to enable
Perth and Kinross to meet net zero by 2045. This project is currently in the
procurement stages. This partnership approach has the potential to

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accelerate and maximise opportunities for strategic energy and low carbon
projects in the PKC area. It is noted that the Strategic Energy Partnership is
expected to be a long-term programme with projects spanning a 25-year
period (including district heating).
Onshore Wind
The Scottish Government’s Onshore Wind Policy Statement sets out an
ambition to deploy 20GW of onshore wind by 2030. Meeting this ambition
will require the deployment of a significant additional level of onshore
wind generating capacity across Scotland. The Statement outlines the
benefits that the additional wind resource could have, as well as the need
to consider environmental considerations.
Hydrogen
As noted in the LAEP (p.18) there are currently no major hydrogen projects
in the area or identified in the Scottish Government Hydrogen Action Plan.
There are also no hydrogen projects identified in the Hydrogen in Scotland
programme. There are however potential plans for an electrolyser
installation at Binn Eco Park, which will be considered further as part of
any associated site assessments at the Proposed Plan stage if relevant.
Scottish Enterprise has published a study on site requirements for
hydrogen projects.
Marine Planning
As the PKC area has limited coastline along a short section of the River Tay,
there are no direct implications arising from the following policy
documents in terms of energy:
• Sectoral Marine Plan for Offshore Wind Energy.
• Innovation and Targeted Oil and Gas Sectorial Marine Plan.
• National Marine Plan and associated Regional Marine Plans.
Scottish Water Assets
Scottish Water has published a guide for developers and communities to
help inform renewable energy opportunities involving Scottish Water
assets.
Community Projects
The Council has mapped existing known community projects which are
tackling climate action. 
Constraints and Environmental Considerations
Under Policy 11 of NPF4, there are a range of environmental and other
land use considerations that are required to be considered during both
project design and the assessment of associated proposals. 
Landscape Designations
In the Perth and Kinross Council area, there are two National Parks –
Cairngorms, and Loch Lomond and the Trossachs. There are also a number
of National Scenic Areas (NSAs) within and adjacent to the Council
boundary. These designations are referenced specifically in relation to
wind farm developments, as per NPF4 Policy 11b which states that:
“Development proposals for wind farms in National Parks and National
Scenic Areas will not be supported.” See Map 6 (included at the end) from
the Council’s Adopted Landscape Supplementary Guidance (2020) which
shows these designations as well as other landscape designations,

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including PKC Local Landscape Areas and those from neighbouring local
authority areas.
Other International and National Designations
Other relevant international and national designations that will be relevant
to the consideration of renewable energy proposals against NPF4 Policy 11
and other relevant NPF4 policies are included in the following topic papers:
• TP 005 – Biodiversity and Natural Places
• TP 006 – Soils
• TP 007 – Forestry, Woodland and Trees
• TP 008 – Historic Assets
Landscape Capacity Study for Wind
In 2010, the Council commissioned a detailed Landscape Capacity Study to
inform wind energy development in the PKC area. This study predates the
NatureScot Landscape Sensitivity Study approach to assessing landscape
impact from specific development types, however it is still considered
relevant in highlighting sensitive landscape features within the PKC area.
Features such as the Highland Boundary Fault, and important viewpoints
and tourist routes are included. The study will assist in the assessment of
landscape impact from wind farm developments acknowledging that the
planning policy has changed significantly since the publication of the study.
Existing Policy and Guidance
Local Development Plan (2019) - Policies 33, 34 and 35
In terms of local planning policy, the following policies of the Perth and
Kinross Local Development Plan (2019) are of relevance to energy and
heat. It is important to note that LDP policies pre-date the adoption of
NPF4 policies.
Policy 33 (Renewable and Low Carbon Energy) provides the local policy
context for the consideration of renewable and low carbon energy
developments.
Policy 34 (Sustainable Heating and Cooling) provides the local policy
context for the consideration of proposals in relation to sustainable
heating and cooling including district heating.
Policy 35 (Electricity Transmission Infrastructure) provides the local policy
context for the consideration of electricity transmission infrastructure
proposals including replacement of existing, and development of new,
infrastructure. 
Spatial Framework for Wind – Policy 33D
As required through the previous Scottish Planning Policy, the current
Local Development Plan (2019) includes Policy 33D (Spatial Framework for
Wind). NPF4 Policy 11b has updated the national spatial policy whereby
spatial frameworks for wind are no longer a requirement for LDPs,
identifying land under one of three groups. 
The LDP Evidence Report Guidance notes that Spatial Frameworks can be
used to help inform future LDPs. Whilst the current Spatial Framework has
been superseded by NPF4 Policy 11b, consideration of renewable energy
proposals are informed by a range of the environmental considerations
included in the current framework. 
See Map 7, The Spatial Framework for Wind map.
Section 3F – Planning Policies on Low /Zero Carbon Technologies

