Appendix B - Liveable Places
Perth and Kinross Council · 5 March 2025
Back to Perth and Kinross Council — 5 March 2025 and its agenda
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Perth and Kinross LDP3 2027 Draft Evidence Report Appendix B Liveable Places March 2025
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Issue: Design, Quality and Place Corresponding NPF4 Policy/Policies: • National Planning Framework 4, Policy 14: Design, quality and place • Other key NPF4 policy connections – All other NPF4 policies Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 018: Design, Quality and Place (https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume nts/TP018_DesignQualityandPlace.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, cultural, economic, social, built heritage, and environmental characteristics of the district. Policy 14 of NPF4 expects the following from LDPs: • LDPs should be place-based and created in line with the Place Principle. The spatial strategy should be underpinned by the six qualities of successful places. LDPs should provide clear expectations for design, quality and place taking account of the local context, characteristics, and connectivity of the area. They should also identify where more detailed design guidance is expected, for example, by way of design frameworks, briefs, masterplans, and design codes. Planning authorities should use the Place Standard Tool in the preparation of LDPs and design guidance to engage with communities and other stakeholders. They should also where relevant promote its use in early design discussions on planning applications. The Policy Intent of Policy 14 is noted as: • To encourage, promote and facilitate well designed development that makes successful places by taking a design-led approach and applying the Place Principle. The Policy Outcomes are: • Quality places, spaces and environments. • Places that consistently deliver healthy, pleasant, distinctive, connected, sustainable and adaptable qualities. 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 14, the Guidance advises that planning authorities can include information about the quality of existing places, in reference to the six qualities of successful places, to develop a useful understanding of how local places are experienced in the context of wider data about socio- economic and environmental characteristics. The Guidance suggests that a place-based approach identifying the links between design, quality and place and other relevant policy areas will support this.
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Links to Evidence: • Perth and Kinross Council Corporate Plan 2022-2027 LDP Spatial Strategies • Scottish Government and COSLA’s Place Principle (2019) • Scottish Government, Creating Places: A policy statement on architecture and place for Scotland (June 2013) • Scottish Government, Designing Streets: A Policy Statement for Scotland (March 2010) • Perth and Kinross Local Development Plan 2 (2019) • Scottish Government NPF4: Annex D – Six Qualities of Successful Places • Transport Scotland, Sustrans and SCOTS, Cycling by Design 2021 • Scottish Government, Planning Advice Note 83: Master planning • Perth and Kinross Placemaking Guide Supplementary Guidance (2020) • Perth and Kinross Consultation Draft Mobility Strategy (2024) • Perth and Kinross Mobility Strategy Draft Action Plan (2024) • Scottish Household Survey (SHS) Understanding Our Local Places • The Improvement Service, Place Standard Engagement Tool • Perth and Kinross Council LDP3 Big Place Conversation • Scottish Index of Multiple Deprivation (SIMD) • Scottish Government, Scottish House Condition Survey: Local Authority Analysis 2017-2019 (February 2021) • Perth and Kinross Council, Local Housing Strategy (LHS) 2022-2027 • Perth and Kinross Council, LHS Action Plan 2022-2027 • Perth and Kinross LDP2 Design Charettes • Perth and Kinross Community Plan (Local Outcomes Improvement Plan) 2022-32 • Perth and Kinross Area Local Action Plans • Community Action Plans: Meigle and Ardler, Stanley, Alyth, Coupar Angus, Dunkeld and Birnam, Crieff, Blairgowrie and Rattray, Pitlochry and Moulin, Muthill and Tullibardine, Auchterarder and Aberuthven, and St. Fillans. • Perth and Kinross Council Ward Profiles Summary of Evidence: 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. LDP Spatial Strategies The Scottish Government and COSLA's Place Principle (2019) In 2019 the Scottish Government and COSLA agreed to adopt a Place Principle to help overcome organisational and sectoral boundaries to encourage better collaboration and community involvement. The Place Principle promotes a shared understanding of place, and the need for communities, public organisations, and businesses to work together to achieve better outcomes for people and communities. The Place Principle says that we recognise that:
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• Place is where people, location and resources combine to create a sense of identity and purpose and is at the heart of addressing the needs of communities and helping them realise their full potential. Places are shaped by the way resources, services and assets are directed and used by people who live in and invest in them. • A more joined-up, collaborative and participative approach to services, land, and buildings, across all sectors within a place, helps support better outcomes for all, and increased opportunities for people and communities to shape their own lives. The Principle requests that: • All those responsible for providing services and looking after assets in a place need to work and plan together and with local communities, to improve the lives of people, support inclusive and sustainable economic growth, and create more successful places. Scottish Government, Creating Places: A policy statement on architecture and place for Scotland (June 2013) This policy statement outlines the Scottish Government’s position on architecture and place. Part One looks at the value of architecture and place and sets out what ‘good design’ is; the key qualities of successful places, and the value good buildings and places can bring to individuals, society and Scotland. It explores – • What quality places mean to people and communities, and how a successful place is accessible to all, and encourages people to connect with one another, helping to create communities which are sage, socially stable and resilient. • The issue of sustainable development, and why it is important to design sustainable buildings and sustainable places to help reduce carbon emissions, maximise energy efficiency and climate resilience, make our buildings more flexible in the longer term, improve the health and wellbeing of our communities, and create more attractive, accessible and well-connected places. • How well-designed buildings and places can help boost the economy through attracting visitors, workers and investors. • The positive health benefits that can be realised through design, by increasing human connectedness, and provided access to good quality greenspace, safe streets and places for children to play outdoors. • The links between our natural and built environments and our national culture and identity, and how the quality of our assets not only adds to Scotland’s international image, helping to attract visitors and investors, but through working together to conserve our rich national assets, we can create a positive legacy for future generations to continue to enjoy. • The importance of landscapes; the need to manage landscape change in a well-planned and considered way that is appropriate to the location, and recognising how landscape design is an integral part of placemaking. Part Two of the policy statement deals with ‘Consolidation and Ambition’. It considers how the Scottish Government’s ambition for architecture and place can be delivered through involving communities in a meaningful way and emphasises that working across different disciplines and sectors is crucial to achieve best possible outcomes. Part Three sets out a strategy “to enable architecture and place policy to better articulate with a range of related policy areas and, in doing so, achieve greater positive physical change. The strategy’s key themes and their associated policies are:
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1. Architecture and Planning - Everyone responsible for Scotland’s built and natural environment must recognise that architecture and places are not simply elements of the planning process – they are among the most important outcomes that the process exists to support, and their quality should be a priority. 2. Investment: Decisions Informed by Place - Communities and places benefit from investment decisions that consider all impacts – societal, environmental as well as economic. Decisions should prioritise long term benefits. The public sector should set an example by ensuring high design standards are adhered to in public procurement. 3. Developing Our Potential – All areas of policy and practice should utilise and promote design as a tool to deliver value, sustainable outcomes and high quality. Scotland’s design heritage and design talent should be celebrated, and the next generation developed and promoted. 4. Design for A Low Carbon Economy – Low carbon design and planning should be a priority. Project clients, commissioners, designers and approvers should encourage design innovation and take advantage of locally-sourced materials to facilitate sustainable development. A ‘re- use not replace’ approach should be considered first when dealing with our existing built environment. 5. Cultural Connections – Creative responses should be taken to enhancing and preserving our existing built heritage. The development of creative places and culture-led regeneration should be encouraged as an effective approach to delivering sustainable, high-quality environments. 6. Engagement and Empowerment – Design processes should harness and utilise the knowledge of communities and encourage active participation in the process, to deliver places with local integrity and relevance. Engagement must be meaningful, early and proportionate. 7. The Role of Architecture and Design Scotland The planning process is seen as playing a fundamental role in helping shape the quality of our architecture, and as such it is important that the two disciplines are closely aligned. Scottish Government, Designing Streets: A Policy Statement for Scotland (March 2010) This document, when published in 2010, was the first policy statement in Scotland for street design and changed the emphasis of guidance on the issue away from a system focused on the dominance of motor vehicles, to a place-making approach. It is based on the premise that good street design should come from “an intelligent response to location, rather than the rigid application of standards, regardless of the context.” It sits alongside ‘Designing Places’, and together are the Scottish Government’s two key policy statements on design and placemaking. The policies set out in the statement are: • Street design must consider place before movement. • Street design guidance, as set out in ‘Designing Streets’, can be a material consideration in determining planning applications and appeals. • Street design should meet the six qualities of successful places, as set out in ‘Designing Places’. • Street design should be based on balanced decision-making and must adopt a multidisciplinary approach. • Street design should run planning permission and Road Construction Consent (RCC) processes in parallel. Perth and Kinross Local Development Plan 2 (2019) The current Perth and Kinross Local Development Plan 2 (2019) along with its accompanying supplementary guidance documents provide a good
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basis of understanding of the local context and characteristics of the Perth and Kinross Area, as well as connections within and into and out of the Area. Information on the principal characteristics of the Area is explored in greater detail within our LDP3 Evidence Report Topic Paper 001: The Plan Area. NPF4: Annex D – Six Qualities of Successful Places NPF4 Policy 14 expects that LDP spatial strategies are underpinned by these six qualities: 1. Healthy: Supporting the prioritisation of women’s safety and improving physical and mental health. 2. Pleasant: Supporting attractive natural and built spaces. 3. Connected: Supporting well connected networks that make moving around easy and reduce car dependency. 4. Distinctive: Supporting attention to detail of local architectural styles and natural landscapes to be interpreted into designs to reinforce identity. 5. Sustainable: Supporting the efficient use of resources that will allow people to live, play, work and stay in their area, ensuring climate resilience and integrating nature positive biodiversity solutions. 6. Adaptable: Supporting commitment to investing in the long-term value of buildings, streets, and spaces by allowing for flexibility so that they can meet the changing needs and accommodate different uses over time. Annex D provides further details in terms of what we should be designing for when implementing each of the Six Qualities. Transport Scotland, Sustrans and SCOTS, Cycling by Design 2021 Cycling by Design provides design guidance for cycling infrastructure on all roads, streets and paths in Scotland. The document “aims to ensure that cycling is a practical and attractive choice for everyday and occasional journeys of all people, particularly new, returning or less confident users.” At the heart of the National Transport Strategy 2 (NTS2) vision and priorities is the aim to encourage people to travel by more active and sustainable means. Through making this modal shift we can help reduce carbon emissions and contribute to national priorities in terms of equality and health improvements. High-quality cycling infrastructure can help to encourage a wider range of people to take up cycling. The design guidance is intended to support designers in integrating cycling into the built environment, and should be applied to schemes delivering cycling infrastructure, new and improved roads, new developments, and any other built environment feature where cycling should be considered. The guidance supports an objective developed by the Active Travel Task Force in their 2018 Delivery Plan, which sought to “improve delivery of the ambitious and inclusive walking and cycling projects in Scotland that will help to create high-quality places and communities that support health and wellbeing.” It also supports the integration of cycling with people walking and wheeling, in holistic and attractive environments, serving the needs of all users, and facilitating the implementation of the Scottish Government’s Sustainable Travel Hierarchy. Designers are expected to meet or exceed the design requirements set out in the guidance to deliver this aspiration. Cycling by Design contains, amongst other information: • ‘12 key messages to designers’, which summarise how they should approach the application of the document’s requirements.
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• A section on ‘Planning for Users’, which considers the needs of users based on their ‘Type’ i.e. new and less confident users, and confident, existing users; different types of cycle vehicle, including their dimensions and turning circle requirements; physical effort required, and how to make a journey attractive and convenient, regardless of age and ability. • A section on Core Design Principles (Safety, Coherence, Directness, Comfort, Attractiveness and Adaptability). • Information on Level of Service indicators (High, Medium and Low) to help designers identify the strengths and weaknesses of their design and identify improvements to achieve a high level of service. • The stages in the Planning and Delivery Process for cycle networks, including using multi-modal/strategic appraisals. • Network Planning in different settings (techniques, components, and integration with other model networks). • Designing new developments to meet or exceed the highest level of service. • Information on the Design Review Process. • Cycle Links (principles, types, providing appropriate facilities). • Geometric Design Requirements. • Considerations for different types of tracks e.g., detached or remote, those adjacent to carriageway, cycle lanes, and mixed traffic streets. • Construction options and details, including advantages and disadvantages. • Detailed design considerations for crossings, junctions, and roundabouts. • Trip end facilities considerations, such as cycle parking, public transport integration, public cycle hire, active travel hubs etc. Scottish Government, Planning Advice Note 83: Masterplanning (2008) This Planning Advice Note (PAN) covers the masterplanning process from beginning to end. It was produced as part of the Scottish Government’s commitment to the design quality agenda, and aims to: • Promote the use of masterplanning to create better places; • Set out how to achieve more effective masterplanning; • Achieve greater consistency in the presentation of masterplans, and • Highlight exemplar case studies to help encourage good practice. Masterplanning is regarded as having the ability to help raise the general standards of urban design and create quality places through providing a structured approach and framework to a wide range of complex issues. Successful masterplanning can promote sustainability and deliver places where people want to live and work. PAN 83 highlights that masterplans can be prepared for almost any site, but that there are types of sites and circumstances where one is most likely to be appropriate i.e., for areas of significant change; sensitive areas; certain small-scale developments, and sites specifically identified via the development plan for an area. The process can also help raise standards in smaller scale developments. Masterplanning is seen as having an important role in creating “well- designed built environments that make us feel welcome and secure, and that promote healthier lifestyles, reduce our environmental impact, are adaptable and have lasting economic and social benefits.” The process requires a high degree of collaboration and communication between a wide range of stakeholders, which can help build commitment to proposals and increase the chances of successful delivery.
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Perth and Kinross Placemaking Guide Supplementary Guidance (2020) The Council adopted its Perth and Kinross Placemaking Guide Supplementary Guidance in March 2020. It was developed to support Policy 1 of the Perth and Kinross LDP2 and is used in the assessment of planning applications and to assist in the placemaking process. The Guide further develops the placemaking criteria and provides more detailed guidance on how to achieve the policy requirements in LDP2. It also provides clear explanations as to how to achieve high quality development that responds to the unique setting of Perth and Kinross. Policy 1: Placemaking of LDP2 and the Guide were developed on the basis of the Scottish Government’s six qualities of successful place contained in Scottish Planning Policy (2014). Those qualities (Distinctive, Safe and Pleasant, Welcoming, Adaptable, Resource Efficient, and Easy to Move Around and Beyond) have been updated slightly for the current set of qualities at Annex D of NPF4, however the key elements and objectives remain the same. The Placemaking Guide also reflects the key messages set out in the Scottish Government’s Creating Places and Designing Streets policy statements. Perth and Kinross Consultation Draft Mobility Strategy (2024), and Perth and Kinross Mobility Strategy Draft Action Plan (2024) The Draft Strategy is a Local Transport Strategy for the Perth and Kinross Area and 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. The Draft Mobility Strategy responds to the climate change agenda and changes in how people travel. It also considers emerging technologies, digital services, housing, inclusion, poverty, health, climate adaptation, economic growth, air quality, and placemaking. The Draft Strategy is also accompanied by a Draft Action Plan which includes several actions which are of direct relevance to our Local Development Plan 3 Spatial Strategy, including those relating to: connected neighbourhoods and centres; green and blue infrastructure; open spaces and opportunities for play, and the identification of sustainable future site allocations. Action 153 is of particular relevance to the Design, Quality and Place policy subject matter. This action is aimed at ensuring developments consider place and prioritise the needs of people before the movement of motor vehicles, in line with national and regional guidance. This includes prioritising sustainable and active travel choices, and including fully accessible paths and routes which are well connected with the wider environment beyond the site boundary. Scottish Household Survey (SHS) The Scottish Household Survey (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, via a random sampling of people in private residences. Participation is voluntary and is important in helping the Scottish Government make representative estimates for Scotland. The most recent publication is the 2022 SHS.
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Neighbourhood Satisfaction The SHS Neighbourhoods and Communities data provides a picture of how residents rate their neighbourhoods as a place to live. In 2022, the data reports that the percentage residents of Perth and Kinross who rated overall their neighbourhood as very/fairly good was 95%, which is the same as the Scotland figure. 63% of residents ranked their neighbourhood as very good; 32% as fairly good; 4% as fairly poor, and 1% as very poor. These percentages also closely mirror the Scotland figures for each of the rankings. The percentages for the Perth and Kinross Area have also remained similar throughout the years since the first survey undertaken in 1999. Figure B1(1): SHS Residents Satisfaction with their Neighbourhoods (2022) Feeling of Belonging to a Community The Survey asked other questions relating to feeling of belonging to a community; experience (by adults) of neighbourhood problems; perceptions of safety when walking alone in their neighbourhood after dark; frequency of social interactions, and how often adults had felt lonely within the previous week time period. The percentage results of those survey questions, where available, are set out below. The results of the survey question regarding ‘Strength of feeling of belonging to a community’ are broken down further to provide figures by sex, age, ethnicity, SIMD quintiles, and housing tenure. The figures overall for Perth and Kinross were fairly similar to those of the Scotland average for the same survey questions. In the Perth and Kinross Area: • 37% of participants felt very strongly in terms of belonging to a community (Scotland average – 38%). • 44% felt fairly strongly (Scotland average – 45%). • 14% felt not very strongly about belonging (Scotland average - 13%). • 3% felt not at all strongly (Scotland average – 4%), and • 2% didn’t know (Scotland average – 1%). When we look at those results closer in terms of breakdown between male and female participants in the area: • 40% of males and 35% of females felt very strongly in terms of belonging to a community (Scotland averages – 36% and 39%).
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• 36% of males and 53% of females felt fairly strongly (Scotland average – 45% and 44%). • 21% of males and 7% of females felt not very strongly about belonging (Scotland averages - 13% and 12%). • 2% of males and 4% of females felt not at all strongly (Scotland averages – 4% and 4%), and • 2% of males and 1% of females didn’t know (Scotland averages – 1% for both sexes). There were no recorded survey participants in the age categories from 16 through to 59, or for the 75 and over group. Figures for the 60-74 age group show that: • 44% of participants felt very strongly in terms of belonging to a community (Scotland average – 46%). • 42% felt fairly strongly (Scotland average – 41%). • 12% felt not very strongly about belonging (Scotland average - 10%). • 1% felt not at all strongly (Scotland average – 2%), and • 2% didn’t know (Scotland average – 1%). Apart from survey data for the ‘White: Scottish’ ethnic group, there are no survey results for any of the other reported ethnicity groups for the Perth and Kinross Area. For that group the results were: 43% felt very strongly; 45% felt fairly strongly; 10% felt not very strongly; 1% felt not at all strongly, and 1% didn’t know. Survey data is available for those Scottish Index of Multiple Deprivation (SIMD) areas in Perth and Kinross which are within Quintiles 3 (41-60% most deprived) and 4 (61-80% most deprived). Note that Quintile 1 is the 20% most deprived data zones in Scotland, and Quintile 5 the 20% least deprived. For Quintile 3 the results were: 34% felt very strongly; 58% felt fairly strongly; 5% felt not very strongly; 3% felt not at all strongly, and 0% didn’t know. These figures differ only slightly from those of the Scotland average for the same Quintile. In terms of Quintile 4: 44% felt very strongly; 35% felt fairly strongly; 15% felt not very strongly; 1% felt not at all strongly, and 4% didn’t know. Again, these figures were fairly similar to the Scotland average results. Problems within Neighbourhoods Participating adults were asked whether a particular set of problems was very or fairly common in their neighbourhood over the 12-month period preceding the survey. Those problems related to noisy neighbours or regular loud parties; graffiti or other deliberate damage to property; rubbish or litter lying around; neighbour disputes; intimidation or harassing of others by individuals; drug misuse or dealing; drunkenness, hooliganism, or loutish behaviour; abandoned or burnt out vehicles, and animal nuisance (noise or dog fouling). The results were reported in terms of both perception and personal experience.
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Figure B1(2): SHS Problems within Neighbourhoods (2022) Perceptions of Safety The SHS Neighbourhoods and Communities Survey also asked participants about their perceptions of safety when walking alone in their neighbourhoods after dark. The results have been reported by sex, age, SIMD, sexual orientation, ethnicity, religious belonging, and disability. Figures B1(3) and (4) to follow show that 13% more male participants felt very or fairly safe walking in their neighbourhoods after dark compared to female survey participants (95% compared to 82%), and 10% of females felt very or a bit unsafe compared to 4% of male survey participants. Figure B1(3): SHS Male Residents Perception of Safety (2022) Figure B1(4): SHS Female Residents Perception of Safety (2022) It is difficult to provide further analysis in terms of age groups and their perceptions as results have only been reported for the Age 60-74 group.
