Appendix A - Sustainable Places
Perth and Kinross Council · 5 March 2025
Back to Perth and Kinross Council — 5 March 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Some pages contain no extractable text. They may be blank, graphics or scanned pages. OCR has not been applied.
Page 1
Perth and Kinross LDP3 2027 Draft Evidence Report Appendix A Sustainable Places March 2025
Page 2
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
Page 3
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
Page 4
• 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
Page 5
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
Page 6
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
Page 7
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.
Page 8
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
Page 9
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.
Page 10
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.
Page 11
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.
Page 12
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
Page 13
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
Page 14
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
Page 15
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.
Page 16
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.
Page 19
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.
Page 20
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
Page 22
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
Page 23
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
Page 29
level of priority taking climate action is given generally rose alongside affluence and was the least prioritised by those in SIMD Quintile 1.
Page 30
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.
Page 33
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.
Page 34
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.
Page 37
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.
Page 38
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
Page 47
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
Page 49
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
Page 52
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.
Page 53
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
Page 54
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
Page 55
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.
Page 56
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.
Page 57
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.
Page 58
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
Page 59
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
Page 60
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
Page 61
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
Page 62
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)
Page 63
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
Page 64
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
Page 65
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.
Page 66
No embedded text on this page.
Page 67
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:
Page 68
• 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.
Page 69
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
Page 70
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
Page 71
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:
Page 72
• 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
Page 73
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
Page 74
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
Page 75
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
Page 76
• 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
Page 77
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
Page 78
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.
Page 79
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
Page 80
• 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
Page 81
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
Page 82
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
Page 83
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.
Page 84
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.
Page 85
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.
Page 86
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
Page 87
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
Page 88
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.
Page 89
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.
Page 90
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
Page 91
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.
Page 92
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:
Page 96
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
Page 106
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
Page 115
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.
Page 116
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.
Page 117
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'
Page 120
No embedded text on this page.
Page 121
No embedded text on this page.
Page 122
No embedded text on this page.
Page 123
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
Page 124
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.
Page 125
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
Page 126
3 • 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
Page 127
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
Page 128
5 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
Page 129
6 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.
Page 130
7 • 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:
Page 131
8 − 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.
Page 132
9 • 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.
Page 133
10 • 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.
Page 134
11 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
Page 135
12 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.
Page 136
13 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.
Page 137
14 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.
Page 138
15 • 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.
Page 139
16 Map A4(1): Scottish Water Drinking Water Protected Areas – Catchments
Page 140
17 Map A4(2): Scottish Water Drinking Water Protected Areas – Groundwaters
Page 141
18 Map A4(3): Scottish Water Drinking Water Protected Areas – Rivers and Lochs
Page 142
19 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
Page 143
20 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.
Page 144
21 Map A4(4): National Forest Inventory for the Perth and Kinross Area
Page 145
22 Map A4(5): Native Woodland Survey of Scotland for the Perth and Kinross Area
Page 146
23 Map A4(6): Ancient Woodland Inventory and Ancient Tree Inventor
Page 147
24 Map A4(7): Tree Preservation Orders within the Perth and Kinross Area
Page 148
25 Map A4(8): Inventory of Gardens and Designed Landscapes Sites within the Perth and Kinross Area
Page 149
26 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
Page 150
27 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
Page 151
28 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.
Page 152
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.
Page 153
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
Page 154
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.
Page 155
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
Page 156
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.
Page 157
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.
Page 158
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.
Page 159
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.
Page 160
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%
Page 161
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.
Page 163
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.
Page 164
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
Page 167
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
Page 168
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.
Page 169
46 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.
Page 170
47 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
Page 171
48 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.
Page 172
49 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.
Page 173
50 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
Page 174
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.
Page 175
52 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
Page 176
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,
Page 177
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
Page 178
55 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
Page 179
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
Page 180
57 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
Page 181
58 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
Page 182
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.
Page 183
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
Page 184
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
Page 185
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
Page 186
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.
Page 187
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
Page 188
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.
Page 189
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
Page 190
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.
Page 191
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.
Page 192
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.
Page 196
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)
Page 197
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
Page 198
Map 1: Historic Land Use Assessment for the Perth and Kinross Area (Land Uses/ Function)
Page 199
Map 2: Historic Land Use Assessment for the Perth and Kinross Area (Time Periods)
Page 200
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
Page 201
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.
Page 202
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.
Page 203
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
Page 204
Map 3: Location of Conservation Areas within Perth and Kinross
Page 205
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.
Page 206
Map 4: Location of Listed Buildings within Perth and Kinross
Page 207
Map 5: Location of Buildings on the Buildings At Risk Register within Perth and Kinross
Page 208
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.
Page 209
Map 6: Location of Scheduled Monuments within Perth and Kinross
Page 210
Map 7: Location of Garden and Designed Landscape and Historic Battlefields Sites within Perth and Kinross
Page 211
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
Page 212
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.
Page 213
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.
Page 214
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
Page 215
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.
Page 216
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.
Page 217
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
Page 218
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
Page 219
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
Page 220
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.
Page 221
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]
Page 222
• 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.
Page 223
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.
Page 224
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)
Page 225
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
Page 226
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
Page 227
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
Page 228
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.
Page 229
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
Page 230
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
Page 231
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
Page 232
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
Page 233
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.
Page 234
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.
Page 235
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
Page 236
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
Page 237
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
Page 238
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.
Page 239
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.
Page 241
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.
Page 243
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
Page 250
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.
Page 251
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
Page 252
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.
Page 253
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.
Page 254
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
Page 255
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
Page 256
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:
Page 259
• 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
Page 263
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.
Page 264
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.
Page 266
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.
Page 267
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.
Page 268
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
Page 269
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.
Page 270
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
Page 271
No embedded text on this page.
Page 272
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:
Page 273
• 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
Page 274
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
Page 275
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
Page 276
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.
Page 277
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
Page 278
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.
Page 279
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
Page 280
• 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.
Page 281
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
Page 282
(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.
Page 283
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
Page 284
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
Page 285
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,
Page 286
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
Page 287
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.
Page 288
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
Page 289
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
Page 290
• 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.
Page 291
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)
Page 292
Map 2: Map of Existing ‘Green Assets’2 2 ‘Smart Perth & Kinross’ Programme: Mapping out low carbon & green energy smart investments, 2022.
Page 293
Map 3: Binn Eco Park & Abernethy Cluster3 3 ‘Smart Perth & Kinross’ Programme: Mapping out low carbon & green energy smart investments, 2022.
Page 294
Map 4: Perth West, Broxden & Perth City Cluster4 4 ‘Smart Perth & Kinross’ Programme: Mapping out low carbon & green energy smart investments, 2022.
Page 295
Map 5: Key Smart Investments across Perth and Kinross5 5 ‘Smart Perth & Kinross’ Programme: Mapping out low carbon & green energy smart investments, 2022.
Page 296
Map 6: Map of Landscape Designations in Perth and Kinross6 6 Map of Landscape designations in Perth and Kinross, ‘Landscape’ Supplementary Guidance, 2020.
Page 297
Map 7: LDP Policy 33D – Spatial Framework for Wind7 7 Policy 33D - Spatial Framework for Wind Map: Perth and Kinross Local Development Plan (2019)
Page 298
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.
Page 299
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.
Page 300
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.
Page 301
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.
Page 302
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.
Page 303
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.
Page 304
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.
Page 305
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.
Page 306
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
Page 307
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
Page 308
• 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
Page 309
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
Page 310
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.
Page 311
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.