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LDPs are required by Section 3F of the Act1 (NB: Section 72 of the Climate
Change (Scotland) Act) to include policies “requiring all developments in
the LDP area to be designed so as to ensure that all new buildings avoid a
specified and rising proportion of the projected greenhouse gas emissions
from their use, calculated on the basis of the approved design and plans
for the specific development, through the installation and operation of low
and zero-carbon generating technologies.” 
LDP Policy 32 (Embedding Low and Zero Carbon Generating Technologies
in New Development) is included as part of the adopted LDP to meet this
requirement of the Act.
The Fourteenth Annual Report on the Operation of Section 72 of the
Climate Change (Scotland) Act 2009 notes that with changes in building
and heat standards there is now no longer a requirement for policies
related to Section 3F. Section 1.8 of the Annual Report notes that this
conclusion enables Scottish Ministers to prepare an Order to repeal the
legislation. Until such time as the repeal order is in force, LDP Policy 32 will
continue to be implemented. This is unlikely to be a matter for the next
LDP, subject to confirmation that the legislative requirements are
repealed.
New Build Heat Standard (2024)
The introduction of the New Build Heat Standard in April 2024 – and
further updated in November 2024 – means that any new build homes and
properties will no longer be allowed to be heated through direct emissions
heating such as gas. This is controlled through the Building Standards 
1 Town and Country Planning (Scotland) Act 1997
process, however it is expected to give rise to an uptake in electrical
heating systems e.g. heat pumps, which will have implications on demand
and capacity of the grid.
Renewable Energy Supplementary Guidance
The Council has prepared and consulted on draft Supplementary Guidance
for Renewable and Low Carbon Energy proposals. In light of the adoption
of NPF4 and the significant updates to national planning policy on energy,
the Council is programming an update to the Guidance in 2025. This will be
prepared taking due cognisance of NPF4 and other key national and local
policies and strategies. The updated Guidance will help to inform the
assessment of renewable energy proposals when adopted.
Community Benefits 
The Scottish Government encourages the use of financial schemes to
directly benefit communities where new renewables schemes are being
hosted. For example, the Onshore Wind Policy Statement outlines the
Scottish Government’s ambitions in relation to community benefits and
shared ownership. Whilst PKC is supportive of the principle of community
benefits, it is important to note that these voluntary arrangements sit
independent of the planning and consenting systems in Scotland, as
outlined in the Chief Planner letter dated 20th September 2024 and the
Scottish Government’s Good Practice Principles for Community Benefits
from Onshore Renewable Energy Developments.

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Summary of Implications for the Proposed Plan:
Energy Infrastructure – capacity and demand
SSEN Transmission and Distribution datasets will be used to inform the
evidence base for the preparation of the Proposed Plan including the
consideration of network capacity and how the Spatial Strategy can inform,
and be informed by, plans regarding the utility network. The ability to
connect to the existing network (including any planned upgrades) will be a
key consideration when preparing an infrastructure-first approach for the
Spatial Strategy, as required by NPF4 Policy 18. This applies both to
connecting generation capability as well as assessing capacity for new
demands on the network.
In terms of energy infrastructure and future capacity/demand, the spatial
strategy and policy framework development will be informed by the
following:
• National plans and strategies, including:
o Scottish Government’s Energy Statement and Just Transition
Plan (2023), in particular targets for installed renewable
generation capacity and locally or community owned energy
generation
o Scottish Government’s Onshore Wind Policy Statement, in
particular the target for additional onshore wind generation
capacity by 2030
o Scottish Government’s Heat in Buildings Strategy (2021) and
Heat in Buildings Bill (2023)
o SSEN-T Pathway to 2030 Projects (Transmission)
o SSEN Distribution Network Future Energy Scenario (DFES)
Report 2024
• Local plans and strategies, including:
o Perth and Kinross Climate Action Plan
o Perth and Kinross Local Area Energy Plan
o Perth and Kinross Local Heat and Energy Efficiency Strategy
(LHEES)
• Energy demands, including:
o electricity generation projections for wind, hydro-electric
and solar photovoltaic
o electricity demand projections for electric vehicles and heat
pump installations
o electricity storage technologies including battery storage
and hydro pumped storage
o future plans for the gas infrastructure network including
proposals for the role of hydrogen
o future plans for hydrogen supply
o potential to develop heat networks 
Future Opportunities: Renewable Energy and Decarbonised Heat
In terms of future opportunities for renewable energy and decarbonised
heat, the spatial strategy and policy framework development will be
informed by the following:
• considerations of infrastructure capacity and demand (see previous)
• National plans and strategies, including:
o Scottish Government’s Energy Statement and Just Transition
Plan (2023), in particular targets for installed renewable