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The lack of reported results is mostly due to the sample size being too small and therefore considered to be insufficiently reliable for publication. This is the same for the SIMD Quintiles, Sexual Orientation, and Ethnicity categories, for the Perth and Kinross Area, making it difficult to get a full picture of perception of safety across the different categories. Social Interaction and Feelings of Loneliness The SHS asked participants how frequently they meet socially with friends, relatives, neighbours, or work colleagues. The results reported for the following options were fairly similar across both categories, and to the Scotland average also: • At least once per week – 64% of males and 70% of females. • At least once or more – 25% of males and 23% of females. • A few times per year/ very rarely – 10% of males and 6% of females. • Never – 1% of males and 1% of females. When we then look at the breakdown for those persons who classify themselves as either disabled or non-disabled, the figures are fairly similar across both categories, and to the Scotland average also: • At least once per week – 64% of Disabled Persons and 68% of Non- Disabled Persons. • At least once or more – 28% of Disabled Persons and 23% of Non- Disabled Persons. • A few times per year/ very rarely – 6% of Disabled Persons and 9% of Non-Disabled Persons. • Never – 2% of Disabled Persons and 1% of Non-Disabled Persons. In terms of how often adult participants felt lonely within the week preceding the survey being carried out, again results have only been reported for the age group 60-74. This makes it difficult to form any picture of loneliness felt in Perth and Kinross across the different age groups. However, results are available for SIMD Quintiles 3 and 4, and for those participants who classify themselves as either disabled or non- disabled. The results are as follows for the different survey answer options: • None or almost none of the time – SIMD 3: 76%; SIMD 4: 74%; Disabled Persons: 76%, and Non-Disabled Persons: 82%. • Some of the time – SIMD 3: 22%; SIMD 4: 24%; Disabled Persons: 20%, and Non-Disabled Persons: 17%. • Most, almost all of the time – SIMD 3: 3%; SIMD 4: 2%; Disabled Persons: 4%, and Non-Disabled Persons: 1%. • Don’t know – SIMD 3: 0%; SIMD 4: 0%; Disabled Persons: 0%, and Non-Disabled Persons: 0%. Understanding Our Local Places The Scottish Government’s LDP Guidance highlights for NPF4 Policy 14, that it will be useful to develop an understanding of how local places are experienced, in the context of wider data about socio-economic and environmental characteristics, and that a place-based approach which identifies the links between design, quality and place, as well as other topical policy areas, will support this. The ‘Step by step guide - Evidence Reports’ in the Guidance suggests the Place Standard Tool, Design Charettes, Local Place Plans (LPPS), other community-led plans, and Creating Places as relevant sources of information which planning authorities may wish to prepare or review for their spatial implications. There are currently no Local Place Plans covering any part of the Perth and Kinross Council Area, but the other information sources are explored in the paragraphs to follow.
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The Improvement Service Place Standard Engagement Tool The Place Standard Engagement Tool provides a simple framework to help structure conversations about a place. It contains 14 themes under 4 thematic groups. It allows users to think about the physical elements of a place, like buildings, spaces, and transport connections, as well as the more social aspects, such as whether or not people feel they have a say in decision making about their place. Scottish Index of Multiple Deprivation (SIMD) (2022) The 2020 Scottish Index of Multiple Deprivation (SIMD) data tells us that 39 out of 186 (21%) of all data zones in the Perth and Kinross Area are ranked in the 40% most deprived areas in Scotland; 7 out of 136 (4%) are within the 15% most deprived; 3 out of 186 (2%) are within the 10% most deprived areas, and 44 out of 186 (24%) are within the 20% least deprived areas in Scotland. The 10% most deprived areas in Perth and Kinross can be found in Perth (Muirton, and Hillyland, Tulloch and Inveralmond), and Blairgowrie East (Rattray). Map B1(1) shows the distribution of SIMD deciles across the Council Area, and Maps B1(2) and (3) show the location of the 10% most deprived areas in Perth and Blairgowrie East. We know from SEPA flood risk management data that there are also Potentially Vulnerable Areas covering the Blairgowrie East and Perth City SIMD areas, and an Air Quality Management Area covering Perth City too. This all helps build a picture of the area’s most vulnerable places and people to help us in developing our Spatial Strategy.
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Map B1(1): SIMD Areas within Perth and Kinross
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Map B1(2): SIMD 10% Most Deprived Areas in Perth City (2020) Map B1(3): SIMD 10% Most Deprived Areas at Blairgowrie East (2020)
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Scottish Government, Scottish House Condition Survey: Local Authority Analysis 2017-2019 (February 2021) This report is part of the Scottish House Condition Survey (SHCS) follows on from the main Scottish House Condition Survey Key Findings report to present estimates of key indicators from the SHCS at a local authority level. It merges three years’ worth of data (2017-2019) in order to achieve sufficient sample sizes - it is worth noting that the survey analysis reports on the average figures for the three-year period. Some of the key indicators the report sets out the local authority level figures for include - fuel poverty rates, energy efficiency ratings, the condition of housing, and the Scottish Housing Quality Standard. The bullet points that follow, set out the detailed breakdown of information contained in the analysis report about the housing stock within the Perth and Kinross Council (PKC) Area for the 2017-2019 time period compared to the Scottish average position. However, in summary, the analysis tells us that: Age and Types of Dwellings: The age of the housing stock within the PKC Area is similar to the Scotland Average, with the majority of dwellings being built after 1945 (65%). 81% of all dwellings are houses, and 19% are flats. Tenure Breakdown: The highest percentage of dwellings are in the Owner- occupied category (67%), and levels of owner-occupation, Social Housing, and Private Rent are similar to the Scotland Average figures across all tenures. Restrictions and Adaptations: A small percentage of households overall within the area have a long-term sick or disabled resident who is restricted by the dwelling (4% PKC Area, 7% Scotland Average), and the percentage of dwellings reported as requiring adaptations is also small (PKC Area 2%, Scotland 3%). Heating and Energy Efficiency: The majority of dwellings within the area have full central heating (91%, compared to the Scotland Average of 96%). However, 31% of the overall stock across the PKC Area is off the gas grid, compared to only 17% of the Scotland Average overall stock figure. A small percentage of the overall stock received a Low Energy Efficiency Rating using the Standard Assessment Procedure (SAP) 2012 based on running costs – 8% compared to the Scotland Average figure of 4%; whereas 34% obtained a High Energy Efficiency Rating based on running costs (45% Scotland Average). Environmental Impact of Housing Stock: 20% of dwellings within the area received a low Environmental Impact Rating, compared to 9% Scotland Average figure. 26% of dwellings obtained a high Environmental Impact Rating, compared to the Scotland Average figure of 34%. Fuel Poverty: 25% of households within the PKC Area were estimated to be in fuel poverty, with a fairly even percentage share across Older households, Families and Other households. These figures are similar to those of the Scotland Average ones for fuel poverty. 18% of households overall are estimated to be in extreme fuel poverty (12% Scotland Average figure). Occupancy Levels: Only 1% of the overall stock within the PKC Area is estimated to be overcrowded/below the Bedroom Standard, but 41% is estimated to be under-occupied i.e. exceed the Bedroom Standard by 2 or more bedrooms.
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Scottish Household Quality Standard (SHQS)1: 37% of the area’s stock fail the SHQS overall, compared to 41% of the Scotland Average figure. A slightly larger percentage of dwellings built Pre-1945 (47%) failed, compared to those built after 1945 (32%). In terms of tenure type, 38% Owner-occupied dwellings fail the SHQS overall; 21% Social Housing fail, and 56% of Private Rent. The Scotland average figures for those tenures are similar for Owner-occupied dwellings (37%), but higher for Social Housing (41%) and lower for Private Rent (35%). Considering the SHQS “Energy Efficiency” criterion, 32% of the overall housing stock within the PKC Area fail to meet the standard, the Scotland Average figure is 30%. A higher percentage of Pre-1945 build dwellings, compared to post 1945 build fail to meet the standard for energy efficiency (40% to 27%); more houses, compared to flats fail to meet it (36% to 15%), and the Private Rent (46%) stock has the highest percentage of dwellings which fail to meet the standard, followed by Owner-occupied (34%), and Social Housing (14%). For comparison, the Scotland Average figures are fairly similar in terms of the ages of dwellings (34% Pre-1945 build, and 29% post 1945); the percentage of flats nationally which fail to meet the energy efficiency standard is higher than that for the PKC Area (15% versus 26%), and in terms of tenure types, the percentage of Private Rent stock across Scotland is also higher than the other tenures, at 35%, but lower than the PKC Area figure. As too is the Owner-occupied figure at 31% compared to 34% within the PKC Area. However, the Social Housing figure for Scotland is 27% compared to the PKC Area figure of 14%. 1 The SHQS is a common standard for assessing the condition of Scotland’s social sector housing. However, the SHQS collects data on all tenures. Detailed breakdown SHCS for the PKC Area: • Total number of households in the PKC Area: 68,000 (Scotland figure: 2,479,000) • % of dwellings built pre-1945: 35% PKC Area; 30% Scotland Average. • % of dwellings built post 1945: 65% PKC Area; 70% Scotland Average. • % breakdown of dwellings by tenure type: o PKC Area – 67% Owner-occupied; 20% Social Housing, and 14% Private Rent. o Scotland Average - 62% Owner-occupied; 26% Social Housing, and 13% Private Rent. • % of Households with a Long-Term Sick or Disabled Resident who is Restricted by the Dwelling: PKC Area - 4%; Scotland Average - 7%. • % of dwellings reported as requiring adaptations: PKC Area – 2%; Scotland Average – 3%. • % breakdown of dwellings with adaptations for limited mobility by tenure type: o PKC Area – 22% Owner-occupied; 37% Social Housing, and no figure reported for Private Rent as the sample size was too small to report. o Scotland Average – 17% Owner-occupied; 33% Social Housing, and 15% Private Rent. • % breakdown of dwellings with adaptations for limited mobility by age profile: o PKC Area – 22% overall stock; 13% Pre-1945 build, and 27% post 1945 build. o Scotland Average – 21% overall stock; 17% Pre-1945 build, and 22% post 1945 build. • % breakdown of dwellings off the gas grid by tenure type:
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o PKC Area - 31% overall stock; 36% Owner-occupied; 6% Social Housing, and 42% Private Rent. o Scotland Average - 17% overall stock; 20% Owner-occupied; 10% Social Housing, and 17% Private Rent. • % breakdown of dwellings with Full Central Heating (by Tenure Type): o PKC Area – 91% overall stock; 89% Owner-occupied; 98% Social Housing, and 89% Private Rent. o Scotland Average - 96% overall stock; 96% Owner-occupied; 98% Social Housing, and 91% Private Rent. • % of Dwellings with a Low Energy Efficiency Rating of F or G (SAP 2009): o PKC Area – 4% of overall stock. o Scotland Average – 3% of overall stock. • % of dwellings with a Low Energy Efficiency Rating of F or G (SAP 2012, Running Costs): o PKC Area – 8% o Scotland Average – 4% • % of dwellings with a High Energy Efficiency Rating of B or C (SAP 2012, Running Costs): o PKC Area – 34% o Scotland Average – 45% • % of dwellings with a Low Environmental Impact Rating of F or G (SAP, 2012): o PKC Area – 20% o Scotland Average – 9% • % of dwellings with a High Environmental Impact Rating of A, B or C (SAP, 2012): o PKC Area – 26% o Scotland Average – 34% • Total number and % share of households fuel poor: o PKC Area - 17,000 in total; 25% of overall stock; 25% Older households; 20% Families, and 27% Other households. o Scotland Average - 605,000 in total; 24% of overall stock; 27% Older households; 17% Families, and 27% Other households. • Total number and % share of households in extreme fuel poverty by dwelling characteristics: o PKC Area - 12,000 in total; 18% of overall; 26% Pre-1945 build, and 13% post 1945 build. o Scotland Average – 294,000 in total; 12% of overall; 16% Pre- 1945 build, and 10% post 1945 build. • Total number and % share of households in extreme fuel poverty by household attributes: o PKC Area – 13% Owner-occupied; 25% Social Housing; 31% Private Rent; 19% Older households; 6% Families, and 22% Other households. o Scotland Average – 9% Owner-occupied; 14% Social Housing; 22% private Rent; 14% Older households; 5% Families, and 14% Other households. • % of dwellings considered to be Below the Tolerable Standards (BTS): o PKC Area – 2% o Scotland Average – 2% • % of dwellings which are overcrowded (below Bedroom Standard): o PKC Area – 1% o Scotland Average – 2% • % of dwellings which are under-occupied (exceed the Bedroom Standard by 2 or more Bedrooms): o PKC Area – 41% o Scotland Average – 32% • % of dwellings which are fail the SQHS overall:
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o PKC Area – 37% overall; 47% Pre-1945 build; 32% post 1945 build; 39% House; 31% Flat; 38% Owner-occupied; 21% Social Housing, and 56% Private Rent. o Scotland Average – 41% overall; 52% Pre-1945 build; 37% post 1945 build; 39% House; 45% Flat; 37% Owner-occupied; 41% Social Housing, and 35% Private Rent. • % of dwellings which are fail the SQHS overall by household type: o PKC Area – 37% Older households; 41% Families, and 35% Other households. o Scotland Average – 42% Older households; 37% Families, and 43% other households. • % of dwellings which are fail the SQHS “Energy Efficiency” Criterion by dwelling characteristics and tenure type: o PKC Area – 32% of overall stock; 40% Pre-1945 build; 27% post 1945 build; 36% House; 15% Flat; 34% Owner-occupied; 14% Social Housing, and 46% Private Rent. o Scotland Average – 30% of overall stock; 34% Pre-1945 build; 29% post 1945 build; 33% House; 26% Flat; 31% Owner- occupied; 27% Social Housing, and 35% Private Rent. • % of dwellings which are fail the SQHS “Energy Efficiency” Criterion by household type: o PKC Area – 32% Older households; 33% Families, and 30% Other households. o Scotland Average – 32% Older households; 29% Families, and 30% Other households. 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
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mitigate the social, environmental, and economic challenges towns across Scotland are facing. In total, five charettes were undertaken for Aberfeldy, Auchterarder, Bridgend, Blairgowrie, and Crieff. Perth and Kinross Community Plan (Local Outcomes Improvement Plan) 2022-32 The Perth and Kinross Community Plan was approved by the Perth and Kinross Community Planning Partnership in September 2022. It contains an ambition for the area to ‘be the best place in Scotland for everyone to live life well, free from poverty and inequality.’ The Plan sets out 5 Strategic Priorities for the area, which are: 1. Reducing Poverty (child, food, and fuel) 2. Physical and Mental Wellbeing (evidence shows a major increase in demand for mental health wellbeing support post Covid-19) 3. Digital Participation (issues of connectivity, technology and individual capacity identified across the area) 4. Learning and Development (supporting individuals and communities to build their skills, confidence, and resilience) 5. Employability – (an enhanced focus on upskilling for those seeking employment and supporting young people in a fast-changing job market, enabling people to enter, sustain and progress in work.) The Community Plan also provides a summary profile for the area of data and trends linked to those Strategic Priorities. This helps build a stronger picture of the key characteristics and challenges of the Area which the Council, along with our Community Planning Partners are seeking to address through a number of area-wide actions. These actions have all been linked to relevant National and Local Outcomes too. Perth and Kinross Area - Local Action Plans There are 5 Local Action Plans (LAP) covering the 7 localities within the Perth and Kinross Area. Each LAP contains a profile of the locality/localities; information on the relevant Community Action Partnerships; data and information on the Key Inequalities for the area under the themes of: SIMD, Child Poverty, Crime, Income, Employment, Housing, Health and Wellbeing, Fairness Commission key themes, and lessons learned so far, and a list of Key Issues Identified, with accompanying statements on ‘What needs to change’ and the actions required to bring about those changes, when and by whom. Community Action Plans (CAPs) 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 provide an insight into a community’s views about their area at the time of producing the Plan i.e. their likes and dislikes; their vision for the future of their area; those issues which matter most to the community, and priorities for projects and action needed to enhance a place over the period of the CAP and beyond. Perth and Kinross Council Ward Profiles In 2022 the Council collated ‘Ward Profiles’ for each of the 12 Council Ward Areas. The information for each area has been divided into main topics which are: population, economy, housing, education, physical
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environment. Information has also been included on local deprivation based on the Scottish Index of Multiple Deprivation (SIMD), where it is relevant to a local area.
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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 14. LDP Spatial Strategies The Scottish Government and COSLA’s Place Principle (2019) Applying the Place Principle in the development of our LDP3 means that we need to work collaboratively at all stages with key stakeholders, including key agencies, our communities, landowners, and developers to ensure our Spatial Strategy is coordinated, fit for purpose, and deliverable. Scottish Government, Creating Places: A Policy Statement on Architecture and Place (June 2013), and Designing Streets: A Policy Statement for Scotland (March 2010) Creating Places outlines the Scottish Government’s aspirations for design and making places and highlights the benefits good design and high quality places bring to not just individuals and society, but also to the country as a whole. Designing Streets advocates a place-based response to designing streets, which seeks to deliver the six qualities of a successful place. Both policy statements emphasise the need for a multi-disciplinary approach to delivering high quality places, in collaboration with communities. Our Placemaking Guide Supplementary Guidance was developed based on both policy statements. The continued application of our Guide (with any updates to reflect changes at a national level), particularly through the Settlement Audit and Site Appraisal stages for our Proposed Plan, as well as working with our key stakeholders, and engaging with our communities about the future of their places throughout the LDP3 preparation process, will help to implement the key principles and policies contained within both policy statements to deliver high quality, successful places. Perth and Kinross Local Development Plan 2 (2019) It is important to recognise when starting a Local Development Plan review 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. In addition, its accompanying supplementary guidance, particularly on placemaking and our various Conservation Area Appraisals, provide a good basis of understanding of the local context and characteristics of the area, and what constitutes high quality successful places within the context of Perth and Kinross.
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NPF4: Annex D – Six Qualities of Successful Places Applying these six qualities in the development of the Plan’s Spatial Strategy, particularly the allocation of proposals in LDP3 should help to foster healthy, pleasant, connected, distinctive, sustainable, and adaptable places. Bringing these qualities through in the LDP’s Settlement Audit and Site Appraisal templates should ensure all elements are given the appropriate level of consideration prior to any site proposals being allocated in the Plan. When thinking about how connected our places are i.e. in terms of access to, from, and within, to destination locations, facilities and services, it is important that we are also mindful of the barriers our communities can face in accessing sustainable modes of transport when we are identifying proposals for future development as part of our LDP3 Spatial Strategy. It is suggested that these barriers might best be considered through the SEA for our LDP3 under the ‘Population and Human Health’ topics, and solutions may also be found through our work on identifying local living and 20 minute neighbourhoods. Transport Scotland, Sustrans and SCOTS, Cycling by Design 2021 An important piece of design guidance to help integrate cycling infrastructure on all roads, streets and paths to create holistic and attractive environments which encourage a wider range of people to take up cycling regardless of age or ability. In developing our LDP3 Spatial Strategy and thinking about connections to, within and from our site proposals, it will be important to incorporate and seek the implementation of the key messages, design principles and requirements set out in ‘Cycling by Design’ through the delivery of development proposals (site-specific requirements). This will contribute towards the achievement of the Scottish Government’s Six Qualities of Successful Places. There are key connections, in particular, between delivery of high-quality cycling infrastructure and our LDP3 Spatial Strategy work on tackling the climate and nature crises, climate mitigation and adaptation, sustainable transport, identifying local living and 20 minute neighbourhoods, infrastructure first, and protecting and enhancing blue and green infrastructure and their networks under NPF4 policies 1, 2, 13, 15, 18, and 20. Scottish Government, PAN 83: Master Planning (2008) An important advice note which sets out the benefits of using masterplanning to help raise design standards and create high quality places, which can also contribute towards achieving the Six Qualities of Successful Places via the LDP3 Spatial Strategy. The PAN identifies types or sites and circumstances where the development of a masterplan is most likely to be appropriate. In developing our LDP3 Spatial Strategy we will consider which locations, sites or groups of sites might benefit from the production of a masterplan and will identify this in the Proposed Plan via the site-specific requirements for those proposals. Perth and Kinross Placemaking Guide Supplementary Guidance (2020) The Council’s Placemaking Guide is still very relevant. Its continued use, particularly during the Site Appraisal stage for the Proposed Plan, will help to ensure the Scottish Government’s Six Qualities of Successful Places are realised on the ground across Perth and Kinross, and that these qualities are framed within a local context.