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generation capacity and locally or community owned energy
generation
o Scottish Government’s Onshore Wind Policy Statement, in
particular the target for additional onshore wind generation
capacity by 2030
o Scottish Government’s Heat in Buildings Strategy (2021),
Heat in Buildings Bill (2023) and New Build Heat Standard
(2024)
o Scottish Government’s Heat Network (Scotland) Act 2021
• Local plans, programmes, and strategies, including:
o Perth and Kinross Climate Action Plan
o Perth and Kinross Local Area Energy Plan. In particular the
Proposed Plan will have influence over the priority
intervention areas deploying local renewable energy
generation and storage, and decarbonising heat/transport. 
o Perth and Kinross Local Heat and Energy Efficiency Strategy
(LHEES), including identified potential heat network zones
o Identification of Heat Network Zones (HNZs) as required
through the Heat Networks (Scotland) Act 2021
o Smart Perth and Kinross programme including key
site/settlement specific projects
o Perth City Strategic Heat Network Project
o Community led projects/schemes
NPF4 has the following policy requirements that will be taken into account
in developing the spatial strategy and policy framework:
• NPF4 Policy 11: LDPs should seek to realise their area’s full potential
for electricity and heat from renewable, low carbon and zero
emission sources by identifying a range of opportunities for energy
development.
• NPF4 Policy 19: LDPs should take into account the area’s Local Heat
and Energy Efficiency Strategy (LHEES). The spatial strategy should
take into account areas of heat network potential and any
designated Heat Network Zones (HNZ).
The consideration of future opportunities for renewable energy and
decarbonised heat – as part of developing the spatial strategy and policy
framework – will also be informed by a number of environmental and
other considerations:
• Landscape Designations including National Scenic Areas, National
Parks, and Local Landscape Areas
• International and national designations, including those listed
under separate sections of the Evidence Report, namely:
o Biodiversity and Natural Places (Landscape)
o Soils
o Forestry, Woodland and Trees
o Historic Assets
• Landscape Capacity for Wind (2010): whilst the policy framework
has changed significantly since the publication of the Capacity
Study, this still includes useful information highlighting key
landscape features to be considered when considering wind farm
developments e.g. Highland Boundary Fault, and important
viewpoints/tourist routes.
• Cumulative effects from existing operational/consented energy
schemes

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• The repealing of Section 3F requirements in relation to low and zero
carbon generating technologies
• Renewable and Low Carbon Energy Guidance: this is expected to be
updated in 2025 to take into account the updated policy framework
i.e. NPF4
Gaps, Uncertainties or Key Issues Raised:
• 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 make reference to NatureScot’s Landscape Sensitivity
Guidance.
• There are indicative plans for potential new pipeline infrastructure
across Scotland including in the PKC area to support emerging plans
around hydrogen production/transmission. Plans are at an early
stage and will continue to be monitored and taken into account
during the preparation of the Proposed Plan, where relevant. 
• The development of UK energy governance arrangements will
continue to be monitored and taken into account during the
preparation of the Proposed Plan, where relevant.
Summary of Stakeholder Engagement:
We have engaged with SSEN (transmission and distribution), SPEN and SGN
in the preparation of the Evidence Report.

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Map 1: Map of Existing Renewable Generation Assets 
1 Perth & Kinross Local Area Energy Plan, Fig 2.11 (p.22). Available - Perth and Kinross LAEP (pkclimateaction.co.uk)

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Map 2: Map of Existing ‘Green Assets’2 
2 ‘Smart Perth & Kinross’ Programme: Mapping out low carbon & green energy smart investments, 2022.

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Map 3: Binn Eco Park & Abernethy Cluster3 
3 ‘Smart Perth & Kinross’ Programme: Mapping out low carbon & green energy smart investments, 2022.

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Map 4: Perth West, Broxden & Perth City Cluster4 
4 ‘Smart Perth & Kinross’ Programme: Mapping out low carbon & green energy smart investments, 2022.

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Map 5: Key Smart Investments across Perth and Kinross5 
5 ‘Smart Perth & Kinross’ Programme: Mapping out low carbon & green energy smart investments, 2022.

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Map 6: Map of Landscape Designations in Perth and Kinross6 
6 Map of Landscape designations in Perth and Kinross, ‘Landscape’ Supplementary Guidance, 2020.