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Gaps, Uncertainties or Key Issues Raised: The guidance remains relevant, but will require a review and some minor updates, to ensure the references contained within it and the terminology used are in line with NPF4, to allow its future use alongside LDP3. Perth and Kinross Consultation Draft Mobility Strategy (2024), and Perth and Kinross Mobility Strategy Draft Action Plan (2024) The Council’s vision for managing and developing the transport and network access across the area, as set out in the Draft Mobility Strategy, should be carried through into our Proposed Plan. Any detailed projects, proposals and actions contained within the Draft Action Plan should also be reflected in LDP3’s Spatial Strategy to support their delivery. Gaps, Uncertainties or Key Issues Raised: Consultation on both the Draft Mobility Strategy and associated Action Plan closed on 28 July 2024. Any amendments to those documents because of comments received through the consultation process should be reflected in our Proposed Plan. Scottish Household Survey (SHS) The SHS is useful in providing us with a picture of how residents of Perth and Kinross feel or perceive different aspects of their neighbourhoods and communities, which will help with developing some aspects of the Spatial Strategy, particularly around creating safe and inclusive places. The 2022 results tell us that typically the majority of residents are happy with their neighbourhoods as a good place to live. However, some perceived there to be, or they have experienced problems within their neighbourhoods, mostly linked to issues that are not within the influence of the land use planning system, e.g., littering and animal related noise, neighbour disputes, rowdy behaviour etc., with the results all being quite similar to the Scotland average for these answers. Overall, a large percentage of participants indicated that they felt like they belong to a community, which is a good representation of the feeling of community experienced across the area. The majority of both males and females, disabled and non-disabled persons, met socially with others at least once per week or more, with the figures mirroring the Scotland averages also. The reported feeling of loneliness across the participants group was quite low, which is very positive considering the rural nature of large parts of the Council Area. In terms of perception of safety when walking alone after dark, a higher percentage of males over females felt very or fairly safe, and a higher percentage of females than males felt very or a bit unsafe. Overall, the majority of participants felt reasonably safe. It is important that the development of our LDP3 Spatial Strategy follows the six qualities of successful places, and that we keep engaging with communities to build on our understanding of their views on their places, so that Perth and Kinross continues to rank highly and that further improvements can be made across the Area. Understanding Our Local Places Place Standard Engagement Tool and 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
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inform the development of the LDP3 Spatial Strategy following a place- based approach, particularly through our Settlement Audit work, but also other Council plans and strategies, such as our Local Transport Strategy – The Mobility Strategy. Scottish Index of Multiple Deprivation (2020) It is important to understand in developing the Plan’s Spatial Strategy where the most vulnerable people and places are across Perth and Kinross, to ensure that we don’t exacerbate existing problems, but rather can help bring about improvements to these places, in a coordinated manner, with input from those affected communities, for the people who live and work there, and also visit them. This will help support Sustainable Development and a Just Transition. The SEA for the Plan will be an important piece of work in developing a Spatial Strategy which aims to deliver these outcomes. Scottish Government, Scottish House Condition Survey: Local Authority Analysis 2017-2019 (February 2021) The Scottish House Condition Survey (SHCS) Local Authority Analysis provides a useful overview of the profile of the housing stock within the Perth and Kinross Council Area and allows comparisons with the national average figures. The SHCS was considered as part of the development of the Perth and Kinross Council Local Housing Strategy (LHS) and LHS Action Plan 2022-2027, which were approved in 2022, and actions were identified via the LHS process in order to help improve levels across the area. The LHS sets out the Council’s priorities and plans for the delivery of housing and related services for the period 2022-2027. The LHS, and its implications for the development of the Proposed Plan, are considered in more detail under the ‘Homes’ issue for this Evidence Report. The LHS was co-produced with community and housing partners, residents and other stakeholders, and impact assessments were also undertaken before its finalisation, to consider the actions from the perspective of equality and fairness; sustainability and climate change, and health and wellbeing. Four main priorities identified under the LHS, to meet the Council’s vision that “Everyone in Perth and Kinross has access to the right home, in the right place, at the right cost.” Those priorities are: 1. Provide more affordable homes to support liveable and sustainable communities – Setting a strategic vision for housing, based on evidence of local need, for providing the right size and type of housing in sustainable, well-connected places. 2. Provide a range of housing options that people can easily access, afford and keep – Improving choice across all types of housing, contributing to tackling child poverty and further developing the Council’s Rapid Rehousing Transition Plan (RRTP), building on our Home First model. 3. Deliver more homes for people with varying needs – Providing more accessible homes, wheelchair homes and supported accommodation to enable people to live independently and well for as long as possible. This will be done through investment in property adaptations, technology, and care and support services. 4. Deliver quality homes with affordable warmth, zero emissions and SMART technology – Improving the quality and energy efficiency of all types of homes, tackling fuel poverty through investment in properties, and setting a road map for reducing domestic carbon emissions.
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Although the LHS Action Plan contains a number of actions under the four priorities which have specifically been identified for delivery via the Development Plan, the majority of the actions within it will more appropriately be delivered through a collaborative approach across different stakeholders (primarily in the housing and property sectors) not all of which are within the remit of land use planning. However, LDP3 can bring together the range of actions, proposals and priorities which have a spatial element to help facilitate their delivery in a coordinated and holistic place-based manner. Those actions in the LHS Action Plan of specific relevance to the development of our LDP3 include: maximising the potential to generate more homes through brownfield regeneration; developing clear definitions of lifetime 20 minute neighbourhoods to support partners, stakeholders and investors to pursue placemaking which improves connectivity (physical, social, and digital infrastructure); identifying opportunities for and adopting a masterplanning approach to effective land supply, and ensuring planning policy, placemaking and housing investment programmes contribute to improved and sustainable homes, outdoor space, health, and wellbeing for all households. The LHS and LHS Action Plan provide the vision and strategy for the future of housing within the Perth and Kinross Council Area up to 2027. Through including the priorities and spatial elements of those documents in the development and implementation of our LDP3, alongside the application of the Place Principle, the Scottish Government’s design policy statements, the Six Qualities of Successful Places, the Council’s Placemaking Supplementary Guidance, and NPF4’s policies and Spatial Principles, our Spatial Strategy will contribute to tackling those issues in the profile of the area’s housing stock identified through the Scottish Household Condition Survey: Local Authority Analysis 2017-2019, but within the parameters of the land use planning system. Gaps, Uncertainties or Key Issues Raised: The survey merges three years’ worth of data (2017-2019) to achieve sufficient sample sizes and the survey analysis reports on the average figures for the three-year period. Whilst it is a useful dataset, it has already been used to develop the Council’s Local Housing Strategy and Action Plan, and as such the incorporation of the relevant priorities and spatial elements identified in those documents would be most appropriate to the development of the Proposed Plan. Perth and Kinross LDP2 Design Charettes 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 will 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 when they were produced, any data or statistics contained within the Design Charettes, which has since been updated, should be reviewed as part of the LDP3 Settlement Audit work. The Audit should also consider if progress has been made against the key issues and actions identified in the charettes,
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and how those issues and actions compare to the feedback gathered through the Big Place Conversation. Perth and Kinross Community Plan (Local Outcomes Improvement Plan) 2022-32 Although there are no specific actions attributed to the Local Development Plan in the Community Plan, there are actions which LDP3 and the land use planning system can help support the coordinated delivery of, such as: enhancing sustainable and active travel connections via new developments; improving the quality and provision of green and blue infrastructure (including open spaces, community allotments, natural water management solutions etc.); identifying housing and employment land in sustainable locations, and facilitating the delivery of quality energy efficient homes in a range of tenures. These actions will be addressed through the development of our Proposed Plan for LDP3 in alignment with National Planning Framework 4. Perth and Kinross Area - Local Action Plans The Local Action Plans contain important profiles of our localities across Perth and Kinross, particularly around their ‘Key Inequalities’. Gaps, Uncertainties or Key Issues Raised: However, as the LAPs were all published in 2017 the statistical data reported within them are not the most recent available data. The list of ‘key Issues Identified’ and ‘What needs to change’ accompanying statements contained within the LAPs will be reviewed as part of our LDP3 Settlement Audit exercise but will be viewed taking account of relevant up-to-date data and information. Community Action Plans Our community led Community Action Plans provide an important source of information about our places, what they offer, and the key priorities and aspirations of our communities for the future of their places. It is important that key considerations contained in these CAPs are taken account of in the development of the Spatial Strategy, primarily through the Settlement Audit exercise, to help encourage, promote, and facilitate development via our LDP3 which reflects the vision, aspirations and priorities of our communities. Perth and Kinross Council Ward Profiles These profiles provide useful information and data about the 12 Council Ward Areas which will be helpful, with updated data, as part of our LDP3 Settlement Audit exercise to inform the development of our place-based Spatial Strategy. Gaps, Uncertainties or Key Issues Raised: The Ward Profiles contain some data and information which is now out of date. As part of the Settlement Audit exercise for developing the Proposed Plan, they should be viewed in the light of the most up-to-date information available for the key characteristics and challenges for those places. Overview of the Implications for the Proposed Plan from the Community Plan, Local Action Plans, Community Action Plans, and Ward Profiles These Community Planning documents and profiles provide an important source of information about our places, not only relating to their key socio- economic characteristics, but also an understanding of the issues and challenges faced by our communities, and their aspirations for the future of their places. It is incredibly important that these characteristics, along
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with relevant environmental, physical, cultural, and built heritage characteristics identified are taken account of in the development of the Spatial Strategy for LDP3, to help deliver sustainable, well designed, and high-quality places. We will engage with our Community Planning Partners and the communities of Perth and Kinross through the development of our Proposed Plan to ensure that the key messages and considerations coming out of these documents and profiles remain relevant and are reflected in our LDP3 Proposed Plan.
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Summary of Stakeholder Engagement: Perth and Kinross LDP3 Big Place Conversation The Council carried out its ‘Big Place Conversation’ (BPC) exercise to kick start the LDP3 process across Perth and Kinross communities during most of 2023. 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. There were also targeted sessions held with schools, service user groups, and minority groups. The results of the BPC have been collated to produce a separate report on the outcomes and findings across the different locality areas, as well as an overview of results for the Council Area as a whole. A full summary of the results of the exercise, and the place-based actions to be taken forward as part of the development of the Proposed Plan, are also provided as part of this Evidence Report, under the statement of steps taken by the Council in preparing the report to seek the views of various stakeholders, as prescribed by the Planning (Scotland) Act 2019. Figures B1(5) to (7) show some of the outcomes of our conversations in some sample locations using the Place Standard Tool, and Figure B1(8) the overall average scores for the Perth and Kinross Area. Several of the key points raised that are relevant to the ‘Design, Quality and Place’ issue have been provided under their related themes to follow. Figure B1(5): Place Standard Wheel for Bertha Park High School Session Figure B1(6): Place Standard Wheel for Birnam and Dunkeld Session Figure B1(7): Place Standard Wheel for Kinross-shire Bertha Park High School
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Figure B1(8): Place Standard Wheel for the Perth and Kinross Council Area Due to the design and purpose of the tool, most of the Place Standard themes and their questions are relevant to the Design, Quality and Place issue of this Evidence Report. The overall summary of the results for those themes for the Perth and Kinross Area which are relevant to this issue tell us that: 1. Moving Around scored an average of 3.6 out of 7. Concerns were primarily raised regarding: • The condition of footpaths and how that can impact on accessibility. • The presence of street furniture and lighting columns which can further restrict access on already narrow footways. • A lack of formal crossing points, especially on busy roads. • The need to install traffic calming measures. • settlements often lacking a cohesive, well-connected path network to support greater uptake of walking and cycling between destinations. • The need for stronger active travel plans to account for out of town housing developments. • Overgrown vegetation encroaching on the public realm and restricting access and visibility. 2. Traffic and Parking scored an average of 2.9 out of 7. Participants concerns were expressed around: • Difficult interactions between road traffic and parked vehicles, limiting access for emergency and larger vehicles. • Traffic volumes creating unwelcoming environments for people to enjoy public spaces in towns and villages. • Insufficient car parking, particularly in settlements which have seen significant growth in recent years. • The influx of tourists and visitors to natural spaces and key attractions which can impact negatively on local areas.
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Some suggested solutions included an increase in the number of Park and Ride or Park and Choose sites; better signposting to public car parks to ease congestion; reduced speed limits (20MPH for all settlements), and the development of bypass routes to reduce traffic through local streets. 3. Natural Spaces scored an average of 5.1 out of 7. Key points raised included: • Participants felt well connected to nature in their place, and that existing high-quality greenspaces enhance access to nature within urban areas. • The active role of local volunteer groups in managing and improving natural spaces and contributing to conservation and biodiversity enhancement efforts was recognised. • Limited parking near to natural spaces was highlighted as something that restricts access to them, as was poor path conditions for those with reduced mobility/mobility impairments. • Noise pollution from traffic was also thought to detract from the enjoyment of natural spaces. • Certain neighbourhoods were viewed as lacking in adequate urban greenspaces due to issues of poor provision, accessibility, connectivity and/or quality. • The path network was identified as being fragmented in places, with missing links between key locations. • The cumulative impact of new development and land management practices on ecosystem health was highlighted as a concern, as too was the loss of greenfield sites (including those in the greenbelt and open spaces) to new development. • Insufficient seating, sheltered areas, and litter bin provision in natural spaces and along paths linking to them was also raised as an issue. Some of the suggested solutions from participants included: • Safeguarding the environment through effective policies such as protecting greenbelt land, promoting brownfield regeneration, and increasing open space designations in the LDP. • Enhancing biodiversity and naturalness in both urban and rural areas through tree planting, conservation initiatives, and well design blue and green infrastructure. • Improving the overall quality and connectedness of the path network, linking settlements with natural spaces. • Ensuring new developments contribute to creating or enhancing greenspaces and path network linkages. • Promoting natural attractions and path networks more effectively. • Increasing opportunities around prominent natural assets e.g. the River Tay. • Encouraging the collaborative management of parks and nature- rich sites with communities. • Increasing parking provision at key natural sites. • Increasing opportunities for community growing, such as orchards, allotments and gardens, and providing more seating and sheltered areas and litter bins. 4. Play and Recreation scored an average of 3.9 out of 7. Overall, there was a lot of positive feedback across the area regarding the level and variety of formal and informal indoor and outdoor play, leisure and sport opportunities, particularly in larger settlements. However, it was felt that: • Children and older adults have the most opportunities, and that the spaces and activities on offer to girls, older children and young people (age 12+) and people with disabilities are insufficient. • Existing play spaces and parks were also considered to lack a variety of exciting and challenging equipment for the 12+ age group and can generate significant concerns amongst children related to anti-social behaviour taking place at them.
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• A limited number of facilities (particularly indoor) and organised activities in rural areas meant that people need to travel by car to access formal opportunities, and issues with active travel and public transport further hinder accessibility. • The hiring of venues and participating in activities can be cost- prohibitive, and many facilities are viewed as being outdated or in poor condition, requiring maintenance and upgrades. • Issues were also raised concerning the loss of informal play and recreation spaces to “No Mow” grassland management approach, and new play provision provided through development either being insufficient or delayed until later project phases. • The key role local volunteer groups play in supporting a variety of opportunities for all age groups was recognised. Some suggested solutions by participants included: • The upgrading of parks to offer a more diverse range of free activities, including picnic areas, exercise equipment, and informal gaming. • The creation of more challenging and varied play opportunities for all groups and users, such as skate parks, pump tracks, bridal trails and mountain bike trails. • Better segregation between play areas and parks for children and young people. • Enhancements to the active travel network to improve access to facilities and more opportunities for recreational walking and wheeling. • Improving public transport connections to key facilities. • Improving accessibility and making better use of existing indoor venues, like church and village halls and schools. • Development of more adaptable multi-use facilities (both indoor and outdoor). • Creation of central online platform for sharing information about groups, activities and events. 5. Facilities and Services scored an average of 4.1 out of 7 in relation to how people view their places are like for accessing services they need. Feedback received presented mixed opinions as to whether local shops and services in rural areas met people’s needs, and whilst some areas were content with existing provisions, others noted travel was necessary to access shops and services. Many rural areas noted the value of mobile services, like mobile libraries, and most areas were able to access facilities and services needed at central hubs, such as nearby towns, and Perth or Dundee. Every area mentioned the need to travel to Perth City Centre for retail and key services that are not available locally, and limited access to healthcare facilities such as GPs and dental services were mentioned in nearly every area. Many communities highlighted poor digital connectivity (both for broadband and mobile), and that primary and secondary education provision required enhancement in some but not all areas. Some of the suggested solutions were the development of rural hubs to deliver essential services or develop more facilities to accommodate growth. Improvement to mobile broadband was also suggested in some areas. 6. Work and Local Economy scored an average of 3.7 out of 7 across the Council Area. Some areas felt that there is a good range of employment opportunities, including part time and local opportunities. However, nearly every area commented on the need to commute to work, and that local jobs can be limited in roles, with those in professional jobs having to travel. Other key points raised included: • Significantly a lack of variety of work opportunities was highlighted in villages and in Perth neighbourhoods. • Many areas mentioned that the local economy is dominated by a few sectors (e.g. tourism, agriculture, and retail), and some areas highlighted that access to workplaces, especially in the evening, is adversely affected by transport issues – this was raised in Perth City neighbourhoods as well as in rural areas.
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• A few areas commented that poor access to Further and Higher Education was an issue which undermines local economic growth. • Some areas also mentioned a shortage of housing which undermines economic growth. Some of the suggested solutions by participants included the provision of more support for small businesses, including affordable premises; improving the promotion of the tourism sector; simplification of planning processes to make better use of existing spaces for a mix of uses; better transport connections to major centres; the development of remote work hubs with improved digital connectivity, and improved range and quality of housing to allow people to live in the same area in which they work. 7. Housing and Community scored an average of 4.1 out of 7. Most of the conversations for this theme centred around the limited availability of different types of housing to meet local needs in certain areas, with a range of impacts on communities, including the ability to recruit and retain workers; loss of young people; affordability, particularly in more rural areas and where short term lets and holiday/second homes levels are higher, and issues with the older housing stock in terms of maintenance and energy efficiency. Some areas commented that new housing development was impacted on the character of local areas and their infrastructure, and in certain communities, it was felt that historic sites need reviewed. Suggestions put forward by participants, of relevance to the Design, Quality and Place issue included – more provision of a variety of housing types to meet the needs of communities; better integration of affordable/social housing into new developments; improvements to infrastructure needed as part of new developments; find a balance between providing new housing and protecting the character of an area e.g. considering local vernacular; prioritise brownfield development and protect the greenbelt, and reuse and repurpose existing buildings to create housing. 8. Social Interaction scored an average of 4.2 out of 7 across the Council Area. There was evidence that there are good opportunities across the area for social interaction, whether that’s at indoor or outdoor locations, and active community groups and sports clubs, as well as organised events and activities etc. helped to support interactions. However, participants did highlight that there are a lack of opportunities for disabled people and young people for meeting in most areas, and in general in rural areas and smaller settlements there are fewer venues to facilitate meeting up. Other concerns raised included: • The experience isolation in some communities. • A lack of public transport preventing social interaction. • The underutilisation of some public buildings, and some public spaces not being well maintained. • Limited free and inclusive spaces for all age groups. • High costs for booking venues, including PKC managed ones. • A need to travel to larger settlements for socialising and activities, and the impact on community life as a result of tourists/tourism. Some of the suggested solutions included – the need for more informal recreational spaces/ places which include outdoor seating/shelters; more free, accessible spaces (with heating and Wi- Fi) to help improve social interaction; better opportunities for young people, including additional places and improved spaces; the modernising of spaces to create community hubs; delivery of community spaces through new developments, and promoting and encouraging more local businesses. 9. Identity and Belonging scored an average of 4.9 out of 7. Whilst a strong sense of community came across in most places, and people feel proud of their place overall, it was felt that community cohesion could be improved in some areas, particularly to welcome new residents, and some areas felt that their identity has been eroded over time, especially with the growth of towns and villages.
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Participants suggested solutions, which included – more local events and celebrations to help promote identity; greater access to and promotion of local heritage to foster pride; improvements to the care and maintenance of some areas to help support identity and belonging, and some felt that more is needed to engage young people. 10. Feeling Safe scored an average of 4.8 out of 7. Most people generally feel safe in their place, and it was highlighted that community spirit contributes towards the feeling of safety. Safety issues in general relate to specific trouble spots, rather than being an overall concern for the whole Council Area. However, not everyone feels safe because of anti-social behaviour, and young people raised more concerns about safety, particularly at night. Other concerns regarding safety included – the use by teenagers of spaces meant for young children; flooding and flood risk; traffic speeds and volume; feeling unsafe walking and cycling on roads and at some crossing places, and vacant and derelict buildings. Suggestions to improve the overall feeling of safety put forward by participants included creating options for young people to reduce the likelihood of anti-social behaviour; improved lighting in some places, including the use of solar powered options where possible (paths, sometimes parks and bus stops are poorly lit); improved drainage and flood protection, and improvements to the appearance of and stronger enforcement around key buildings and land, including the reuse of vacant and derelict properties. 11. Care and Maintenance scored an average of 3.8 out of 7. BPC participants were asked if there are spaces or buildings that need cleaning up or fixing in their area. Feedback was that ‘In Bloom’ groups and other volunteers do a great job, and some local communities take pride in their place organising litter picks and the maintenance of public spaces. • Overall parks and public spaces were thought to be generally well maintained, but the ‘No Mow’ grassland management approach changes resulted in spaces being viewed as unkempt/poorly maintained. • Condition issues were noted for roads, pavements, paths, and to a lesser extent signage and bridges, and the encroachment of vegetation onto paths and walking/cycling routes was highlighted as an issue. • Playparks and sporting equipment was identified as requiring better upkeep, and some historic buildings were noted as needing better maintenance. • An increase in fly tipping, graffiti, litter (particularly on roads from passing cars and in natural spaces) and dog-fouling were flagged, and the need for more bins, and the more frequent emptying of bins in certain locations. • Invasive species, like Japanese Knotweed were identified as requiring close monitoring, and the addressing of blocked drains and farmland/hillside run off was also raised in relation to the exacerbation of flooding issues. • Impacts from wild camping and the lack of public toilets were also raised. Suggested solutions from our local communities included – improved funding for local groups; better and more collaboration between the Council and community groups; more public toilet provision; improved vegetation maintenance in summer months; improvements to shop frontages; a coordinated approach to town centre management; stronger enforcement of building maintenance requirements; redevelopment of key vacant and derelict sites; improved street cleaning and litter picking; improved drainage and flood protection; designated spaces for young people to practice street art; improved facilities for campervans and tourists, and wild camping byelaws. Perth and Kinross LDP3 Evidence Report Topic Papers
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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 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. The comments received on Topic Paper 018: Design, Quality and Place, 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. Perth and Kinross Council’s Tay Forest National Park Bid and Consultation Analysis report As highlighted under other issues in this Evidence Report, consultation events were carried out as part of the development of the Council’s Tay Forest National Park bid during October to December 2023. 162 people attended the drop-in events in Dunkeld, Pitlochry, Comrie, Aberfeldy and Crieff, and there were also online surveys, webinars, targeted workshops and an in-person questions and answers session. The Consultation Analysis Report was produced by LUC. Of most relevance to the Design, Quality and Place issue of this Evidence Report, the key points raised included: • Top 5 ‘Special Qualities’ of the area were identified as - trees and woodland, nature and wildlife, lochs/rives, scenery and distinctive landscapes, and recreational opportunities. People and communities, the historic environment and heritage features, and productive agricultural land also scored highly. • The main areas for improvement were highlighted as – enhancing and restoring biodiversity; sustainable transport provision to and around the area; enhancing the tourism offer and managing visitor impacts; reducing carbon emissions and adapting to the effects of climate change; community development (housing, services and infrastructure), and encouraging business investment and creating jobs. • Access, Recreation and Infrastructure improvements which could benefit both local people and tourists include – improved path maintenance, including a focus on prevention of footpath erosion, improved wayfinding, and better surfacing for a range of users; enhanced outdoor activities; additional parking provision (inc; more visitor facilities (e.g. public toilets, waymarked paths, play spaces etc.), and potential for off-road overnight parking for motorhomes. • Support for improving the energy efficiency of local businesses and also improvements to individual homes/building stock. • Improved safety and conditions of roads and paths for cyclists and pedestrians to encourage active travel. • Develop and join routes through hills and drove roads, enhancing green travel options across the area.
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• Provision of new community facilities to reduce the need to travel to meet needs. • Delivery of high-speed broadband to support local businesses and homes. • Development of community heating systems. • Regeneration of town centres. • Preserving the beauty of local landscapes and cultural heritage. • Importance of local heritage assets, with opportunities to protect them for the benefit of local people and sensitively promote the area to those who will enjoy and appreciate it. How the views expressed have been taken account of in the Evidence Report? The Big Place Consultation 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. The biggest overall concern for our communities was around the theme of Traffic and Parking, and how related issues can cause difficulty for pedestrians, cyclists and other road users. It was also felt that high traffic volumes, coupled with a lack of adequate car parking can detract from the look, feel and enjoyment of many of our places, particularly natural spaces. The need to strike a balance between the benefits of tourists and tourism, including those who visit our natural spaces for recreation and leisure, and the knock-on impacts that can have on local communities is also an important concern which has been considered in more detail under the Tourism issue of this Evidence Report. The Moving Around, Work and Local Economy, Care and Maintenance, and Play and Recreation overall scored quite similarly for the Council Area. It is considered that those issues raised by communities and potential solutions suggested would be most appropriately looked at in more detail through our Settlement Audit exercise to ensure our LDP3 Spatial Strategy reflects not only the needs and concerns of individual local communities, but that any specific solutions identified through the Plan have been developed taking account of all relevant policy areas and potential new site proposals, to deliver multiple benefits for our people, places and nature. Whilst the Tay Forest National Park bid was not successful, the consultation and engagement carried out to inform it provides us with a greater insight into not only the concerns and priorities of the people who live and work there, but also the qualities of the area which they value the most, and the improvements they would like to see. Reflecting on the outcomes of both the Big Place Conversation and National Park bid, we can see common themes coming through across Perth and Kinross, particularly around transport and travel (including active travel); striking a balance between tourism and quality of life for local communities; a greater choice of more efficient and affordable housing, particularly in more rural areas where short term lets and holiday/second homes is a concern; a wider range of business, services and employment opportunities which are not concentrated in the main population centres; protecting and enhancing
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the character and special qualities of our places which make them unique; enhancing biodiversity; mitigating against and adapting to the impacts of climate change, and improved infrastructure, whether that is to encourage more walking and wheeling, improving access to high-speed broadband and public transport services, more play and recreation opportunities for different age groups which are inclusive (both indoor and outdoor), and greater infrastructure provision to accommodate tourists. Each of these issues are linked to national planning policies in NPF4 and have been considered in turn under the relevant issues of this Evidence Report in terms of relevant sources of evidence and the likely implications of that evidence to the development of our Proposed LDP3.
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Statements of Agreement/ Dispute: 14 responses were received on our Design, Quality and Place Topic Paper. Most respondents (12 out of 14) either agreed with or had no comment to make on the evidence identified through Topic Paper 018, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered. A summary of these comments, their status, and the Council’s response are provided in the table below. There were 2 responses on the Design, Quality and Place 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 A.S. Associates Ltd. Planning and Architectural Services Disagree, but does not wish for it to be treated as a formal dispute List of Evidence/Datasets: The respondent has indicated that they disagree with the list of evidence/datasets identified in Topic Paper 018: Design, Quality and Place. They specifically refer to the reference under paragraph 1.60 to ‘Settlement Audit’ work and ‘Site Appraisal’ templates giving appropriate consideration to the ‘Six Qualities of Successful Places’ prior to site proposals being allocated in the Plan and the lack of clarity as to which datasets will provide evidence for this audit and appraisal work. They further comment that the audit/appraisal of settlements should include reference to the planning history of land around settlements, including small-scale proposals that have implications for alteration to settlement boundaries. A suggested essential dataset is the mapped register of planning applications and its associated case file information, and historic information relating to submissions from landowners/agents for land to be considered for allocation in the LDP should also provide essential evidence. The respondent refers to their client’s history of applications for a site at Auchterarder, which they were advised in the ‘Report of Handling’ PKC’s response to this is two part – Firstly, in line with the Scottish Government’s LDP Guidance (May 2023) paragraph 108, PKC have not considered any detailed policies or site proposals at the Evidence Report stage. There will be a ‘Call for Sites’ or similar exercise following on from the publication of the Evidence Report for our LDP3. The Council will carry this representation forward for consideration at a later date as part of the consideration of proposals and potential review of settlement boundaries exercises. Secondly, the Site Appraisal template that we propose to use as part of this exercise is included in an annex to this Evidence Report and is the agreed ‘Local Development Plan: Site Assessment and SEA Checklist’ template developed by the Consultation Authorities and dated 6th February 2024, with additional deliverability criteria added. The Settlement Audit template is noted as an existing evidence gap in this Evidence Report as we have not had the capacity to develop it to date. In developing our template we will draw on all place-based evidence sources we have, and which have been identified in this Evidence Report in order to meet the requirements and expectations of the national suite of planning policies included in NPF4.
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Respondent Agree or Dispute Summary of Comments PKC’s Response for the application to pursue, via the LDP process, the seeking of an alteration to the settlement boundary. They wish for their client’s site to be considered in the preparation of LDP3. Summary of Implications for Proposed Plan (PP): No Comments made. Further Comments: They had no further comments to make. Formal Dispute: A.S. Associates Ltd. Planning and Architectural Services do not wish for their response to be treated as a formal dispute. Earn Community Council Agree List of Evidence/Datasets: Agree with list of evidence/datasets set out under Topic Paper 018. Summary of Implications for Proposed Plan (PP): Agree with summary of implications of the evidence for the PP. Further Comments: Highlights that there is no mention in Topic Paper 018 of the Community Council’s ‘Place Standard’ which was carried out in 2020, but that there is reference to “out of date” Local Action Plans and Design Charettes. Further comments that no link is provided on page 28 of the Topic Paper to PKC Ward Profiles. Overall, Earn Community Council comments that overall, a need is identified to update data in the planning and preparation in regard to Design Quality and Place. Formal Dispute: Earn Community Council does not wish their response to be treated as a formal dispute. PKC welcomes the comments submitted by Earn CC; reference to the Earn Community Conversation Report was omitted in error by the Council but it has now been included under the Local Living and 20 Minute Neighbourhood issue list of evidence and datasets. The hyperlink to the PKC Ward Profiles has been provided elsewhere in Topic Paper 018 on pages 23 and 25 (paragraphs 1.55 and 1.59) and in Table A1 of Appendix A. It has also been provided under this issue of our Evidence Report under the ‘Links to Evidence’ and ‘Summary of Evidence’ sections. The age of the Local Action Plans and Design Charettes have been acknowledged under the ‘Gaps, Uncertainties and Key Issues Raised’ sections of this Evidence Report and in Topic Paper 018. It is the Council’s intention to review the contents of these documents for each of our places as part of our Settlement Audit work and to update the data/profiles to reflect current circumstances prior to developing our LDP3 Spatial Strategy.
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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 018: Design, Quality and Place, and our summary of implications of that evidence for the preparation of the Proposed Plan. Further Comments: They had 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. Gray Planning and Development Ltd. On behalf of GS Brown Construction Ltd. Neither List of Evidence/Datasets: No comments made. Summary of Implications for Proposed Plan (PP): No comments made. Further Comments: The respondent has commented that landowners would like to be included as part of the Settlement Audit exercise mentioned in Topic Paper 018. Formal Dispute: Not applicable. PKC notes Gray Planning and Development Ltd.’s request for landowners to be included in the Settlement Audit stage of the Proposed Plan’s preparation. The Settlement Audit will look at the existing facilities and services on offer in a settlement, any current constraints (environmental, infrastructure etc.), and where opportunities might exist for future development, taking account of the Proposed Plan’s overall Spatial Strategy for the PKC Area. A ‘Call for Sites’ or similar exercise will also be carried out in conjunction with the Settlement Audit, which will provide an opportunity for landowners to put forward sites for consideration for inclusion within the Proposed Plan, and to provide evidence or information as to the suitability of their sites to help support the delivery of the Spatial Strategy. No further action required at Evidence Report stage. Historic Environment Scotland (HES) Agree List of Evidence/Datasets and Summary of Implications for PP: In their comments HES indicated that they agree with the list of PKC welcomes Historic Environment Scotland’s comments. No further action required.
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Respondent Agree or Dispute Summary of Comments PKC’s Response evidence/datasets which has been gathered by the Council for this issue and the summary of implications of the evidence for the Proposed Plan, as set out in Topic Paper 018. Further Comments: HES commented that they welcome the references to the relevance of PKC’s Placemaking Guide, as well as the commitment to update it; continuing that the Placemaking Guide sets out useful and important guidance on the consideration of the historic environment in planning, and the opportunities it offers in placemaking. Formal Dispute: Not applicable. Homes for Scotland Dispute List of Evidence/Datasets: In their comments Homes for Scotland indicated that they disagree with the list of evidence/datasets which have been gathered for this issue (as set out in Topic Paper 018). They have suggested the following additional sources of evidence for inclusion under the ‘Design, Quality and Place’ issue in order to deliver the six qualities of a successful place and policy intent of NPF4 Policy 14: • Creating Places: A Policy Statement on Architecture and Place for Scotland – sets out comprehensive value that good design can deliver. • Scottish House Condition Survey Local Authority Analysis 2017-19 – provides data on how house conditions compare to the national average. • Designing Streets: A Policy Statement for Scotland – sets out key considerations for street layouts and how communities can be accommodated through design. PKC welcomes HfS’s comments and has now updated the list of evidence for the Design, Quality and Place issue of this Evidence Report to include the additional suggested information sources. A summary of implications of these pieces of evidence for the development of the Proposed Plan has also been provided, including the recognition that a multi- disciplinary approach to the design (including new build) and delivery of high quality places, in collaboration with communities, can also deliver successful places. As a result of adding the Scottish Household Condition Survey (SHCS) Local Authority Analysis to our list of evidence for consideration, the Council’s Local Housing Strategy (LHS) and LHS Action Plan have also been added under this issue, and the key information and summary of implications for the Proposed Plan addressed under the SHCS Local Authority Analysis heading.
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Respondent Agree or Dispute Summary of Comments PKC’s Response • Cycling by Design 2021 – details how active travel can be accommodated in new and existing developments and the benefits that can be gained. • Planning Advice Note 83: Masterplanning – details the masterplan process and how it has an important role in achieving successful places. Summary of Implications for the Proposed Plan: Homes for Scotland (HfS) also indicated that they disagree with the summary of implications of the evidence for the Proposed Plan. In their response to Topic Paper 018 they comment that the paper has detailed the criteria for meeting the six qualities and focussed on residents’ perception of the Perth and Kinross Council Area, along with data from the SIMD. Whilst HfS agree that these are important to understand the current base position, it is their view that the Council should also consider evidence relating to how design, quality and place can be delivered through new housing development. Further Comments: HfS supports the development of the ‘Localities Profiles’ as part of the Settlement Audit work for LDP3 to support the delivery of local living and 20 minute neighbourhoods. As per their comments in response to the Local Living and 20 Minute Neighbourhoods Topic Paper, new housing developments of circa 500 homes could potentially support the delivery of some facilities, such as retail units, to support local living. HfS Members would be happy to engage with PKC to discuss this either during or following a ‘Call for Sites’ exercise. HfS invites the Council to utilise the Site Assessment Methodology and Deliverability Checklist that HfS As per the Council’s response to HfS under the Homes issue of this Evidence Report, their proposed deliverability checklist has been taken into consideration in compiling the site assessment methodology template for LDP3.
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Respondent Agree or Dispute Summary of Comments PKC’s Response have shared with PKC when considering ‘Call for Sites’ submissions. The methodology lists NPF4 policies which proposals will be assessed against, and scoring can establish principles to create successful places. Formal Dispute: HfS wish their comments to be treated as a formal dispute. The points they wish to dispute are that PKC should include the additional data listed in their response, and analyse how this will influence the design, quality and place that will be created by future development. Montagu Evans LLP on behalf of Loch Developments Ltd. Agree List of Evidence/Datasets: Agree with list of evidence/datasets. Summary of Implications for Proposed Plan (PP): Agree with the summary of implications of the evidence for the PP. Further Comments: Montagu Evans LLP comment that the allocation and subsequent development of the former BCA site in Kinross will contribute to the development of a liveable place of high-quality design. Formal Dispute: Not applicable. PKC welcomes Montagu Evans LLP’s comments on behalf of Loch Developments Ltd. However, in line with the Scottish Government’s LDP Guidance (May 2023) paragraph 108, PKC have not considered any detailed policies or site proposals at the Evidence Report stage. There will be a ‘Call for Sites’ or similar exercise following on from the publication of the Evidence Report for our LDP3. The Council will carry this representation forward for consideration at a later date as part of the consideration of proposals. No further action required for this Evidence Report. Nature Scot Neither List of Evidence/Datasets: In relation to the evidence gathered on the issue of ‘Design, Quality and Place’ under Topic Paper 018, Nature Scot noted that the Scottish Government’s ‘Creating Places: A policy statement on architecture and place for Scotland’ has been referenced on page 19 of the Paper but has not been included in the list of data sources. Nature Scot also suggest the inclusion of PKC welcomes Nature Scot’s comments on this issue; ‘Creating Places’ was omitted in error from Topic Paper 018 but has now been added to the list of data and information sources as part of this Evidence Report, along with ‘Designing Streets’.
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Respondent Agree or Dispute Summary of Comments PKC’s Response the ‘Designing Streets’ policy statement as part of the evidence for this issue. Summary of Implications for Proposed Plan (PP): No comments provided. Further Comments: No further comments provided. Formal Dispute: Not applicable. PKC Transportation and Development Team Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The Council’s Transportation and Development Team welcomes the focus on place in Topic Paper 018. They neither agree nor disagree with the list of evidence/datasets gathered on this issue, but highlight, in terms of the Council’s Mobility Strategy and Action Plan, that Action 153 is an area for collaboration in the development of the Proposed Plan. This action is to ensure that developments consider place and prioritise the needs of people before the movement of motor vehicles, in line with national and regional guidance. This includes prioritising sustainable and active travel choices, and including fully accessible paths and routes which are well connected with the wider environment beyond the site boundary. Further Comments: No further comments provided. Formal Dispute: Not applicable. We welcome our Transportation and Development Team colleagues’ comments on this issue. The Summary of Implications for the Proposed Plan section of the Evidence Report for this issue has been updated to include specific reference to Action 153. Private Individual Disagree List of Evidence/Datasets: Disagrees with the list of evidence included within Topic Paper 018: Design, Quality and Place. In response to the consultation question asking what the respondent thinks we could improve on in terms of the list of evidence included to allow us to prepare our LDP3, they comment that the effect of over-development and PKC welcomes the respondent’s comments. However, at this stage in the LDP3 process, for the Design, Quality and Place subject, the Council has gathered evidence and information about the localities across Perth and Kinross using the Place Standard Tool as part of our Big Place Conversation (BPC) exercise, and from published community documents, such as Local Action Plans,
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Respondent Agree or Dispute Summary of Comments PKC’s Response how the Six Qualities of Successful Places have been mitigated in these circumstances are not detailed. When asked if there are any other sources of information which they suggest for inclusion, the respondent highlights evidence from objections to LDP2 and the North Scone development, and the objections to the detailed planning applications. The respondent continues that in their opinion PKC has ignored the Six Qualities of Successful Places. Summary of Implications for Proposed Plan (PP): The respondent disagrees with the summary of implications of the evidence for the PP, as the effect of over-development and how the Six Qualities of Successful Places have been mitigated in these circumstances are not detailed. Further Comments: Under the ‘Further Comments’ section of the consultation questionnaire, the respondent comments that “PKC have demonstrated with LDP2 they do not take into consideration the views of the local residents. They ignore the criteria for the Six Qualities of Successful Places.” Formal Dispute: Yes. The respondent wishes their comments to be recorded as a formal dispute as it is their view that Topic Paper 018 fails to address any of the recent historical activity and objection of the local community. Community Action Plans and Design Charettes. The outcomes of our BPC exercise, and these community documents are considered helpful in furthering our understanding of the views of local communities on their local assets, their aspirations, areas for improvement, and a vision for the future of their place. As noted under the ‘Gaps, Uncertainties and Issues Raised’ section for these sources of evidence, PKC recognises that they will require to be updated as part of our Settlement Audit work to ensure they are relevant considering current circumstances. The data gathered as part of our Settlement Audits will also be used to inform our work on Local Living and 20 Minute Neighbourhoods. We have not revisited representations received to our LDP2 as part of our Evidence Report information gathering exercise, or objections to individual planning applications. There will be further opportunities as part of the development of the Proposed Plan and our Spatial Strategy to express location specific issues or concerns. This Evidence Report identifies the Scottish Government’s Six Qualities for Successful Places as key considerations in the development of our LDP3 Spatial Strategy. It summarises those qualities, and comments more generally that applying the qualities in the development of the Plan’s Spatial Strategy, particularly the allocation of proposals in LDP3, should help to foster healthy, pleasant, connected, distinctive, sustainable, and adaptable places. Furthermore, bringing these qualities through in the LDP’s Settlement Audit and Site Appraisal templates should ensure all elements are given the appropriate level of consideration prior to any site proposals being allocated in the Plan, including the
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Respondent Agree or Dispute Summary of Comments PKC’s Response level of development to date, and the capacity of a settlement to absorb further development. Savills on behalf of Dupplin Estate Neither List of Evidence/Datasets: No comments made. Summary of Implications for Proposed Plan (PP): No comments made. Further Comments: Under the ‘Further Comment’s section of the consultation questionnaire, Savills have highlighted that through the ‘Perth Sustainability Park’, there is an opportunity for a development of high-quality homes following the principles of Building with Nature. The response goes into further detail regarding - the facilitatory role that housing delivery plays in assisting PKC achieve other Spatial Strategy aims, the Council’s MATHLR options, and the importance of providing infrastructure first. Formal Dispute: Not applicable. PKC welcomes Savills comments on behalf of Dupplin Estate. However, in line with the Scottish Government’s LDP Guidance (May 2023) paragraph 108, we have not considered any detailed site proposals at the Evidence Report stage. There will be a ‘Call for Sites’ or similar exercise following on from the publication of the Evidence Report for our LDP3. The Council will carry this representation forward for consideration at a later date as part of the consideration of proposals. In terms of comments made regarding the facilitatory role of housing delivery in helping achieve other Spatial Strategy aims, the Council’s MATHLR options, and the importance of an infrastructure first approach, these comments have also been made against the ‘Homes’ and ‘Infrastructure’ topics of this Evidence Report and to avoid duplication, will be more appropriately addressed under those issues. No further action required for this Evidence Report. 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 Comment’s section of the consultation questionnaire, Savills have commented that whilst the evidence sources listed under Topic Paper 018: Design, Quality and Place, in addition to applying the Place Principle and carrying out Settlement Audits, should provide a robust picture in relation to promotion of successful places in LDP3, they consider that “arbitrary site assessment steps should be avoided (for example PKC welcomes Savill’s comments on behalf of Scone Estate. Whilst we appreciate their position regarding the use of site assessments and the need for a balanced planning judgement to be taken, it is still the intention of PKC to use site assessments as part of our Strategic Environmental Assessment (SEA) for LDP3. We have used a site assessment approach to inform our SEA for LDP1 and LDP2. It is an approach which is advocated by the three SEA Consultation Authorities and allows for a consistent approach to the appraisal of all site proposals, provides an evidence trail, ensures that no sites are missed, and that the relevant SEA Topics are fully considered. It also assists in the consideration of
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Respondent Agree or Dispute Summary of Comments PKC’s Response SEA site assessments that are typically used in emerging LDPs) because there is a risk that matters become black and white and a balanced planning judgement is lost.” They provide an example in relation to the likely need of the Council to consider prime agricultural land because of the lack of suitable brownfield land, and areas of highest population demand tend to be near prime agricultural land, and further comment that planning judgement should be used in this instance to weigh- up the benefits that sites, which may be part of the prime agricultural land resource, can deliver across the spectrum of NPF4. Savills also note 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. They wish for this initiative to be referenced and encouraged in the Evidence Report and in LDP3. Formal Dispute: Not applicable. the cumulative effects of proposals on a location. Furthermore, the use of site assessments in the SEA process helps us to gather relevant environmental data and evidence to be taken into account alongside other considerations, such as social and economic issues, to support balanced planning judgements which will consider the content of NPF4 as a whole. The subject of community benefits from renewable schemes is discussed under the ‘Energy, Heating and Cooling’ issue of this Evidence Report. It is however worth noting that, as per the Scottish Government’s Good Practice Principles for Community Benefits from Onshore Renewable Energy Developments, community benefit schemes are voluntary arrangements offered by renewable energy businesses to communities located near developments, and are not a material consideration in a planning application. No further action required. Scottish Water Neither List of Evidence/Datasets: No comment made. Summary of Implications for Proposed Plan (PP): No comment made. Further Comments: Under the ‘Further Comments’ section, Scottish Water (SW) have commented that they welcome a best practice approach on water efficiency within Perth and Kinross. They regard the long-term consideration of impact on water resources when planning for new development to be a key feature in building sustainable, adaptable and healthy places. Building new and retrofitting PKC welcomes Scottish Water’s response and agree with their comments in terms of promoting a best practice approach on water efficiency within the Perth and Kinross Area and taking a long-term view as to the impacts of new development on water resources of the area. PKC will continue to work closely with SW during the different stages in the preparation of our LDP3 and beyond, to help identify where opportunities may exist to safeguard existing resources, introduce efficiency measures at site and community scales, and develop BGI proposals with multiple benefits, including those around
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Respondent Agree or Dispute Summary of Comments PKC’s Response existing homes to become more water efficient will help address water scarcity issues, and incorporating efficiency measures into developments and refurbishments maximises water saving potential. SW would welcome opportunities to manage rainwater at plot and community scale and make use of that water for non-potable use. To this end, SW support developers in building water efficient homes, and would go further to suggest that new developments become water neutral to allow communities to thrive through sustainable water use. In addition, SW notes reference to blue-green infrastructure in Topic Paper 018, and strongly supports the inclusion of blue-green assets as a key design feature for new and existing developments, due to the positive health benefits these assets can provide by being accessible. SW will continue to work with local authorities and housebuilders to develop Blue-Green Infrastructure proposals that have strong placemaking, as well as surface water management, at the heart of design. Formal Dispute: Not applicable. surface water management and creating high-quality attractive places. No further action required for this Evidence Report. Tactran Regional Transport Partnership Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): In relation to the list of evidence gathered and summary of implications of that evidence for the Proposed Plan, Tactran notes the Council’s reference in Topic Paper 018 to the Scottish Government’s Six Qualities of Successful Places, including connected places, and what that means. Tactran commented that in addition to the key elements of connected places outlined in the Scottish Government’s Six Qualities PKC welcomes Tactran’s comments. The Summary of Implications for the Proposed Plan section of the Evidence Report for this issue has been amended to include reference to the need to consider the barriers our communities can face in accessing sustainable modes of transport when we are identifying proposals for future development as part of our Spatial Strategy. It is suggested that these barriers might best be considered through the SEA for our LDP3 under the ‘Population and Human Health’ topics, and solutions
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Respondent Agree or Dispute Summary of Comments PKC’s Response of Successful Places, that “the ability to meet the travel demands of development by sustainable modes will be informed by the barriers that people face to using sustainable travel such as cost, physical ability (e.g. disabilities) and safety and security. A successful place is one that is accessible for everyone, irrespective of physical or learning difficulties.” Further Comments: Overall, Tactran welcomed the detail set out in the Council’s topic papers in relation to the evidence that will be used to inform the development of this Evidence Report and the Proposed LDP3. Specifically relating to the evidence for this issue presented in Topic Paper 018, Tactran did not dispute the list of evidence/datasets and the summary of implications of that evidence for the Proposed Plan but advised of key considerations which the Council should take into account when developing our LDP3 Spatial Strategy in order to deliver connected places which are accessible for everyone. Formal Dispute: Not applicable. may also be found through our work on local living and 20 minute neighbourhoods.