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Map 7: LDP Policy 33D – Spatial Framework for Wind7 
7 Policy 33D - Spatial Framework for Wind Map: Perth and Kinross Local Development Plan (2019)

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Statements of Agreement/ Dispute 
Respondent Agree or Dispute Summary of Comments PKC’s Response
Scottish Enterprise Disagree List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): Scottish Enterprise disagree with the list of
evidence/datasets for Topic Paper 012 and the Implications for the
Proposed Plan.   
Further Comments: Scottish Enterprise note that a final published
LHEES plan would be a pre-requisite for the Proposed Plan,
including more clarity/certainty around proposed heat network
zones. Scottish Enterprise also disagree with the wording in
paragraph 2.35 of the Topic Paper 012 in relation to the role of
hydrogen in the gas grid for future home heating. The response
highlights 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.
Formal Dispute: Scottish Enterprise do not wish to make a formal
dispute.
Comments noted. 
The section on the future role of
hydrogen has been updated to include
specific reference to the Hydrogen
Action Plan and to note that domestic
heating is not considered to be a
significant part of the future role of
hydrogen. 
The Council has published its LHEES
which is referenced above. The formal
designation of HNZs is still to take
place as noted above.
Errol Community
Council
Neither List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): The Community Council neither agreed or
disagreed with the list of evidence/datasets for Topic Paper 012 or
the Implications for the Proposed Plan.   
Further Comments: No further comments.
Formal Dispute: The Community Council does not wish to make a
formal dispute.
No further action.
NatureScot Neither List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): NatureScot neither agreed or disagreed with
the list of evidence/datasets for Topic Paper 012 or the
Implications for the Proposed Plan.   
No further action.

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Respondent Agree or Dispute Summary of Comments PKC’s Response
Further Comments: NatureScot welcomed the inclusion of
landscape in the Topic Paper.
Formal Dispute: NatureScot does not wish to make a formal
dispute.
Homes for Scotland Disagree List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): Homes for Scotland disagree with the list of
evidence/datasets for Topic Paper 012 and the Implications for the
Proposed Plan.   
Further Comments: Homes for Scotland provide a list of additional
evidence/datasets to be included:
• Hydrogen Action Plan (2022)
• ESO for GB – Electricity Explained: future energy scenarios
• Hydrogen Production and Export Locations – Site
Requirements Study (2022)
• Onshore Wind Policy Statement (2022)
• Scottish Water Renewable Energy Guide (2018)
• Scottish Government Climate Change Act – Section 72,
fourteenth annual report 
Homes for Scotland highlight that CC Act Section 72
Fourteenth Annual Report highlights there is no longer a need to
include policies within Development Plans under Section 3F
and a repeal Order is being prepared for consideration by the
Scottish Parliament.
Homes for Scotland also highlight 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.
It is highlighted that the Spatial Strategy for the next Plan will need
to consider both sustainable and marketable locations for new
development, and the Council will require to work with the DNO to
Comments noted. 
The listed documents have been
included for reference in the Evidence
Report. 
This Issue already makes reference to
the Fourteenth Annual Report on
Section 72 of the CC Act. This section
highlights that the Scottish
Government are intending to repeal
the Section 72 requirements. 
This Issue highlights that development
of the Spatial Strategy will need to
take into account the capacity of the
energy network when considering
development allocations. Working
with SSEN Transmission and
Distribution – an action identified in
the Council’s LAEP – will be an
important part of preparing the
Spatial Strategy to take these
considerations into account. Early
engagement has already been
undertaken with both the SSEN
distribution and transmission teams.

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Respondent Agree or Dispute Summary of Comments PKC’s Response
ensure that an upgrade to the network is aligned with future
housing supply pipeline. 
Homes for Scotland also highlight that ensuring alternative heating
solutions are available will ensure that housing need identified in
HFS Report ‘Existing Housing need in Perth and Kinross’ is not
delayed and can contribute to the future housing land
requirement. 
Formal Dispute: Homes for Scotland do not wish to make a formal
dispute.
In terms of heating solutions for new
housing developments, these are
underpinned by existing Building
Standards legislation (‘New Build Heat
Standard’) as well as potential
opportunities for the development of
heat networks, which will be further
consulted upon through the
requirements of the Heat Networks
(Scotland) Act 2021.
Holder Planning
o/b/o SSE
Renewables
Dispute List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): The respondent disagreed with the list of
evidence/datasets for Topic Paper 012 or the Implications for the
Proposed Plan.   
Further Comments: The respondent notes that the Onshore Wind
Policy Statement (2022) should be included in the list of datasets
for the Evidence Report. 
The respondent also notes that the PKC Landscape Capacity Study
for Wind (2010) should carry very limited weight due to it being
out of date and subsequent policy changes. Instead reference is
suggested to be made to NatureScot Guidance in terms of
landscape sensitivity.
The respondent also disagrees with paragraph 2.63 in relation to
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. Reference to NPF4 Policy 11 is made in terms of the
updated national approach to renewable proposals including BESS.
It is noted that local guidance would be helpful to further detail
any localised considerations however this is not required to be
enshrined within the new LDP.
Comments noted. 
In response to point 1, an additional
section has been added to the
Evidence Report to include reference
to the Onshore Wind Policy
Statement. 
In response to point 2, recognition is
already made to NatureScot’s
Landscape Sensitivity guidance as well
as highlighting that the Capacity Study
includes important landscape features
that will need to be taken into
account for large-scale wind
developments. It is recognised that
national policy for energy has
significantly shifted since publication
however the Study provides guidance
– including on important landscape
features within the PKC area – to help
inform future decision making.

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Respondent Agree or Dispute Summary of Comments PKC’s Response
Formal Dispute: The respondent wishes to make a formal dispute,
noting the following particular points:
• Omission of onshore wind: policy statement 2022 from
legal and National Policy Requirements and Expectations
section and from Section 2. 
• Paragraph 2.63 for the reasons outlined in response to
question 5a above.”
In response to point 3, the section on
the Spatial Framework for Wind has
been updated to provide clarity. NPF4
Policy 11b provides the over-arching
spatial policy for wind, superseding
the previous SPP. Recognition is made
that many of the environmental
considerations included within the
current Spatial Framework (LDP Policy
33D) are currently included in the
assessment of renewables proposals. 
Montagu Evans LLP
o/b/o Loch
Developments Ltd
Neither List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): The respondent neither agreed nor disagreed
with the list of evidence/datasets for Topic Paper 012 or the
Implications for the Proposed Plan.   
Further Comments: No further comments.
Formal Dispute: The respondent does not wish to make a formal
dispute. 
No further action.
SSEN Transmission Agree List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): SSEN Transmission agreed with the list of
evidence/datasets for Topic Paper 012 and the Implications for the
Proposed Plan.   
Further Comments: SSEN Transmission suggested two minor text
changes to paragraphs 2.10 and 2.11 of the topic paper:
• Should be “electricity” rather than “Energy” System
Operator
• Should be “OFGEM” rather than “Ofgem” as it’s an
acronym for the Office For Gas and Electricity Markets.
SSEN Transmission also suggest consideration of including SSEN
Transmission’s Coupar Angus substation as an area of high interest
for solar and battery developments.
Comments noted. Updates to the
Evidence Report section have been
made to incorporate suggested
changes/additions.

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Respondent Agree or Dispute Summary of Comments PKC’s Response
Formal Dispute: SSEN Transmission does not wish to make a
formal dispute.
Scottish Water Agree List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): Scottish Water agreed with the list of
evidence/datasets for Topic Paper 012 and the Implications for the
Proposed Plan.   
Further Comments: Scottish Water welcome PKC strategy for
expanding and developing local heat networks and recognise
importance of HNZs and their role in achieving goals set out in the
PKC LHEES. Scottish Water will work collaboratively across all
agencies involved to support future network expansion as
necessary.
Scottish Water also support infrastructure first approach – as a key
concept of NPF4 – and supports early consideration of water and
wastewater infrastructure through planning. Scottish Water also
emphasises the approach to supporting development ensuring the
risk of stranded assets is minimised where growth ambitions are
not realised.
Formal Dispute: Scottish Water does not wish to make a formal
dispute.
Comments noted. PKC will continue to
work with Scottish Water on any
potential future project(s) for
decarbonised energy and/or heat
network development.
Private Individual Disagree List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): The respondent disagreed with the list of
evidence/datasets for Topic Paper 012 however agreed with the
Implications for the Proposed Plan.   
Further Comments: The respondent notes that the topic paper
does not consider the potential concerns over the commercial
robustness of providers and the implications of failure of the
enterprise. The respondent also notes 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.
In response to point 1 it is considered
that this relates to the potential
provision of future heat networks in
the Council area. In terms of the
robustness of providers this isn’t a
material planning consideration. The
Heat Networks (Scotland) Act will
enact regulation to ensure that heat
network operations are suitability
regulated.