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Issue: Local Living and 20 Minute Neighbourhoods Corresponding NPF4 Policy/Policies: • National Planning Framework 4, Policy 15: Local living and 20 minute neighbourhoods • Other key NPF4 policy connections – 1:Tackling the climate and nature crises; 2: Climate mitigation and adaptation; 13: Sustainable transport; 14: Design, quality and place; 18: Infrastructure first; 16: Quality homes; 20: Blue and green infrastructure; 21: Play, recreation and sport; 25: Community wealth building; 27: City, town, local, and commercial centres, and 28: Retail Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 019: Local Living and 20 Minute Neighbourhoods (https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume nts/TP019_LocalLiving20MinuteNeighbourhoods.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, cultural, economic, social, built heritage and environmental characteristics of the district. Section 15(2A) of The Town and Country Planning (Scotland) Act 1997, as amended: • A statement of the planning authority’s policies and proposals as to the provision of public conveniences. Section 15(2B) of The Town and Country Planning (Scotland) Act 1997, as amended: • A statement of the planning authority’s policies and proposals as to the provision of water refill locations. The policy intent for NPF4 Policy 15 is noted as: • To encourage, promote and facilitate the application of the Place Principle and create connected and compact neighbourhoods where people can meet the majority of their daily needs within a reasonable distance of their home, preferably by walking, wheeling or cycling or using sustainable transport options. The policy outcomes for Policy 15 are: • Places are planned to improve local living in a way that reflects local circumstances. • A network of high-quality, accessible, mixed-use neighbourhoods which support health and wellbeing, reduce inequalities and are resilient to the effects of climate change. • New and existing communities are planned together with homes and the key local infrastructure including schools, community centres, local shops, greenspaces, health and social care, digital and sustainable transport links. Under Policy 15 Local Development Plans (LDP) are expected to support local living, including 20 minute neighbourhoods within settlements, via
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their spatial strategy, associated site briefs and masterplans. The approach should take account of the local context, consider the different settlement patterns across the LDP area, and reflect the particular characteristics and challenges faced by each place. Communities and businesses are seen as having an important role to play in informing this approach through their engagement with the planning system, helping to strengthen local living. 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 15, the Guidance advises that planning authorities are expected to have an understanding of existing settlement patterns, considering the particular characteristics and challenges faced by places in terms of local living. The LDP Guidance highlights those other types of information which planning authorities may wish to prepare or review (for spatial implications) as: the locations of existing facilities used for community functions (e.g. for the purposes of sport, leisure, arts and cultural activities, or to support lifelong learning or social interaction); locations of facilities that are used for support services within a community for health and wellbeing (e.g. visiting health services, clinics, support and advice services and childcare provision), and a review of previous engagement. Links to Evidence: Understanding Our Local Places • Climate X Change and Ramboll, 20 Minute Neighbourhoods in a Scottish Context (February 2021) • Scottish Government, Local Living and 20 Minute Neighbourhoods: Planning Guidance (April 2024) • Perth and Kinross Council Corporate Plan 2022-2027 • Perth and Kinross Local Development Plan 2 (2019) • Perth and Kinross LDP2 Infrastructure Capacity Studies (2017) • Scottish Index of Multiple Deprivation (2020) • PKC LDP3 Big Place Conversation • Perth and Kinross Community Plan (Local Outcomes Improvement Plan) 2022-32 • Perth and Kinross Council LDP2 Design Charettes • The Perth City Plan 2015-2035 • PKC Placemaking Programme • Invest in Perth: Smart Investing Now and for the Future • Perth Cycle Network Masterplan • Consultation Draft Mobility Strategy • Perth and Kinross Mobility Strategy Draft Action Plan • Perth and Kinross Local Action Plans • Community Action Plans - Meigle and Ardler, Stanley, Alyth, Coupar Angus, Dunkeld and Birnam, Crieff, Blairgowrie and Rattray, Pitlochry and Moulin, Muthill and Tullibardine, Auchterarder and Aberuthven, and St. Fillans. • PKC LDP3 Invitation to Create LPPs • PKC Ward Profiles (2022) • Scottish Living Locally Data Portal
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The Place Principle • Scottish Government and COSLA, Place Principle (2019) Location of Facilities • Perth and Kinross LDP2 Infrastructure Capacity Studies (2017) • Perth and Kinross Council, Map of Public Toilets and Comfort Schemes • Scottish Water, Your Water, Your Life - Find My Nearest Tap • Perth and Kinross Council List of Water Foutain and Refill Taps Sport and Leisure, Arts and Cultural Activities • PKC Leisure, Sport and Culture Webpage • Live Active Website • Perth City and Towns Website • Visit Scotland Website • Perth and Kinross Council Culture Strategy (2023-2028) Childcare Provision and Supporting Lifelong Learning • PKC Schools and Learning Webpages • University of the Highlands and Islands Website • Perth and Kinross Employability Network Visiting Health Services and Clinics • NHS Inform Scotland’s Service Directory Social Interaction, and Support and Advice Services • Your Community PK Website Summary of Evidence: Understanding Our Local Places Climate X Change and Ramboll 20 Minute Neighbourhoods in a Scottish Context (February 2021) This research paper was published by Climate X Change and Ramboll following the completion of a project which considered the ambition for applying the 20 minute neighbourhood concept in Scotland, taking account of the varying settlement patterns across the country, and sought to identify solutions that would support its delivery. It also analysed international evidence of success for the various concept solutions and delivery mechanisms, including the specific elements that were considered successful, any impacts on placemaking, barriers to success, regulatory frameworks, funding mechanisms, and stakeholder engagement and buy- in. The key findings of the assessment showed that communities, across both urban and rural settlement areas, have the necessary services and infrastructure that would allow them to be 20 minute neighbourhoods. However, it could not be concluded through the assessment that the required quality of services or infrastructure is in place, or that these places are currently performing as 20 minute neighbourhoods. The examples reviewed highlighted that a clear plan, which is people-centred, developed with stakeholders in the local community, and with bespoke local considerations, is necessary in order to achieve the vision. Local Living and 20 Minute Neighbourhoods: Planning Guidance (April 2024) This Scottish Government guidance document has been developed to help support the application of NPF4 Policy 15 and highlights the links between
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a local living and 20 minute neighbourhoods’ approach and the delivery of healthy, sustainable, and resilient places that can support a good quality of life and balance our environmental impact at the same time. Wider benefits of the approach are recognised in terms of climate and the environment, health and wellbeing, the local economy, and quality of life. The document contains a ‘Local Living Framework’ which is intended to provide ‘a consistent structure to consider the key characteristics of local living and 20 minute neighbourhoods in development planning, decision- making and in design proposals.’ The Framework sets out 14 key themes, reflecting the Place and Wellbeing Outcomes and the Place Standard Tool (Design Version), which are then grouped into the 5 overarching categories of: Movement; Space; Resources; Civic, and Stewardship. These categories are regarded as the key considerations for local living. The delivery of local living is thought to be a place-based, flexible approach that involves having a full understanding of the context of a place, all the assets present, and also its needs and opportunities. In order to take a structured approach to local living the guidance suggests (on page 29) the following steps: 1. Understand context – understanding the context of the place through the use of quantitative and qualitative information. 2. Collaborate, plan, design – developing collaborative models of working to inform place-based planning and design processes. 3. Implement and review – aligning investment, developing delivery capacity, and embedding in ways of working. Collaborative, participatory and place-based working are considered as essential components in delivering local living and 20 minute neighbourhoods that are inclusive, and allow everyone to live well locally, as well as take part in decision making processes about their places. Placemaking is also highlighted as being important to delivery of the approach. The guidance refers to the Place Principle and the Six Qualities of Successful Places as being key to delivering good places and also local living and 20 minute neighbourhoods. In terms of applying the concept to different geographies, the document recognises Scotland’s diversity, and that flexibility will be required – this is because accessing the majority of daily needs within a 20 minute walk, wheel, or cycle in remote rural or island areas may not always be achievable. However, it is still considered ‘…possible to support local living through planning for connected, attractive, sustainable places that respect the character and context of rural settings, and also by considering the relationship between different settlements and the opportunities that exist to support a network of places to meet daily needs. 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.
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Delivery of the Corporate Plan’s Priorities will be underpinned by a set of Key Principles and delivered through a range of Key Actions. Perth and Kinross Local Development Plan 2 (2019) The current Perth and Kinross Local Development Plan, along with its accompanying supplementary guidance documents, and research and information papers on infrastructure, provide a good basis of understanding of the local context and characteristics of the area’s towns and villages, as well as Perth City. Information on the principal characteristics of the area; sustainable transport; design, quality, and place; infrastructure; quality homes; blue and green infrastructure; open space, play and recreation; Community Wealth Building; city, town and local centres, and retail, are all explored in more detail under the Issues of this Evidence Report. The Perth and Kinross Area is a mix of both urban and rural communities. The Plan’s settlement hierarchy follows the Tiers 1, 2 and 3 categories which were defined in the now revoked Strategic Development Plan – TAYPlan. This hierarchical approach focuses development on the Principal Settlements, but also recognises the extremely limited brownfield opportunities that exist across Perth and Kinross, and that the sustainable growth of the area will rely on greenfield land release also. Map 1 to follow shows the LDP2 Spatial Strategy: A Successful, Sustainable Place, representing the hierarchy of settlements, key transport connections across the area, and the Strategic Development Areas that were identified in TAYPlan. Map 2 outlines the LDP2’s Spatial Strategy for the Plan’s ‘A Connected Place’ theme, highlighting the existing and proposed key transport connections across the area. Finally, Map 3 shows the active travel connections across Perth and Kinross, including: the National Cycle Network, Rights of Way, Core Paths, the Cateran Trail, and Signposted Routes.
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Map 1: LDP2 Spatial Strategy: A Successful, Sustainable Place
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Map 2: LDP2 Spatial Strategy: A Connected Place
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Map 3: Key Active Travel Connections within Perth and Kinross
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Scottish Index of Multiple Deprivation (2020) The 2020 Scottish Index of Multiple Deprivation (SIMD) offers a wide range of metrics to understand how different areas in Perth and Kinross perform compared to the rest of Scotland. Overall deprivation figures show that 39 out of 186 (21%) of all data zones within PKC are ranked overall in the 40% most deprived areas in Scotland. These account for a population of over 29,000, a 19.3% of the total for PKC. 11 out of 186 (5.9%) zones are within the 15% most deprived; 3 out of 186 (2%) are within the 10% most deprived areas. By way of contrast, 16 out 186 (8.6%) zones and 12,016 residents (8%) are within the 10% least deprived areas in Scotland. The most deprived zones within PKC are located in urban areas. Of the 11 data zones within the 20% most deprived in Scotland, 9 are in Perth city, with 2 zones in Rattray to the east of Blairgowrie. Map below shows the overall SIMD decile for Perth city from 1 (most deprived) to 10 (least deprived). The map shows significant contrast in deprivation levels within urban environments. While areas to the south of the city enjoy very low levels of deprivation, there are several zones within the most deprived in the country. Further analysis of data reveals a compilation of issues in these zones, with low scores for education, health, income and housing. The SIMD also monitors accessibility for residents of a data zone to key services and facilities. The ‘Access’ domain summarises proximity to petrol stations, primary healthcare, post office, retail and primary and secondary education premises. Perth and Kinross has a large number of data zones within the most access deprived in Scotland. These, together with the population they account for, are summarised in table below
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Metric No. of zones (% of PKC total) Population (%) Working age population (%) 5% most access deprived 16 (8.6%) 11,886 (7.9%) 7,613 (8.3%) 10% most access deprived 38 (20.4%) 32,758 (21.7%) 20,589 (22.3%) 20% most access deprived 67 (36%) 56,357 (37.3%) 34,731 (37.7%) Maps below show the distribution of SIMD data zones based on the ‘Access’ domain for the whole of PKC as well as Perth city.
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Perth and Kinross LDP2 Infrastructure Capacity Studies (2017) As part of the research work carried out for the production of our LDP2, Infrastructure Capacity Studies were undertaken in 2017 for the larger settlements within the PKC Area. These studies analyse population growth, community facilities, open space, transport infrastructure, education, health, energy and water infrastructure. The information contained within the studies will be updated as part of our Evidence Report, infrastructure audits and Settlement Audit work to inform the Proposed Plan. 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 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. There were also targeted sessions held with schools, service user groups, and minority groups. The results of the Big Place Conversation have been summarised and made available in the Perth and Kinross Council website. The results are provided by community council area, by ward and overall council-wide findings. Some of these insights have been included as part of LDP3’s Evidence Report under the required statement of steps taken by the Council in preparing the report to seek the views of various stakeholders, as prescribed by the Planning (Scotland) Act 2019. Perth and Kinross Community Plan (Local Outcomes Improvement Plan) 2022-32 Our Community Plan was approved by the Perth and Kinross Community Partnership in September 2022. It contains an ambition for the area to ‘be the best place in Scotland for everyone to live life well, free from poverty and inequality.’ The Plan sets out 5 Strategic Priorities for the area, which are: 1. Reducing Poverty (child, food, and fuel) 2. Physical and Mental Wellbeing (evidence shows a major increase in demand for mental health wellbeing support post Covid-19) 3. Digital Participation (issues of connectivity, technology and individual capacity identified across the area)
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4. Learning and Development (supporting individuals and communities to build their skills, confidence, and resilience) 5. Employability (an enhanced focus on upskilling for those seeking employment and supporting young people in a fast-changing job market, enabling people to enter, sustain and progress in work) The Community Plan also provides a summary profile for the area of relevant data and trends linked to those Strategic Priorities. This helps build a stronger picture of the key characteristics and challenges of the Area which the Council, along with our Community Planning Partners, are seeking to address through a number of area-wide actions. These actions have all been linked to corresponding National and Local Outcomes too. Perth and Kinross Council 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. The Perth City Plan 2015-2035 This Plan was prepared on behalf of the Perth City Development Board. The Board consists of senior representatives of the private and public sector in Perth and Kinross, and the wider region. It sets out a long term vision for Perth as one of Europe’s great small cities, along with a framework for investment in strategic infrastructure. It also includes a 5 year delivery plan for economic development and placemaking. The Plan focuses on the concept of smart growth, i.e. that Perth City ‘uses digital and environmental technologies, thoughtful design and next generation concepts to make… [it] a place where: • People live well, work in quality jobs and play in a great environment – a prosperous, balanced community not a commuter dormitory; • Environmental technologies will be a key driver of economic growth and innovation; • The city will grow in a responsible way, reducing car dependency and encouraging the use of public transport; • We take full advantage of digital technologies to create a city which is efficient and connected; • Low-carbon will be a way of life, founded on energy-efficient homes and businesses; • The unique characteristics of the historic city centre and Perth’s natural setting will be celebrated and enhanced.’ Figure 1 to follow shows the Plan’s Framework, which is based on 4 strategic themes and 8 ‘Big Moves’ to help promote investment in economic development, learning skills, placemaking, and tourism.
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Figure 1: Perth City Plan – The Framework PKC Placemaking Programme This Programme is linked to the Perth City Plan and 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). Invest in Perth: Smart Investing Now and for the Future This document sets out the investment opportunities being delivered through 3 key pillars (energy, mobility, and digital) to realise a ‘Smart Perth’. The aim of the Smart Perth programme is to make Perth one of the most sustainable small cities in Europe. A city with a net zero future that will be inclusive, sustainable, grow the economy, create jobs, and improve quality of life. The programme’s flagship investment project is Perth West, which will incorporate Perth Eco Innovation Park, the Perth Innovation Highway, and a logistics, mobility, and refuelling hub. Wider opportunities for smart investing include - Perth and Kinross Strategic Energy Partnership; EV Charging Infrastructure; Circular Economy and Binn Eco Park, and Gigabit Connected Perth. Perth Cycle Network Masterplan This document is a key part of the Perth City Plan, building on the vision of creating a hierarchy of streets, public spaces, walking and cycling routes
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across the city region. It outlines a framework for investment in active travel through identifying 8 cycle corridors which will help link the city centre to its surrounding communities and those areas identified in LDP2 for development to the north and west of Perth. Mobility Strategy The Mobility Strategy sets Perth and Kinross 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. The Strategy responds to the climate change agenda and changes in how people travel. It also considers emerging technologies, digital services, housing, inclusion, poverty, health, climate adaptation, economic growth, air quality, and placemaking. The document presents a set of 11 Transport Planning Objectives (TPOs), aiming to guide the definition of policy, development and investment decision making processes. This list of TPOs includes several items that align with, and should work in support of, the principles of Local Living: • TPO1: To improve the affordability of transport options across Perth and Kinross for all • TPO2: To improve the ability of rural communities and communities with protected characteristics to access jobs, education and services • TPO3: 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 • TPO6: To support local development that encourages and facilitates local living and sustainable access, across Perth and Kinross, by achieving an increased active travel and public transport mode split to and from new developments • TPO8: To improve labour market access through sustainable transport, active travel, and digital opportunities, to and from Perth and Kinross • TPO10: To improve physical; and mental health within Perth and Kinross through walking, wheeling and cycling Perth and Kinross Mobility Strategy Action Plan The Mobility Strategy is also accompanied by an Action Plan which includes a number of actions which are of direct relevance to our Local Development Plan 3 Spatial Strategy, including those relating to: connected neighbourhoods and centres; green and blue infrastructure; open spaces and opportunities for play, and the identification of sustainable future site allocations. Perth and Kinross Local Action Plans There are 5 Local Action Plans (LAP) covering the 7 localities within the Perth and Kinross Area. Each LAP contains a profile of the locality/localities; information on the relevant Community Action Partnerships; data and information on the Key Inequalities for the area under the themes of: SIMD, Child Poverty, Crime, Income, Employment, Housing, Health and Wellbeing, Fairness Commission key themes, and lessons learned so far, and a list of Key Issues Identified, with accompanying statements on ‘What needs to change’ and the actions required to bring about those changes, when and by whom.
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Community Action Plans 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. There are currently 11 Community Action Plans (CAPs) in Rural Perth and Kinross. These are available for Alyth, Auchterarder and Aberuthven, Blairgowrie and Rattray, Coupar Angus, Crieff, Dunkeld and Birnam, Meigle and Ardler, Muthill and Tullibardine, Pitlochry and Moulin, Stanley, and St. Fillans. There is also a CAP development process due to start for Comrie once the necessary funding has been secured. PKC LDP3 Invitation to Create Local Place Plans The Planning (Scotland) Act 2019 introduced a new type of plan called Local Place Plans (LPPs). These are plans prepared by a Community Council or community-controlled body, and supported by the community, that describe their vision for the future of their local area. LPPs set out proposals for the “development and use of land”, which can be proposals for new buildings, or other changes in the way land is used, such as walking or cycling routes, historic building preservation, affordable housing, or improved open spaces. When preparing an LPP, the community body must have regard to the Local Development Plan, National Planning Framework, and the Locality Plan for the area. In December 2023, Perth and Kinross Council advertised an invitation to create LPPs, stating that community bodies can prepare LPPs for their area and submit to the Council for registration at any time. Any LPPs that are registered with the Council by 31 January 2025 will have the greatest opportunity to be taken into account when preparing our LDP3, as work on preparation of the Proposed LDP3 is programmed to begin in early 2025. At the time of writing this document, a number of community bodies within Perth and Kinross expressed their interest in preparing an LPP. The following 10 communities have engaged in the plan making process: • Aberfeldy Dull and Weem; • Alyth; • Ardoch; • Blairgowrie and Rattray; • Cleish and Blairadam; • Crieff; • Errol; • Fossoway; • Glenlyon and Loch Tay; and • Meigle and Ardler. Perth and Kinross Council Ward Profiles (2022) In 2022 the Council collated ‘Ward Profiles’ for each of the 12 Council Ward Areas. The information for each area has been divided into main topics which are: population, economy, housing, education, physical environment. Information has also been included on local deprivation based on the Scottish Index of Multiple Deprivation (SIMD), where it is relevant to a local area. These profiles (with updated data where available) will be useful to our LDP3 Settlement Audit exercise.
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The Place Principle Scottish Government and COSLA Place Principle (2019) One of the Policy Intents of NPF4 Policy 15 is to encourage, promote, and facilitate the application of the Place Principle to create connecting and compact neighbourhoods. The Place Principle was adopted by the Scottish Government and COSLA in 2019 to help overcome organisational and sectoral boundaries to encourage better collaboration and community involvement. It promotes a shared understanding of place, and the need for communities, public organisations, and businesses to work together to achieve better outcomes for people and communities. The Place Principle says that we recognise that: • Place is where people, location and resources combine to create a sense of identity and purpose and is at the heart of addressing the needs of communities and helping them realise their full potential. Places are shaped by the way resources, services and assets are directed and used by people who live in and invest in them. • A more joined-up, collaborative and participative approach to services, land, and buildings, across all sectors within a place, helps support better outcomes for all, and increased opportunities for people and communities to shape their own lives. The Principle requests that all those responsible for providing services and looking after assets in a place need to work and plan together and with local communities, to improve the lives of people, support inclusive and sustainable economic growth, and create more successful places.
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Location of Facilities Perth and Kinross LDP2 Infrastructure Capacity Studies (2017) The 2017 studies included mapped information on the number and type of different community facilities and services within settlements and how accessible they were within travel zones of 5 minute intervals, from 5 minutes through to 20 minutes. The list of facilities and services looked at included: • Community sports facilities and leisure activities. • ATMs • Petrol stations • Libraries and/or mobile library services • Community or town halls • Post Offices • Public houses and hotels • Recycling points and centres • Council offices • Healthcare facilities and services • Open spaces • Education provision and capacity • Retail and employment offer • Energy supply and water/wastewater capacity • Access to high speed broadband The capacity studies also considered transport and travel connections, including active travel, the capacity of the road network, and road safety records. Finally, a SWOT analysis was undertaken for each settlement. Perth and Kinross Council, Map of Public Toilets and Comfort Schemes Perth and Kinross Council currently operates 7 public toilets throughout the Council Area, and Blairgowrie and Rattray Development Trust operate a further public convenience facility at a Council-owned building in Blairgowrie. They are a mix of unattended facilities (located mainly in smaller settlements and parks), which are free to use, and the attended facilities (located in larger towns), which have a 50 pence admission charge. Regular visitors of the attended facilities who have certain medical conditions, can apply for a Public Toilet Access Pass, which allows them to use the attended facilities free of charge. Under 5’s can use the facilities free of charge when accompanied by a fee-paying adult. The Council also offers a number of free to use public toilets through partnerships with local service providers, e.g. hotels, pubs and public buildings. This is known as the Perth and Kinross Comfort Scheme. The Council pays an annual fee to businesses, tourist hubs and community groups, to allow the public to use these facilities at no cost, regardless of whether or not they are a customer. Map 5 to follow provides an overview of the distribution of these facilities. Further details regarding the location and types of public toilets, and those
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which are part of the ‘Comfort Scheme’, can be viewed on an interactive map provided on the Council’s website. Map 5: Location of Public Toilets and Comfort Schemes Scottish Water, Your Water, Your Life - Find My Nearest Tap Scottish Water currently has 6 installed blue top up taps within the Perth and Kinross Council Area. The locations of these publicly accessible refill taps are listed below and can be viewed on Scottish Water’s ‘Your Water, Your Life’ webpages. • The Square, Aberfeldy • Lady Mary’s Walk Car Park, Crieff • Perth High Street • South Inch Park, Perth • North Inch Park, Perth • Atholl Road, Pitlochry Perth and Kinross Council Water Refill Locations Perth and Kinross Council manages a total of 169 water fountains and zip/refill taps located within council premises. These are often installed in educational and care facilities, as well as council depots. While these are part of the asset management duties of PKC, they are only accessible to authorised users of the facilities, and are not available to the wider public. The Scottish Government’s LDP Guidance suggests that other information which planning authorities might wish to prepare or review in relation to NPF4 Policy 15 are those which help identify the locations of facilities which are used for community functions and support services within a community for health and wellbeing. A more detailed audit of a number of these types of facilities (including consideration of their capacity) will be considered under the ‘Infrastructure’ issue in this Evidence Report and updated where necessary as part of the Settlement Audit work for LDP3. The audits will build on the infrastructure capacity studies undertaken for LDP2 in 2017 for the larger settlements within Perth and Kinross. Other information sources which can be drawn upon to help update the 2017 infrastructure capacity studies are covered in the paragraphs to follow. It is likely that the list of “destination uses” which we use in our approach to identifying 20 minute neighbourhoods and local living places will replicate those facilities and services included in our 2017
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Infrastructure Capacity Studies and include any additional types of facilities and services listed in the Scottish Government’s LDP Guidance regarding Policy 15. Sport and Leisure, Arts and Cultural Activities PKC Leisure, Sport and Culture Webpage Perth and Kinross Council has an online interactive ‘Open Spaces’ map which contains data on the location and typology of different types of open spaces across Perth and Kinross. The map holds information on major parks, skate parks, sports pitches, burial grounds, community food growing locations, play areas, rights of way, adopted core paths, signposted paths, maintained open space, and our countryside sites. It is available both internally via our corporate GIS system and there are also publicly accessible maps under the various open space type sections on the Leisure, Sport and Culture page of our website. Live Active Website The Live Active website provides information on the location of leisure facilities, as well as community halls available for hire, across Perth and Kinross, and the ranges of activities on offer at them. Perth City and Towns Website, Visit Scotland Website and Perth and Kinross Council Culture Strategy (2023-2028) The Perth City and Towns website provides information on the location of cultural and event venues across Perth and Kinross, along with what is on offer at those venues under the ‘Explore and Stay’ and ‘Things to Do’ sections. The Visit Scotland website and the Council’s Culture Strategy (2023-2028) also provide lots of useful details about places of interest and things to do across the area. Childcare Provision and Supporting Lifelong Learning PKC Schools and Learning Webpages The Council maintains a record of the provision of early learning and childcare services (including childminders, children’s clubs, and groups), and schools (primary and secondary) throughout the area. This record includes details of their location and school catchment areas and is available via an interactive map on the Council’s Schools and Learning pages on the website. University of the Highlands and Islands (UHI) Website The UHI website provides information on the University’s Perth Campus, including courses, their partnership working with all senior secondary schools in Perth and Kinross, and the services on offer at the campus. Perth and Kinross Employability Network The Perth City based Perth and Kinross Employability Network provides information on their website about the wide range of supports, and opportunities they offer to help people with additional challenges and barriers to work improve their employability skills and access meaningful volunteering or work experience placements with their Members. Information on current Service Offers, including the Employment Connections Hub in Perth is also available on the Network’s website.
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Visiting Health Services and Clinics NHS Inform Scotland’s Service Directory The NHS Inform Scotland’s Service Directory provides details of health and wellbeing services available across the Perth and Kinross Area. This includes information on - A&E and Minor Injuries Units; dental services; GP practices; hospitals; opticians; pharmacies; clinics, and other health and wellbeing services, like support groups. Social Interaction, and Support and Advice Services Your Community PK Website The ‘Your Community PK’ website provides an extensive list of services available (including contact information) across Perth and Kinross under the - Advice and Info; Care and Support; Children and Families; Health and Wellbeing, and Things To Do categories. The website also contains an interactive map to help identify the location of these services. Overall accessibility research Scottish Living Locally Data Portal Research led by the University of Glasgow maps the level of access of data zones across Scotland to facilities and services classified under 12 living locally domains. Table below shows the percentage of residential locations that have access to specific facilities and services within an 800m network distance, as an average for data zones within Perth and Kinross, and compared to averages for Scotland. Domain PKC Nation avg. Domain PKC Nation avg. Healthy food retail 44.1 52.9 Financial 67.7 81.7 Public Transport 89.2 94.4 Pharmacy 40.4 59.0 Frequent Public Transport (>5 / hr) 59.3 65.1 Public Open Space 77.6 89.6 Primary Health Care 27.0 42.2 Social Cultural 72.0 77.6 Recreational & Sports Facilities 75.4 86.1 Eating Establishment 47.0 57.5 Primary School 52.9 67.9 Superfast Broadband 82.4 92.5 While figures for Perth and Kinross are determined by the rural nature of a number of data zones, the overall comparison to the national average demonstrates gaps in the provision of facilities and services to a segment of the population. A breakdown of accessibility figures for individual data zones within Perth and Kinross is shown in Summary of SLLDP data.
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Summary of Implications for the Proposed Plan: • The next stages of the Development Plan process will include the update of datasets to provide a more accurate picture of facilities and services. • A methodology for the assessment of local living and 20 minute neighbourhood interventions will be developed. This will combine the need for development to be adequately placed and the role that new proposals can play in the delivery of additional infrastructure for local communities. • The selection of sites for development will include an evaluation of sustainable travel options. Infrastructure for walking and cycling and public transport services will be assessed to identify existing provision or enhancement opportunities. • The location of housing and employment land will take into account the potential for commuting trip generation and will aim to identify reduction or mitigation opportunities. • The location of healthcare and educational facilities will be assessed, aiming to support the accessibility for residents and visitors, and promoting well integrated places • Feedback from community consultation exercises, including Big Place Conversation and Local Place Plans, will be incorporated to identify key gaps in the provision of local facilities and inform future development. • Utilise masterplans and design briefs to encourage developments to follow the principles of local living. Understanding Our Local Places Climate X Change and Ramboll 20 Minute Neighbourhoods in a Scottish Context (February 2021) The Climate X Change and Ramboll research is incredibly useful in providing a definition of what a 20 minute neighbourhood is within a Scottish context, and outlining what the key elements of such a place are. It establishes a baseline for Scotland at a national scale, to allow us to see how close the neighbourhoods across the country are to meeting the 20 minute definition. This baseline can also be applied at a local level for our LDP3 local living and 20 minute neighbourhood analysis work. The research work also categorises neighbourhoods using residential densities from the Urban Rural Classification, to allow for the development of recommendations that can be applied to the different types of urban and rural areas, which provides a helpful framework for application via our LDP3 approach. Local Living and 20 Minute Neighbourhoods: Planning Guidance (April 2024) The Scottish Government’s Planning Guidance on the subject is helpful in setting out a framework within which our work on identifying Local Living and 20 Minute Neighbourhoods across Perth and Kinross can be developed. To date, we have not started our work on developing a methodology to help us identify what Local Living and 20 Minute Neighbourhoods will look like within the context of the Perth and Kinross Council Area. This will be developed prior to developing our Proposed Plan and will use data and information gathered on our places through our Settlement Audit work to inform the outcomes i.e. the identification of our ‘Local Living’ places or networks of places, as appropriate.
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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, 5 and 7 in particular should be delivered through implementing NPF4 Policy 15. 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. Perth and Kinross LDP2 Infrastructure Capacity Studies (2017), PKC LDP3 Big Place Conversation, Perth and Kinross Council LDP2 Design Charettes, Perth and Kinross Local Action Plans, Community Action Plans, Scottish Index of Multiple Deprivation (2020), and Perth and Kinross Council Ward Profiles (2022) The SIMD data, capacity audits, ward profiles, feedback received during engagement events, and our community led documents provide an important source of information about our places, not only relating to their key socio-economic characteristics, but also an understanding of the issues and challenges faced by our communities, and their aspirations for the future of their places. It is important that these characteristics, along with relevant environmental, physical, heritage, and socio-economic characteristics are taken account of and reflected through the development of the Spatial Strategy for LDP3, to help support the identification of local living and 20 minute neighbourhoods across the Perth and Kinross Area. Perth and Kinross Community Plan (Local Outcomes Improvement Plan) 2022-32 Although there are no specific actions in the Community Plan attributed to the Local Development Plan, there are actions which LDP3 and the land use planning system can help support the coordinated delivery of, such as: enhancing sustainable and active travel connections via new developments; improving the quality and provision of green and blue infrastructure (including open spaces, community allotments, natural water management solutions etc.); identifying housing and employment
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land in sustainable locations, and facilitating the delivery of quality energy efficient homes in a range of tenures. The Perth City Plan 2015-2035, PKC Placemaking Programme, and Invest in Perth: Smart Investing Now and for the Future Perth Cycle Network Masterplan The Perth City Plan, Placemaking Programme, and the Invest In Perth document provide the framework for the future growth and development of Perth. They include details on strategic themes and ‘Big Moves’, as well as investment opportunities, which should be reflected in LDP3’s Spatial Strategy for the City. The aspirations of and any detailed projects and proposals contained within the Perth Cycle Network Masterplan should be identified in our LDP3. Mobility Strategy and Action Plan The Council’s vision for managing and developing the transport and network access across the area, as set out in the Mobility Strategy, should be carried through into our Proposed Plan. Any detailed projects and proposals contained within the Action Plan should also be reflected in LDP3’s Spatial Strategy to support their delivery. PKC LDP3 Invitation to Create Local Place Plans As required under Section 15A of the Planning Act, the Council invited local communities to prepare local place plans (LPPs). To date, there have been some expressions of interest in preparing an LPP from community bodies within Perth and Kinross, but there are currently no registered LPPs. Any LPPs that are registered with the Council by 31 January 2025 will have the greatest opportunity to be taken into account when preparing our LDP3, as work on preparation of the Proposed LDP3 is programmed to begin in early 2025. However, all submissions will be taken into account at later stages of the plan making process. The Place Principle Scottish Government and COSLA Place Principle (2019) Applying the Place Principle in the development of our LDP3 means that we will need to work collaboratively at all stages with key stakeholders, including key agencies, our communities, landowners, and developers to ensure our Spatial Strategy is coordinated, fit for purpose, and deliverable. Location of Facilities; Sport and Leisure, Arts and Cultural Activities; Childcare Provision and Supporting Lifelong Learning; Visiting Health Services and Clinics, and Social Interaction, and Support and Advice Services Perth and Kinross LDP2 Infrastructure Capacity Studies (2017) Perth and Kinross Council, Map of Public Toilets and Comfort Schemes Scottish Water, Your Water, Your Life - Find My Nearest Tap Perth and Kinross Council List of Water Foutain and Refill Taps PKC Leisure, Sport and Culture Webpage Live Active Website Perth City and Towns Website, Visit Scotland Website and Perth and Kinross Council Culture Strategy (2023-2028) PKC Schools and Learning Webpages University of the Highlands and Islands (UHI) Website Perth and Kinross Employability Network NHS Inform Scotland’s Service Directory
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Your Community PK Website The above data sources provide useful information of the location of different facilities and services across Perth and Kinross which can be fed into the LDP3 Settlement Audit and Local Living and 20 Minute Neighbourhoods work to build an understanding of how well our places are currently performing in terms the Local Living and 20 Minute Neighbourhoods concept. Statements Regarding Public Conveniences and Water Refill Locations Sections 15(2A) and (2B) of The Town and Country Planning (Scotland) Act 1997, as amended by the 2019 Act requires planning authorities to provide statements of the planning authority’s policies and proposals as to the provision of public conveniences and water refill locations. In relation to public conveniences, whilst the provision of public toilets is not a statutory function, it is recognised that in an area like Perth and Kinross (PKC), which benefits from a thriving tourist industry, it is preferrable to have facilities available. This has been reflected through historic committee papers and budgetary decisions throughout the years. Currently, a review of PKC run facilities and provision is being planned. In the interim, until that review has been conducted, the Council operates 7 public toilets (a mixture of attended and unattended), a further 1 is provided for public use through a community development trust, and PKC also runs a ‘Comfort Scheme’ with facilities available to the public to use at no cost at 32 partnership venues across the area. With regard to water refill locations, Perth and Kinross Council manages and maintains a long list of water stations across the Plan Area. The majority of these points are located within premises operated by the Council, such as education and community facilities, and access to them is limited to users and staff associated with these locations. Whilst the current provision is considered to cater for the needs of users of public premises, the Council will keep under review the requirement for the provision of additional water points in locations where an identified need is demonstrated. Gaps, Uncertainties or Key Issues Raised: Despite some time having elapsed since our Infrastructure Capacity Studies, Design Charette reports and Ward Profiles were produced, their content still provides a good source of information on the assets, facilities and services offered in our places, along with the community’s views of their local assets, their aspirations, vision for the future of their place, and areas identified for improvement. Any data or statistics contained within them which has since been updated will be reviewed as part of the LDP3 Settlement Audit work. The Audit will also consider if progress has been made against the key issues and actions identified, and how those issues and actions compare to the feedback gathered through the Big Place Conversation. LDP2 Infrastructure Capacity Studies were only carried out for the larger settlements within Perth and Kinross. However, our Settlement Audit work for LDP3 will consider all settlements across the area.
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SIMD data zones in rural areas tend to cover a large land area and reflect a more mixed picture of people experiencing different levels of deprivation. This means that SIMD is less helpful at identifying the smaller pockets of deprivation found in more rural areas, compared to the larger pockets found in urban areas. SIMD domain indicators can still be useful in rural areas if analysed separately from urban data zones or combined with other data. Given the rural nature of much of Perth and Kinross, it will be important to keep this limitation in mind when considering rural areas as part of our Local Living and 20 Minute Neighbourhoods analysis work. It is planned as part of the Settlement Audit work for LDP3 to develop a Localities Profile template which will set out those factors which officers need to take account of in developing their understanding of each place and its needs to satisfy the requirements of the Planning Act, Regulations, LDP Guidance and NPF4 policies. This should also help inform work on Local Living and 20 Minute Neighbourhoods required under NPF4 Policy 15. The template has yet to be developed but will be in place prior to work beginning on the Proposed Plan. The data included in the Scottish Living Locally Data Portal utilises sources produced between 2020 and 2022. While the majority of facilities and services mapped are likely to still be available, public transport provision has changed significantly in recent years. The indicators of access to public transport networks and high frequency services can offer a good understanding of the connectivity available for local residents but would benefit from more recent data to enhance the accuracy of assessments. The Scottish Living Locally Data Portal utilises the same data zones as the SIMD. While they provide a helpful framework to understand access to services within urban and semi-urban settlements, the SLLDP offers limited information for rural areas. The development of 20 Minute Neighbourhood assessment methodologies will need to take into account these limitations. Currently, not all of the information regarding the facilities and services on offer in our communities is currently mapped in GIS. This will require to be carried out as part of our LDP3 Settlement Audit work to allow for analysis in terms of local living and 20 minute neighbourhoods to be undertaken. With regard to the Council’s list of public toilets, there is the intention to undertake a future review of the provision of these facilities. However, there is no timeframe currently for when such a review will be carried out. Summary of Stakeholder Engagement: The Big Place Conversation (BPC) is the main consultation exercise undertaken by PKC in support of their LDP process. It took place in 2023 and created opportunities to engage with communities across the local authority, as well as a variety of minorities and interest groups. Input received through the consultation has been collated in the BPC results page. This section includes summaries for individual community councils and wards, as well as overall reporting with council-wide findings. The BPC follows the Place Standard methodology, which aligns with the principles used to shape the Local Living Framework as shown in the Scottish Government Planning Guidance: Local living and 20 minute neighbourhoods. The summary of results document for the whole of the council provides key insights on how local communities perceive the facilities and services available to them. While it is recommended to consult the summary documents for each ward or community council for
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more detail, responses to the BPC questionnaire highlighted some overall points of consideration: • Public spaces and key public buildings are often seen to be a positive contribution to the character of local communities, supporting interaction. However, some respondents showed concern about the condition of some of these assets, and the recent closure of community premises that reduces opportunities to socialise. • Natural and green spaces are highly valued by a majority of respondents. The presence of quality landscapes and enclaves enhances the sense of belonging and encourages physical activity. Some responses consider there are areas without access to these green spaces, and others point at excessive levels of noise from nearby traffic as a deterrent for users of those natural spaces. • Places for play and recreation are widely perceived as accessible to local communities, with a range of activities and clubs that encourage people of all ages to engage with their local community. However, rural areas are seen as underserved in this regard, creating the need to travel to access those premises. Also, some age groups appear to have fewer options available. • Responses regarding the level of facilities and services available locally offered a range of views. Towns and some villages seem to enjoy a sufficient level of everyday shopping options, but respondents highlighted in many areas it is necessary to travel to larger settlements to address essential needs. • Primary healthcare and dental services appear to offer limited access, with most areas commenting on the lack of provision or the shortage of resources to offer sufficient appointments to local residents. • The provision of digital connectivity was mentioned by several areas as a concern. Broadband and mobile networks fail to offer a sufficient service, with reliability and speed issues that restrict the ability of local residents to work remotely. • Some areas considered primary and secondary education provision needs reinforced. • Public transport services were perceived as an important area for improvement, specially in rural areas. The lack of reliable and frequent services restricts access to local communities, increasing the reliance on the private car. • Towns and villages were seen as unwelcoming for people walking, wheeling and cycling. The volume and speed of road vehicle traffic discourages the uptake of active travel for shorter journeys, with a lack of dedicated infrastructure making it less accessible for the majority of the public. • Most areas highlighted the need to commute to work, with limited options for local employment and a lack of opportunities for professional jobs. Villages and some neighbourhoods in Perth were seen to lack variety in the available jobs, with hospitality, agriculture or retail dominating the offer of specific places. In addition to the input received through the BPC exercise, the Council carried out a consultation of the Topic Papers for individual subject matters of NPF4’s national planning policies suite. The comments received
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on Topic Paper 019: Local Living and 20 Minute Neighbourhoods, 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.