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Respondent Agree or Dispute Summary of Comments PKC’s Response
Formal Dispute: The respondent does not wish to make a formal
dispute.
In response to point 2, the Council’s
LHEES will steer future action in terms
of supporting the transition of fossil
fuel heating systems to decarbonised
solutions in rural areas.
Earn Community
Council
Agree List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): The Community Council agreed with the list of
evidence/datasets for Topic Paper 012 and with the Implications
for the Proposed Plan.   
Further Comments: The respondent welcomes the datasets and
information included and notes the low carbon programme is very
ambitious. The respondent also highlights the phasing out of
natural gas and transitioning to low carbon alternatives/renewable
energy will be a complex process and not to be underestimated.
Formal Dispute: The respondent does not wish to make a formal
dispute.
Comments noted. No further action.
Savills o/b/o Dupplin
Estate
Neither List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): The respondent neither agreed or disagreed
with the list of evidence/datasets for Topic Paper 012 or with the
Implications for the Proposed Plan.   
Further Comments: The respondent highlights the Perth
Sustainability Park proposal and the potential to integrate
renewable energy generation to support a key national and locally-
based business, Aviva, in its aim to decarbonise the Pitheavlis
campus. The respondent also highlights that infrastructure-led
development at Perth West will enable a low carbon solution to
urban growth that could be showcased as an exemplar across
Scotland and the UK. 
Formal Dispute: The respondent does not wish to make a formal
dispute.
Comments noted. Site specific
considerations in relation to energy
including opportunities for promoting
decarbonised, decentralised solutions,
will be considered further at the
Proposed Plan stage.
Savills o/b/o Scone
Estate
Neither List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): The respondent neither agreed nor disagreed Comments noted.

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Respondent Agree or Dispute Summary of Comments PKC’s Response
with the list of evidence/datasets for Topic Paper 012 and with the
Implications for the Proposed Plan.   
Further Comments: The respondent notes the opportunity for
large-scale renewables project to provide private wire electricity to
help decarbonise transport in the area
The respondent also notes the analysis of SIMD data as part of the
Evidence Report and highlight the prospect of renewables projects
that can raise community benefit funds to help tackle deprivation
across Perth and Kinross.  The respondent seeks for this initiative
to be referenced and encouraged in the Evidence Report and in
LDP3.
Formal Dispute: The respondents do not wish to make a formal
dispute.
In relation to point 1, the Proposed
Plan will be required to realise the
area’s full potential for electricity and
heat from renewable, low carbon and
zero emission sources by identifying a
range of opportunities for energy
development. Where there are
specific sites put forward that can
support the delivery of renewable
energy development this will be
further assessed during the
preparation of the Proposed Plan.
In terms of the role of community
benefits from onshore renewable
projects, additional information has
been included in this Issue under
‘community benefits’.
Anonymous
Responses x 2
Agree List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): The 2 x anonymous responses agreed with the
list of evidence/datasets for Topic Paper 012 and with the
Implications for the Proposed Plan.   
Further Comments: The 2 x anonymous responses welcome the
datasets and information included and notes the low carbon
programme is very ambitious. The responses also highlight the
transition to low carbon alternatives should not be
underestimated.
Formal Dispute: The respondents do not wish to make a formal
dispute.
No further action.

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Issue: Zero Waste
Corresponding NPF4 Policy/Policies:
• National Planning Framework 4, Policy 12: Zero Waste
• Other key NPF4 policy connections – 1: Tackling the climate and
nature crises; 2: Climate mitigation and adaptation; 9: Brownfield,
vacant and derelict land and empty buildings; 11: Energy; 18:
Infrastructure first; 19: Heat and cooling; 25: Community wealth
building; and 33: Minerals.
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 013: Zero Waste
https://consult.pkc.gov.uk/communities/copy-of-
topicpapers2/supporting_documents/TP013%20Zero%20waste.pdf
Information required by the Act and NPF4 regarding the topic:
Section 15(5) of the Town and Country Planning (Scotland) Act 1997, as
amended:
• the infrastructure of the district; and
• how that infrastructure is used.
Regulation 9
Have regard to:
• the national waste management plan
NPF4 Policy 12 expects LDPs should ‘…identify appropriate locations for
new waste management infrastructure to support the circular economy
and meet identified needs in a way that moves waste as high up the waste
hierarchy as possible.’
The policy intent for Policy 12 is noted as:
• To encourage, promote and facilitate development that is
consistent with the waste hierarchy
The policy outcomes for Policy 12 are:
• The reduction and reuse of materials in construction is prioritised
• Infrastructure for zero waste and to develop Scotland’s circular
economy is delivered in appropriate locations
The Scottish Government’s Local Development Plan Guidance under its
step by step guide provides advice on relevant evidence for the NPF4
policy topics to help planning authorities in considering the national
planning policies when preparing their Evidence Report.
With respect to NPF4 Policy 12 Zero waste, the Guidance advises that
planning authorities are expected to consider suitable sites for resource /
waste management infrastructure and that these may include those which
have been identified for employment, industry or storage and distribution,
former mineral sites and derelict or degraded land.
Planning authorities are expected to work with industry stakeholders to
help facilitate co-location and to integrate energy efficiency and waste
innovations within the construction and business environments. Links with
heat networks and the relationship with the relevant LHEES should also be
taken into account where relevant.