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Statements of Agreement/ Dispute During the stakeholder engagement exercise following the topic paper stage, 17 responses were received for the Local Living and 20 Minute Neighbourhoods section. 6 responses neither agreed or disagreed with the list of evidence evaluated or the summary of implications for the Proposed Plan provided. 4 agreed, and 7 disagreed with some of the content of the topic paper. Of these, 2 wished to register their comments as a formal dispute to the Evidence Report. A summary of these comments, their status and the Council’s response is shown in the following 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 and summary of Implications for Proposed Plan (PP): No to 20 minute cities. People do not want to live in a 20 minute city. No members of the public ever voted for these smart cities. Further Comments: No further comments made. Formal Dispute: No PKC welcomes the respondent’s comments and responds that the 20 Minute Neighbourhoods policy is a national mandate as set in NPF4. Local authorities are expected to develop policies that enable sustainable land uses and deliver liveable places. These national objectives are drawn under the spatial principle that the Plan will support local liveability and improve community health and wellbeing by ensuring people can easily access services, greenspace, learning, work and leisure locally. Local living and 20 minute neighbourhoods are one of the measures that the Scottish Government is promoting to meet the terms of a range of national commitments. These include, amongst others, the climate Change Plan, the Just Transition
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Respondent Agree or Dispute Summary of Comments PKC’s Response Plans and the National Transport Strategy. As a policy informing local development, local living concepts aim to limit the use of additional land for development. This contributes to the protection of the greenbelt, and the creation of local communities that feel connected, resilient and accessible to all. One of the immediate impacts that successful local neighbourhoods bring is a reduction in the reliance of the private car. This is not only a desirable outcome from an environmental point of view, but one that delivers more equitable and affordable communities for all users. Errol Community Council Dispute List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): Notwithstanding the fact that the Local Action Plans mentioned at paragraph 1.54 require to be updated, we do not consider that it is appropriate for Errol Community Council area and the Carse of Gowrie as a whole to be part of Eastern Perthshire and consider that we would be better aligned with Bridge of Earn. We do not consider that the evidence is up to date or particularly relevant. Further Comments: We are working and intent to submit an Local Place Plan for Consideration. PKC welcomes the feedback, and comments that the areas shown in the Local Action Plans follow a grouping aiming to reduce the number of areas, enhancing the effectiveness of the document. However, this grouping will not influence the development of local living and 20 minute neighbourhoods policy. While LAPs also aim to support local communities with identified
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: Yes, the respondent wishes for their comments to be registered as a formal dispute to the Evidence Report. issues, they tackle concepts in an area-wide manner. In contrast, local living and 20 minute neighbourhoods work to identify how land use can be optimised to enable development and services that benefit a local without the need to travel. These solutions are more focused in a specific settlement or site. As a consequence, the previous geographic division of the territory of PKC will not shape the definition of localised improvements. The rationale behind the concept is to shape communities that reduce the distance between residents and the services and facilities they need. While it is understood that villages and rural areas often lack those services within the same settlement, the delivery of local living solutions for rural communities will still aim to create networks that support residents and reduce the need to travel as much as possible. Nature Scot Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): It is useful to see the key policy connections on page 7. We welcome the inclusion of blue- green infrastructure and open spaces in this topic paper. Further Comments: No further comments made. PKC welcomes the comments and agrees on the importance of considering blue and green infrastructure when designing local living policies.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: No Tactran Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): Tactran refers to its comment in relation to sustainable travel and quality of places above and further notes that it is important to establish the risks to the viability of communities, such as risk of transport poverty. Tactran notes that the successful implementation of the local living / 20-minute neighbourhood concept depends on the provision of local facilities and services. Further Comments: No further comments made. Formal Dispute: No PKC welcomes Tactran’s comments and agrees on the need to encourage the presence of local facilities and services to create successful local places. Perth and Kinross Council – Transport Planning Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): The Mobility Strategy also acknowledges that a rural counterpart to the 20-minute neighbourhood is required. Our community engagement and consultations highlighted that rural isolation is a significant risk and that many residents, even if they are able to access goods and services locally, are at risk of social isolation that impacts on their health and wellbeing. We thus welcome a LDP response that supports rural communities to identify what the 20- minute neighbourhood equivalent would look like to be able to support their needs. Strategic Actions 75 and 111 of the Mobility Strategy have reference: Action 111: Deliver connected neighbourhoods within towns and cities to better achieve connected and more accessible communities following the 20-minute neighbourhood concept, so that as many people as possible can meet the majority of their daily needs within a reasonable walk, wheel or cycle of their home. Action 159: Develop a rural approach/equivalent to the 20-minute neighbourhood concept in and around PKC welcomes the comments received from the transport planning team and agrees on the need to consider interventions tailored to rural areas. NPF4 outlines the expectation for LDPs to support 20 minute neighbourhoods within settlements, taking into account the local context. Local living interventions in rural areas will need to acknowledge the challenges of each place, and enable solutions that promote robust communities. The planning policy team will engage with the transport planning team during the process to shape a suitable policy for rural areas.
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Respondent Agree or Dispute Summary of Comments PKC’s Response villages and towns to enhance local accessibility, help tackle societal causes of inequality, and reduce social isolation and loneliness. Further Comments: No further comments made. Formal Dispute: No Homes for Scotland Agree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): . Further Comments: No further comments made. Formal Dispute: Not applicable. Homes for Scotland Disagree, but does not wish to register as a formal dispute List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): The socio-economic benefits of home building cannot be understated. Our 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. It is positive to see the Topic Paper recognises Scotland’s diversity, and that flexibility will be required in terms of applying the concept to different geographies and that 20 minute neighbourhoods may not always be achievable in remote rural areas. The 20 minute neighbourhood principle must be capable of being applied flexibly taking into account local context and with discretionary decision-making powers depending on wider social, economic and environmental benefits. PKC welcomes Homes for Scotland’s feedback and agrees on the important role that housebuilders play in the delivery of infrastructure and the creation of communities and neighbourhoods. The next stages of the plan process will include consistent collaboration with key stakeholders as described. With regards to local living outside of urban spaces, PKC would like to refer to the response to PKC’s transport planning team regarding the need to develop suitable local living solutions in rural areas. We agree the 20 minute neighbourhood concept might not be achievable in some rural areas.
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Respondent Agree or Dispute Summary of Comments PKC’s Response It is discussed in the Topic Paper how 20 minute neighbourhoods are one of the ways in which local living can be delivered within appropriate locations in Perth and Kinross. It should be noted that larger-scale housing developments, by way of the integration of mixed uses, may be able to create new 20 minute neighbourhoods which would be compliant with National Planning Framework (NPF) 4 aspirations. The Topic Paper considers the implementation of the Local Living and 20 Minute Neighbourhoods approach and how it will be adjusted in the more rural areas of the region. However, to do this sustainably requires improvements across a number of fronts – from home/hybrid working facilities, to the quality and frequency of public transport, to safe cycling and walking connections between villages where distances are close enough. HFS members can assist with this through their developments. The housing layout may enhance connectivity by incorporating active travel links and provide passive surveillance. Furthermore, new homes are also generally fibre enabled ensuring that the homeowner has the ability to work from home reducing the need to travel. Further Comments: It is not specified in the draft Topic Paper whether the Council will provide a proportion of their Local Housing Land Requirement (LHLR) in town centres. Whilst Homes for Scotland (HFS) does not disagree with the notion of allocating sites for residential development within town centres, this should not be at the expense of placemaking principles, nor viability factors. A balanced approach is In that regard, we refer to Policy 15 within NPF4. This policy promotes the use of local living arrangements, with the use of 20 minute neighbourhood where relevant. It is expected for LDPs to assess the local context and provide an environment conducive of successful local living for communities. With regards to the role of housing developers in the delivery of infrastructure and services, we agree on the potential for collaboration to achieve developments that facilitate connectivity and support modern living arrangements. The LDP will give consideration to a variety of settings to accommodate development. Town centre housing is a desirable development to revitalise our urban spaces. While there is an opportunity to collaborate with developers in achieving viable solutions, the allocation of sites and the assessment of these opportunities will take place in the next stages of the plan. Consequently, it is unclear at Evidence Report stage
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Respondent Agree or Dispute Summary of Comments PKC’s Response required. If the Local Development Plan (LDP) is to identify a proportion of the LHLR in town centres, then any site needs to be available and deliverable and if policy interventions are required (such as a compulsory purchase order) then these should be set out at the outset. It is positive to see the Topic Paper refer to deliverability in terms of the spatial strategy and that the Council plan to work collaboratively at all stages with key stakeholders, including key agencies, communities, landowners, and developers to ensure this. Formal Dispute: No, the respondent does not wish to register their comments as a formal dispute to the Evidence Report. whether specific locations will be brought forward. Montagu Evans on behalf of Loch Developments Ltd Agree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): The allocation and the subsequent development of the former BCA site in Kinross will contribute to the enhancement of the 20 minute neighbourhood by providing new homes, new retail uses and better connectivity with the wider community to Loch Leven, and the existing settlement through vehicular and active travel routes. Further Comments: No further comments made. Formal Dispute: Not applicable. PKC welcomes the respondent’s feedback and agrees on the potential for brownfield sites to accommodate future development. It would be however imprudent to discuss the suitability of a site prior to carrying out a formal assessment. With regards to the consideration of specific sites, we refer to the Call for Ideas and Sites stage of the plan, which is due to start during Q2 2025. Scottish Water Agree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments made. Further Comments: The Scottish Water acknowledges the contents of Topic Paper No. 019: Local Living and 20 Minute Neighbourhoods and is supportive of high level principles set out. At this stage, Scottish Water has no further comments to PKC welcomes Scottish Water’s comments and agrees on the need for future collaboration to plan development and communities.
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Respondent Agree or Dispute Summary of Comments PKC’s Response make and will continue to work closely with Perth and Kinross Council to support Local Living and place based design principles in future planning of communities. Formal Dispute: Not applicable. Avison Young on behalf of Aldi Stores Ltd. Disagree, but does not wish to register as formal dispute List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): The report that has been produced appears to be a plan of how to prepare an evidence report rather than an evidence report itself. For example, paragraph 1.82 refers to the production of LDP3 Settlement Audits in future. We consider that the evidence report should have included those documents already so that there would be an opportunity to comment on them. We note that paragraph 79 of the Local Development Planning guidance states "it should provide a summary of what the evidence means for the plan." This appears to be missing from the document and we therefore consider the evidence report to be lacking in sufficient detail to enable a response on its adequacy. Further Comments: No further comments made. Formal Dispute: No, respondent does not wish to register comments as a formal dispute to the Evidence Report. PKC welcomes the respondent’s feedback and would like to clarify that Settlement Audits were always scheduled to take place after Evidence Report gatecheck review. With regards to the stakeholder engagement exercise, topic papers were made available as a summary of data sources that PKC considered could inform the content of the Evidence Report. The aim was to consult on the adequacy of those sources, and for stakeholders to suggest additional sources that they deem relevant. The implications for the plan are introduced in this Evidence Report chapter. A.S Associates Ltd Planning and Architectural Services Disagree, but does not wish to register as a formal dispute List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): Section: Gaps, Uncertainties, and Key Issues Raised, Paragraph 1.81 Appendix A Table A1 Reference is made to 'Settlement Audit' work and 'Site Appraisal' templates in relation to considering 'Local Living and 20 Minute Neighbourhoods' analysis. It is not clear what PKC welcomes the respondent’s comment and wishes to respond in two parts. Firstly, in line with the Scottish Government’s LDP Guidance (May 2023) paragraph 108, PKC have not considered any detailed policies or site proposals at the Evidence Report stage. There will be a ‘Call
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Respondent Agree or Dispute Summary of Comments PKC’s Response datasets will provide evidence for this audit and appraisal work. The audit/appraisal of settlements should include reference to the planning history of land around settlements, including small-scale proposals that have implications for alteration to settlement boundaries. We suggest that an essential dataset is the mapped register of planning applications and its associated case file information. In addition, historic information relating to submissions from landowners/agents for land to be considered for allocation in the Local Development Plan should also provide essential evidence. As an example, we highlight our client's history of applications at Sunnybrae, Windsole, Auchterarder, including most recently the refusal of application 21/01744/IPL The Report of Handling for that application states 'If the applicant does wish to pursue development on this site, the most appropriate means to do so would be seek for an alteration of the settlement boundary through review of the Local Development Plan.' We subsequently submitted a request to the Development Plan Team for our client's site to be considered in the preparation of LDP3. Further Comments: No further comments made. Formal Dispute: No for Sites’ or similar exercise following on from the publication of the Evidence Report for our LDP3. The Council will carry this representation forward for consideration at a later date as part of the consideration of proposals and potential review of settlement boundaries exercises. Secondly, the Site Appraisal template that we propose to use as part of this exercise is included in an annex to this Evidence Report and is the agreed ‘Local Development Plan: Site Assessment and SEA Checklist’ template developed by the Consultation Authorities and dated 6th February 2024. The Settlement Audit template is noted as an existing evidence gap in this Evidence Report as we have not had the capacity to develop it to date. In developing our template we will draw on all place-based evidence sources we have, and which have been identified in this Evidence Report in order to meet the requirements and expectations of the national suite of planning policies included in NPF4.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Gray Planning & Development Ltd on behalf of GS Brown Construction Ltd Disagree, but does not wish to register as a formal dispute List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): It is noted that to date no formal Local Place Plans (LPPs) have been registered by PKC (topic paper para 1.57). How are developers and landowners expecting to produce new neighbourhood proposals without the LPPs where it is likely that the intent of LPPs (through legislation and guidance) feeds into site identification and assessment for new LDPs? Further Comments: No further comments made. Formal Dispute: No PKC welcomes the respondent’s feedback, and would like to clarify the non-statutory nature of LPPs. Paragraph 5 and Annex B of the Local Development Planning guidance clarify the role of LPPs in the LDP process, and the roles that communities and local authorities can play in their development. Annex B, paragraph 3 outlines the expectation for local authorities to invite communities to prepare LPPs. PKC has met these requirements and actively engaged with community groups, as summarised in the topic paper. At the time of writing this Evidence Report chapter, no LPPs had yet been submitted. The guidance also clarifies that, while LPPs can maximise their impact if they are submitted prior to the Evidence Report stage, they will be taken into account in the preparation of the LDP whenever they are registered (Annex B, paragraph 9). The role of local authorities in the LPP process is to invite and assist where necessary. However, the creation of the LPP itself, including
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Respondent Agree or Dispute Summary of Comments PKC’s Response mapping, proposals and key local concerns, lies with the community group. It is therefore possible for the Evidence Report to be built without the content of LPPs being made available. Likewise, while LPPs could inform site assessment stages, they are not the only consideration. For areas where no valid LPP is submitted, PKC will carry out the assessment of proposed sites through the agreed methodology. Private individual Dispute List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): The 20 minute travel fails to address community, social and family friends and family activity, and mental well being in regularly connecting with these activities Further Comments: No further comments made. Formal Dispute: The respondent wishes to register their comments as a formal dispute to the Evidence Report on the grounds that 20 minute travel fails to address community, social and family friends and family activity, and the mental well being in regularly connecting with these activities. PKC welcomes the comments, and agrees on the importance of social connections. However, it disagrees on the absence of social connection within 20 minute neighbourhood and local living concepts. Policy 15 of NPF4 introduces the support to the delivery of local living arrangements and 20 minute neighbourhoods where relevant. While the majority of this policy refers to the delivery of infrastructure, facilities and services, these needs are underpinned by the value of human connection and interaction with the local community. The infrastructure needs outlined in
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Respondent Agree or Dispute Summary of Comments PKC’s Response policy 15 point at the importance of social contact, referring to informal play opportunities, open spaces and community facilities. The concept is further developed in the report Understanding the 20 Minute Neighbourhood: Making opportunities for people to live well locally (AlWaer and Cooper, 2024). The document highlights one of the aims of 20 minute neighbourhoods is ‘creating an improved sense of community, where people can get to know one another and work together to improve their neighbourhood’. The use of local living principles and more walkable environments are considered conducive of better social interactions, with stronger communities and higher levels of participation and trust. The ethos of local living initiatives is to deliver more attractive places where every aspect of the built environment that can provide comfort, convenience and foster connections with others is acknowledged and supported. Kinross-shire Civic Trust Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments made. PKC welcomes the respondent’s feedback, and comments that the development of local living and 20
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Respondent Agree or Dispute Summary of Comments PKC’s Response Further Comments: The graphs in Topic Paper 028: Rural Development and Homes show significant commuting from Kinross to Perth, Fife and Edinburgh. Topic Paper 004: The Climate and Nature Crises (p. 12) quotes the six principles of NPF4 that should form the basis of an LDP spatial strategy. Number 3 is Local living - "We will support local liveabiity and improve community health and wellbeing by ensuring people can easily access services, greenspace, learning, work and leisure locally." There is very little work locally in Kinross/Milnathort. In terms of services, it is takes a long time to obtain a doctor's appointment and there are no NHS dentists in the county of Kinross-shire. Formal Dispute: No minute neighbourhood policies will aim to identify existing shortcomings in infrastructure and opportunities. This type of feedback is valuable to understand local concerns. Earn Community Council Agree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments made. Further Comments: The definition of “20-minute neighbourhoods” seems to relate to Perth and large settlements, and mentions walking, wheeling and cycling. Round trip is mentioned elsewhere P. 5. Again, nothing in relation to the elderly. Public transport is mentioned in relation to other areas where “Local Living” approach is the alternative, with sustainable transport options. We need to emphasise the need for better rural transport link ups, and the encouragement of community involvement, eg. Glenfarg Bus initiative. No Ward Profile available. Link in Topic 019 1.58 P. 23 not working. Much needed Large P&R for Bridge of Earn given the great success of Ember Bus Service Dundee - Edinburgh. LPP's Pg 22 1.56/1.57 - More information on LPP's required to be shared with community bodies. PKC welcomes the comments, and agrees on the importance of providing local living solutions that include all age ranges. The concept of 20 minute neighbourhoods, or the local living arrangement as applicable, presents a framework for decision making that prioritises the creation of settlements that reduce the reliance on the private car. Amongst other benefits, this aims to deliver places accessible to all, including young people and the elderly. The report Understanding the 20 Minute Neighbourhood: Making opportunities for people to live well locally (AlWaer and Cooper, 2024) highlights that more
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: Not applicable. walkable environments enable independent mobility and support a more active lifestyle for older people. The delivery of local living interventions will be sympathetic with the characteristics of individual communities. While the concept highlights the value of walking and cycling as a way to reinforce social contact, public transport solutions also play a vital role in the creation Savills on behalf of Dupplin Estate Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): We note that the Topic Paper cites the Government's guidance and the fact that 20 minute neighbourhoods must recognise the character of place and be flexible to different geographies. This is absolutely critical. A rigid adherence to the 20 minute neighbourhood concept can be counter-productive and frustrate otherwise appropriate development proposals. NPF4 is designed to be "read and applied as a whole" and "Factors for and against development will be weighed up in the balance of planning judgement" (Chief Planners Letter 8 February 2023: Transitional Arrangements for National Planning Framework 4). The importance of infrastructure at the outset of larger developments cannot be overstated. Perth West is designed around the Placemaking Principles of the 20 minute neighbourhood but this is reliant on the co-development of employment land and an integrated public transport system. PKC welcomes the respondent’s comments, and agrees on the importance for local living interventions to adapt to the characteristics of a location. The assessment of development proposals will be cognisant of the environment, and identify the existing provision of facilities and services to understand how any new development is likely to impact the local area. Where possible, masterplans and development layouts will be used to create mixed use, well- connected environments. PKC would like to clarify that local living solutions are not solely to be
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Respondent Agree or Dispute Summary of Comments PKC’s Response Further Comments: No further comments made. Formal Dispute: No delivered as 20 minute neighbourhoods. It is understood that some areas do not have the population density or the facilities to support the standard of connectivity associated with 20 minute neighbourhoods. Future stages of the development plan process will include a methodology that supports suitable options for these areas. Savills on behalf of Scone Estate Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): We also note the Draft Mobility Strategy looks to improve access to rural areas. We consider there should be focus on improving settlement and rural area 20 minute potential using development to facilitate this. Areas should not be written off because they may not have particular services at the time of LDP site allocation/adoption. There is reference within the Topic Paper to the fact that work on identifying 20-minute neighbourhoods has not yet commenced. Our 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 services. They should avoid a slavish adherence to 20-minute neighbourhoods and blanket restrictions on development being based on current services only. The sustainability of rural areas is dependant 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. PKC welcomes the feedback, and comments that 20 minute neighbourhood and local living concepts are understood as a framework for placemaking and development. The assessment of NPF4 policies will take place using a balanced approach, where local living aspirations are combined with other objectives. While the methodology for the development of local living policies is still to be confirmed, it is reasonable to expect that proposed developments that deliver improvements to the local provision of facilities and services will be well received.