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Existing waste management sites may be safeguarded for current and
future use unless the facility is no longer required or the capacity can be
met through an alternative facility or technology of equal or improved
standard.
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:
Scotland's Zero Waste Plan
Scotland’s Zero Waste Plan highlights the aim of achieving a zero waste
Scotland where resources are used most efficiently by minimising our
demand on primary resources, and maximising the reuse, recycling and
recovery of resources. The Plan sets out targets for reducing waste and
increasing recycling.
The waste hierarchy is used to rank options according to the best
environmental outcome. It gives top priority to preventing waste, and
prioritises reuse, recycling and recovery of materials over disposal.
Making things last: a circular economy strategy
The Circular Economy strategy sets out the approach to keeping valuable
products and materials in use for as long as possible. 
The strategy aims to move Scotland towards a more circular economy by
using resources more efficiently, taking steps to encourage reuse and
reduce waste, and by increasing recycling of materials.
Stop, Sort, Burn, Bury - incineration in the waste hierarchy: independent
review
The Scottish Government commissioned a review on the decarbonisation
of residual waste infrastructure in 2021. The Stop, Sort, Burn, Bury? report
led to a Government decision to ban new Energy from waste plants, noting
that an excess in infrastructure capacity was likely. The report makes 12
policy recommendations for the Scottish Government, local authorities
and the wider waste industry, including proposing that no new permissions
should be granted for additional energy from waste infrastructure. 
Existing waste infrastructure
A summary of waste infrastructure capacity is set out in the following
section. 
Analysis of household waste data trends shows a significant recent
decrease in the amount of waste landfilled. The amount of waste recycled
is fluctuating between 49% and 53%.
Table of household waste data (percent) 2019-2023

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2019 2020 2021 2022 2023
Recycled 52.7% 49.4% 50.2% 49.3% 51.7%
Other * 5.8% 7.2% 7.6% 7.2% 21.2%
Landfilled 41.5% 43.4% 42.3% 43.5% 27.2%
* Other: represents waste diverted from landfill, not reused, recycled or
landfilled. It includes household waste treated by incineration, mechanical
biological and heat treatment. Source SEPA waste analysis: household
waste
A summary of waste sites and capacities is set out in the following table.
Table of all waste – sites and capacity – Perth and Kinross – 2019-2023 
2019 2020 2021 2022 2023
Number
of sites 43 43 43 44 44
Annual
capacity
(tonnes)
1,556,759 1,556,759 1,602,759 1,611,861 1,617,361
Waste
accepted
(tonnes)
262,342 227,649 469,359 471,937 465,946
Source SEPA waste analysis: waste sites and capacity 
The following map extract shows the location of waste sites in Perth and
Kinross. 
Source: SEPA waste analysis: waste sites and capacity map
Transfer station sites
Perth and Kinross has 10 registered transfer station sites with an annual
capacity of 356,900 tonnes. These sites accepted 95,540 tonnes in 2023.
Civic amenity sites
Perth and Kinross has nine civic amenity sites, which accepted 74,684
tonnes in 2023. The civic amenity sites are at the following locations:
• Aberfeldy

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• Auchterarder
• Bankfoot
• Blairgowrie
• Crieff
• Friarton, Perth
• Inveralmond, Perth
• Kinross
• Pitlochry
They are used for recycling, and for disposing of bulky waste and general
household waste.
The centres prioritise reuse and recycling of items, and the Council
promotes information on reuse and recycling of many types of material
including batteries, books, clothing and textiles, cooking oil and engine oil,
electrical equipment, furniture, light bulbs and tubes, paint, and plastic.
Food and garden waste sites
Food and garden waste collected by the Council is taken to Earnside
Energy, Glenfarg for industrial composting.
Landfill sites
There are seven registered landfill sites in Perth and Kinross, all of which
have ceased landfilling. The most recent landfill operations were in 2019
and there are no proposals to resume landfill operations.
From the end of 2025, the landfilling of biodegradable municipal waste in
Scotland will be banned as part of the Government's actions to transition
to a circular economy and reduce waste-related greenhouse gas emissions.
Energy from waste
The upcoming national end to landfill operations, together with increasing
landfill taxes and the waste hierarchy encouraging energy recovery over
landfill, has been linked to a rise in demand for incineration facilities as
waste is diverted away from landfill. However NPF4 does not support new
energy from waste facilities except in limited circumstances.
Proposed waste infrastructure
Future capacity
Scotland’s targets for waste and resource management are set out in the
Scottish Government’s Zero Waste Plan; and Making Things Last: A Circular
Economy for Scotland.
SEPA has produced an estimate of the national shortfall in waste
management infrastructure capacity required to meet these targets, the
SEPA Regional capacity calculations for Scottish Planning Policy (SPP). The
last available capacity estimates are based on 2018 data and were
published in December 2020. They refer to the TAYplan SDP area, which
comprised Angus, Dundee City, Perth and Kinross and north east Fife.
The following table shows the additional operational waste management
infrastructure capacity that was required to meet the Making Things Last
targets (tonnes) (SEPA 2018 data) 
TAYplan SDP area
Total additional diversion capacity needed 90,000

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Additional capacity needed to manage source
segregated recyclables 40,000
Additional capacity needed to manage unsorted
waste 50,000 
The following table shows the 10 year rolling landfill capacity that was
required (tonnes) (2018 data) 
TAYplan SDP area
10 year capacity of existing landfill infrastructure 250,000
10 year landfill required capacity 690,000 
Since this data was produced in 2018, landfill operations have ceased in
Perth and Kinross. However more the recent information on waste sites
and capacities, together with recent data on how household waste is
handled show that sufficient capacity exists. 
Additional future capacity: Energy from waste
In 2020, the Council granted planning permission for an energy from waste
plant at Binn Farm, Glenfarg. The location was identified in the Local
Development Plan for the expansion of waste management uses and the
approved facility has capacity for 84,900 tonnes per year. The
development is currently under construction and is scheduled to start
operating in 2026.
Summary of Implications for the Proposed Plan:
• 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.
Gaps, Uncertainties or Key Issues Raised:
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.
Summary of Stakeholder Engagement:
Big Place Conversation 
The Council carried out its ‘Big Place Conversation’ exercise to kick start
the LDP3 process across Perth and Kinross communities during most of
2023. This was a substantial exercise involving over 100 events throughout

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the Council area. The events ranged from drop-in information sessions,
meetings, and online surveys to workshops and online sessions using the
Place Standard Tool to capture the views of local communities about
different aspects of their places. The results of the BPC are summarised as
part of a separate report on the outcomes and findings across the different
locality areas.
LDP3 Evidence Report Topic Papers
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 week during
July and August 2024.  As part of our consultation process for LDP3 Topic
Papers we welcomed the views of our key stakeholders (who were
contacted specifically via email regarding the consultation exercise) and
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 LDP. 
Statements of Agreement/ 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.
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.
Earn Community Council made constructive comments on issues for the
Proposed Plan to consider.
A summary of these comments, their status, and the Council’s response
are provided in the table below.
There were no formal disputes.

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Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Historic
Environment
Scotland
Neither List of Evidence/Datasets: Has no specific comments to make.
Summary of Implications for the Proposed Plan: None
Further Comments: Notes that 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.
Formal Dispute: No.
PKC welcomes and agrees with the comments.
No further action required.
Earn
Community
Council
Agree List of Evidence/Datasets: Agree
Summary of Implications for the Proposed Plan: Agree
Further Comments: NPF4 Policy 12 Expects identification of the
need for new waste management infrastructure. 
Intent - encourage, promote and facilitate development of
waste. 
Outcomes - reduce and reuse especially in construction thus
promoting a circular economy.
Circular economy - 4 priority areas: Food and drink; re-
manufacture; construction; and energy infrastructure.
Research into how products ""flow"" through the economy. The
place of incineration is mentioned, but no comment. 
There is financial benefit as well as environmental benefit to
P&KC economy. - No mention of this either.  With budgets
tightening the financial benefit should not be dismissed.
Comment is that for such a huge topic it is only 10 pages. 
There was no indication of how to proceed in the aims.
Formal Dispute: No
The suitable stage at which to identify new
appropriate locations for new waste
management infrastructure is the Proposed Plan
stage and the respondent’s expectation
regarding the need for new waste management
infrastructure will be addressed by the Council
when the Evidence Report is agreed. 
The Council agrees that the Proposed Plan
should support the policy intent and outcomes
of Policy 12 and the four priority areas are
noted.
The financial and environmental benefits of
supporting the circular economy and moving
waste as high up the waste hierarchy as possible
are recognised in the NPF4 policy, and the
Proposed Plan will also address this point.