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Respondent Agree or Dispute Summary of Comments PKC’s Response 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. Further Comments: No further comments made. Formal Dispute: No
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Issue: Blue and Green Infrastructure Corresponding NPF4 Policy/Policies: NPF4 Policy 20 – Blue and Green Infrastructure Policy Connections: o 1: Tackling the climate and nature crises o 2: Climate mitigation and enhancement o 3: Biodiversity o 4: Natural places o 5: Soils o 6: Forestry, Woodland and Trees o 7: Historic assets and places o 8: Green belts o 13: Sustainable Transport o 14: Design, Quality and Place o 15: Local Living and 20 Minute Neighbourhoods o 16: Quality homes o 18: Infrastructure first o 19: Heating and cooling o 21: Play, Recreation and Sport o 22: Flood Risk and Water Management o 23: Health and safety o 27: City, town, local and commercial centres o 29: Rural development Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 021: Blue and Green Infrastructure Information required by the Act and NPF4 regarding the topic: Town and Country Planning (Scotland) Act 1997 In line with the requirements of the Act, this paper will have regard to: Section 15(5) of The Town and Country Planning (Scotland) Act 1997, as amended, which requires Local Authorities to consider: • The principal physical, social and environmental characteristics of the district • And the principal purposes for which the land is used. Open Space Audit and Strategy Regulation 9 of The Town and Country Planning (Development Planning) (Scotland) Regulations 2023 requires planning authorities to have regard to any Open Space Strategy (OSS) published under Section 3G (3) of the 1997 Act. The OSS is to set out a strategic framework of the planning authority’s policies and proposals as to the development, maintenance and use of green infrastructure in their district, including open space and green networks. Section 3G of the Act requires an audit of existing open space provision and an assessment of current and future requirements along with any other matter the planning authority considers appropriate. NPF4 Policy 20 of National Planning Framework 4 (NPF4) expects LDPs to: • be informed by relevant, up-to date audits and/or strategies, covering the multiple functions and benefits of blue and green infrastructure • identify and protect blue and green infrastructure assets and networks
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• enhance and expand existing provision including new blue and/or green infrastructure. This may include retrofitting. • identify priorities for connectivity to other blue and/or green infrastructure assets, including to address cross-boundary needs and opportunities, should also be identified. • encourage the permanent or temporary use of unused or under-used land as green infrastructure. Where this is temporary, this should not prevent future development potential from being realised. • safeguard access rights and core paths, including active travel routes, and encourage new and enhanced opportunities for access linked to wider networks. Local Development Plan Guidance Scottish Government (2023) Local Development Planning Guidance (p.134) specifically states: “NPF4 policy 20 recognises blue and green infrastructure as an integral part of early design and development processes. The policy also encourages the design of multifunctional BGIs to deliver benefits including climate mitigation, nature restoration, biodiversity enhancement, flood prevention and water management; as well as providing opportunities for play, recreation and sport where they are accessible. The design should be consistent with the six qualities of successful places. The spatial strategy should identify opportunities for new, enhanced or improved provision of blue and green infrastructure, or improved access to green and blue spaces, taking account of the areas that can best contribute to enhancing and delivering key green networks and priorities. Plans may identify land that could be used for localised, temporary greening and/or community food production, including community growing spaces, especially in urban areas.”
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Links to Evidence: General • Scotland’s Environment Web • SEPA – Environmental Data • NatureScot – Open Data Hub • Scottish Wildlife Trust – Open Data Hub • Improvement Service – Spatial Hub • Scottish Government – Spatial Data Portal • PKC – Open Data • PKC – LDP2 Webmap • Scotland 2022 Landcover Map • Scotland’s Wetland Inventory • Scottish Index of Multiple Deprivation Audits, Policy and Strategy • PKC (DRAFT) – Open Space Quality Audit • PKC – Green and Blue Infrastructure Supplementary Guidance • PKC – Open Space Provision for New Developments Supplementary Guidance • PKC – Forest and Woodland Strategy • PKC – Food Growing Strategy • PKC – Climate Change Projections Map • PKC – Perth Integrated Catchment Study • Scottish Government – Surface Water Management Planning Guidance (2018) • Scottish Government – Water-Resilient Places • PKC – Mobility Strategy and Action Plan • PKC – Active Travel Strategy Woodland • Ancient Woodland Inventory • Ancient Tree Inventory • National Forest Inventory • Native Woodland Survey of Scotland • Riparian Woodland Scotland Designated and Protected Sites • Cairngorms National Park • Loch Lomond and the Trossachs National Park • National Nature Reserves • National Scenic Areas • RAMSAR Sites • Special Areas of Conservation • Special Protection Areas • Sites of Special Scientific Interests • Scottish Wildlife Trust Reserves • Gardens and Designed Landscapes • PKC – Tree Preservation Orders • PKC – Air Quality Management Areas Existing Greenspace Areas • PKC – Maintained Open Space • PKC – Major Parks • PKC – Parks Countryside Sites
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• PKC – LDP2 Designated Open Space • OS – MasterMap Greenspace Water Environment • OS – MasterMap Water Network • SEPA – Recommended Riparian Buffer • SEPA – Riparian Vegetation Planting Opportunities • SEPA – Obstacles to Fish Migration • SEPA – Water Environment Hub • SEPA – Water Classification Hub • PKC (Internal Shapefile) – Sustainable Urban Drainage Systems Flooding and Geomorphic Risk • SEPA – Surface Water Flood Risk • SEPA – River Flood Risk • SEPA – Coastal Flood Risk • SEPA – Geomorphic Flood Risk • SEPA – Natural Flood Management Maps • PKC – Strategic Flood Risk Assessment (add core document reference) • PKC – Surface Water Management Plans o Milnathort SWMP (add core document reference) o Blairgowrie & Rattray (ongoing) o Perth (ongoing) o South Kinross, Aberfeldy, Comrie and Scone (programmed completion within next 24 months) • PKC – Natural Flood Management Studies o Aberfeldy (add core document reference) o Blackford (add core document reference) o Alyth (add core document reference) o Invergowrie FPS and Flood Study Report (add core document reference) o Comrie NFM within the Flood Protection scheme feasibility report (add core document reference) o South Kinross (add core document reference) Active Travel Network • PKC – Adopted Core Paths • PKC – Signposted Paths • PKC – Rights of Way • PKC (Internal Shapefile) – Future Potential Routes (for footpaths) • Sustrans – National Cycle Routes • Sustrans – National Cycle Network Link • Sustrans – Regional cycle Routes • Sustrans (Internal Shapefile) – Green Routes • Ramblers – Path Network Scotland • Tactran – Regional Active Travel Network • PKC – Perth Cycle Network Masterplan • Neighbouring Authorities Datasets: o Core Paths – Scotland • Specific Routes: o Cateran Trail o Loch Leven Heritage Trail o Crieff to Comrie (Pilgrim’s Way)
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o Crook of Devon to Kinross via Balado Opportunities for Intervention • PKC – LDP2 Proposals • PKC – Maintained Open Space • PKC – Grow Wild Sites • PKC (Internal Shapefile) – Disused Railway Lines • PKC (Internal Map) – Urban Capacity and Brownfield Study • Vacant and Derelict Land Survey 2022 • SEPA – Water Environment Fund Current and Potential Projects • PKC – Nature Restoration Fund Projects • Perth and Kinross Community Groups and Projects Map • Perth and Kinross Environmental Youth Groups and Projects Map • PKC – Big Place Conversation Results • Local Place Plans
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Summary of Evidence: The evidence noted above provides context and background to identify existing blue and green infrastructure (BGI) of value, which should be protected from development. It also highlights opportunities for enhancing and delivering new infrastructure. The open space audit will establish a baseline for public open spaces and accessibility to them within settlements. Combined with additional ecological data on local biodiversity and habitats, this will form the basis of BGI mapping. Further natural flood management studies and river management plans provide a foundation for BGI interventions that benefit both communities and nature. Vacant land and urban capacity studies could offer opportunities for temporary uses, including community food growing. Active travel data on existing and potential routes, along with community engagement feedback, 20-minute neighbourhood analysis, and PKC’s Mobility Strategy, will underpin the development of active travel networks. When integrated with BGI opportunities, this will identify green networks. Up to Date Audits and Strategies PKC Green & Blue Infrastructure Supplementary Guidance. This guidance supports the delivery of LDP Policy 42: Green Infrastructure by setting out the Council's vision and spatial strategy for blue-green infrastructure. The vision outlined in the document is for: "Green infrastructure across Perth and Kinross will be high quality and multifunctional, allowing the free and easy movement of people and wildlife. It will deliver a wide range of ecosystem services, contributing to climate change adaptation and mitigation and wellbeing." The Strategy is informed by a BGI Audit conducted in 2019 which used an Integrated Green Infrastructure Approach to develop opportunity mapping and identify: • The extent and composition of the existing green and blue network, and • Those areas which provide potential opportunities for protecting, enhancing and connecting the network to promote habitats, access and health, landscape and water management. The Opportunity Map includes: • Strategic habitat and biodiversity opportunities such as protected sites, habitat corridors and woodland areas, using integrated habitat models; • Active travel opportunities focused on access to and through greenspace including parks, open spaces and path networks (e.g. long distance, core and signposted paths); • Water environment opportunities including water quality, flood plains and riparian corridors • Cultural heritage and landscape assets (gardens and designed landscapes) • Council owned and/or maintained assets, growth opportunities and development sites identified in Local Development Plan 2 Due to changes to licencing agreements for the datasets which the Opportunity Map is derived, this is currently only available for internal use. However, the outputs of the audit and mapping are summarised in the supplementary guidance for LDP2 Tiered Settlements and Strategic
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Development Areas (see section 6.4 of the SG). The table below shows which settlements and areas are included: Appendix 1 in the supplementary guidance provides further detail on the methodology and datasets included in the audit. The audit and mapping are currently being updated and will be made publicly available in early 2025. This will inform the preparation of the Open Space Strategy and Settlement Audits for LDP3. It will be made available to communities ahead of engagement planned for the Open Space Strategy development. A Blue-Green Infrastructure Audit Datasets spreadsheet has been submitted with the Evidence Report core documents, referencing the datasets considered in the BGI Audit update for LDP3. Draft Open Space Audit and Strategy. An Open Space Strategy (OSS) is currently being prepared in fulfilment of duties set out in The Planning (Scotland) Act 2019. To inform the preparation of the strategy, an Open Space Audit has been undertaken by the planning department and the results are currently being reviewed by the Council's Community Greenspace team. The Open Space Audit includes an assessment of the quantity, quality, and accessibility of publicly accessible open spaces in the planning authority area. Statements will be provided on a settlement level to identify areas of insufficient provision and/or accessibility of good quality open spaces for the Spatial Strategy. Furthermore, the audit will be used to review LDP2 Open Space Designations, which are the main mechanism for safeguarding open spaces from development. The Open Space Audit has included: • Aggregation of existing greenspace spatial datasets including: LDP2 Designated Open Space, Maintained Open Space, Countryside Sites, and OS Greenspaces • Site visits and quality surveying • Desk-based analysis A quality survey has been conducted for the audit, with site visits carried out for over 500 publicly accessible open spaces within or adjacent to settlements, including all LDP2 designated open spaces. The quality survey includes an assessment of the following criteria for each site: • Typology • Functions • Accessibility • Place Quality • Care and Maintenance • Biodiversity and Habitat Cover
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• Community Use To date, the audit has identified 1,360ha of open space within or adjacent to settlements, of which 704ha are considered publicly accessible and have been surveyed. This data was benchmarked against PKC’s two open space quantity standards outlined in the Open Space Provision for New Developments Supplementary Guidance (2021). Overall, Perth and Kinross exceeds both standards, as shown below: Quantity Standard 1: 80m² of open space per dwelling. With 70,120 residential properties, the provision equates to 100m² per dwelling. Quantity Standard 2: 3.5ha of open space per 1,000 people. Based on an estimated population of 150,800, the provision is 4.67ha per 1,000 people. As the Open Space Audit is still ongoing, only quantity figures have been provided at this time. This audit is expected to be completed in early 2025, after which quality and accessibility statements will be provided. The Open Space Audit and previously reference BGI Audit will form an evidence-base for developing the OSS. The strategy will support the delivery of NPF4 Policies 20 and 21, through the safeguarding, enhancement and improved connectivity of open spaces. This will be prepared in partnership with communities and key stakeholders in 2025, alongside preparation of the Proposed Plan. The Forest and Woodland Strategy (2020) provides information about where and how new woodland and forestry should come forward. This informs the identification of areas appropriate for new green infrastructure particularly outside settlements. The strategy will be updated for LDP3. See Topic Paper 006 for further details. Perth and Kinross Climate Change Risks and Opportunities Assessment (2023) provides information on projected changes to key climate variables across Perth and Kinross, including seasonal variations in temperature, precipitation, wind, snowfall, sea level rise and storm surge. Spatial data has been provided for these variables and will be used to identify future requirements and inform the OSS. Identify and Protect Existing Blue and Green Infrastructure Perth and Kinross is home to a wealth of natural rivers, lochs, and woodland habitats, along with peatland and grassland. Perth, along with our towns and villages, benefit from a range of multifunctional greenspaces and natural corridors. The diagram below shows the output from recent Place Standard engagement (The Big Place Conversation), showing that communities perceive their access to good quality natural spaces as one of the best aspects of living in Perth and Kinross, highlighting the need to protect existing green and blue spaces.
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Natural spaces provide significant ecosystem services that deliver a significant range of benefits for both communities and nature, including those shown in the diagram below. NatureScot: Ecosystem Services – Nature’s Benefits We will use the sources referred to in this section to identify existing blue and green infrastructure and use that knowledge to inform how and where development will come forward. The OS MasterMap Greenspace Layer provides vital geospatial data to support planning, management and research. OS MasterMap Greenspace Layer covers all settlements with a population over 500 people and includes a 500-metre buffer around the settlement. It uses the greenspace typology as set out in Planning Advice Note 65, to categorise all urban greenspaces into 22 different types and provides up to two form and two functional types for each greenspace polygon. This was used to support Green Infrastructure mapping that was used to develop Perth & Kinross (2020) Green infrastructure Supplementary Guidance. This will inform the
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Open Space Strategy which will inform sufficiency of improvements to and linkages of open spaces. Forest and Woodland Strategy (2020). The Forest and Woodland Strategy includes existing woodland and where new woodland is preferred. The strategy will be developed alongside identification of green infrastructure to ensure that development protects and supports important trees and woodland. Other Existing Green Infrastructure. Topic Paper 005 and 006 with regards biodiversity and trees and woodland set out sources for mapping existing green infrastructure in more detail, particularly outside settlements. These will help identify existing green infrastructure which is protected by Policy 20: • Native Woodland Survey of Scotland • Ancient Woodland Inventory • Tree Protection Orders • Ancient Tree Inventory • National Soil Map of Scotland • NatureScot’s Habitat and Land Cover Map of Scotland • NatureScot’s Mountain Woodland Restoration Areas • Existing Restoration Projects LDP2 Designated Open Space. Current open space for nature, recreation and amenity is mapped and designated for protection against development in LDP2. This is currently the key mechanism for protecting open spaces within settlement boundaries from development. Designated sites will be considered and reviewed for LDP3. NPF4 Policies 20 and 21 do not address open space for purposes of amenity, where that may be for residential amenity separation or for landscape purposes. This needs to be considered in both drawing boundaries of settlements or whether a local policy is required for Open Space. OS MasterMap Water Network dataset is a collaborative project between Ordnance Survey, the Environment Agency, and the Scottish Environment Protection Agency that combines detailed data on watercourses across Great Britain. It provides a comprehensive baseline for PKC’s water environment, showing the flow and precise course of rivers, streams, lakes, and canals. SEPA Recommended Riparian Corridor is relevant for required blue-green infrastructure mapping and to inform proposed allocations during the preparation of development plans. The inclusion of this layer in BGI mapping addresses the requirement for identification and protection of BGI assets and infrastructure, as well as identification of opportunities for improvement to the water environment. SEPA Surface Water Flood Risk Layers identify land which may have potential to be part of the blue network. It is considered that the low-risk layer will be the most appropriate one to use, before a climate change surface water risk layer is available. This layer used the medium likelihood flood event with an increase in rainfall intensity of 20% nationally. This layer may provide a first indication of those areas potentially at risk from surface water flooding in the future, however due to projected changes in rainfall intensity it may not show all locations that may be affected in the future. Scotland Wetland Inventory is generated from data supplied to SEPA by NatureScot. The wetland inventory database comprises several 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 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 geographic information system (GIS). However, it will be a useful resource. Enhance and Expand Blue and Green Infrastructure
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Development Enhancement Measures. Blue and Green Infrastructure is protected from harm by development under NPF4 Policy 20(a) and proposals for incorporating new or enhanced BGI is supported by Policy 20(b). The requirement in NPF4 Policy 3 to conserve and enhance biodiversity is expected to contribute to positive measures for blue and green infrastructure. Further information on enhancement beyond site requirements can be found in Topic Paper 005. Open Space Provision for New Developments Supplementary Guidance (2021). This current guidance accompanies LDP2 Policy 14: Open Space Retention and Provision, providing: • The quantity, accessibility and design standards for open space in new developments • Information as to the types of open space required for different scales of development • Conditions for on-site and off-site developer contribution requirements • The mechanisms for the maintenance of open space. The guidance seeks to ensure there is appropriate mitigation for the impact new development has on existing open spaces and determine whether or not new public open space will be required to support the development. Furthermore, the document provides guidance on landscaping and the design of development. It encourages well0connected, high quality open spaces which are designed with long- term maintenance implications in mind. Big Place Conversation Results. During this engagement settlement specific comments were noted and often drawn on maps as to not only where valuable green infrastructure was but where interventions could take place such as natural flood management, increases in tree planting or improvements to green spaces. This information will help inform the open space strategy. Local Place Plans (LPPs) are currently being prepared by community groups across Perth and Kinross. Early conversations with groups indicated that BGI proposals are likely to be included in some LPPs, including proposals for new sites to receive open space designation and safeguarded against development. Furthermore, there are several current Community Action Plans that include ongoing or proposed BGI projects, and these will be considered alongside LPPs. Grow Wild. This campaign is reviewing the way Council managed greenspaces are cut with potential benefits for nature. A survey currently covering the wider Perth area also invites comments on further suggestions for biodiversity improvements as well as food growing suggestions. This feedback will be included within the Open Space Strategy and settlement audits and will help identify opportunities to support valued sites. Other Blue and Green Infrastructure Opportunities. Opportunities exist where there are gaps in existing green infrastructure. The Evidence Report’s Biodiversity chapter also sets out sources for mapping restoration opportunities for the purposes of identifying Nature Networks. Where not included in Nature Networks this data will help identify opportunities for restoring or enhancing green infrastructure: • Investment Ready Projects • Natural Flood Management Studies • SEPA Riparian Vegetation Planting Opportunities • SEPA Obstacles to Fish Migration • SEPA Natural Flood Management mapping • SEPA Geomorphic Risk layer
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• SEPA Water Environment Framework Projects Strategic Flood Risk Assessment (SFRA) considers, identifies, and collates information on natural flood risk management opportunities for all settlements within LDP2. It considers Local Authority Flood Studies to help identify proposed Natural Flood Management and uses the SEPA low surface water flood risk layer and SEPA Natural Flood Management mapping to identify future potential opportunities. SFRA datasets are being collated into an interactive webmap for submission with the Evidence Report. These layers will be incorporated into wider BGI mapping once available. As an example of the SFRA analysis of Natural Flood Management opportunities within a settlement, it is useful to consider Blackford. In terms of the SEPA Natural Flood Management opportunities mapping there is both substantial floodplain management and sediment management opportunities related to the Allan Waters. Unfortunately, we cannot publish this mapped information due to licensing restrictions. However, you can view the Natural Flood Management maps on the SEPA map viewer. Whilst SEPA mapping of opportunities is a starting point, the Blackford flood study carried out in 2020 identified Natural Flood Management as part of the preferred option. The Natural Flood Management could aid in storing flows within the upstream catchment as well as having wide catchment benefits. It is suggested that if alternative options are put in place to enable flood risk reduction, natural flood management measures could be incorporated later to provide some additional attenuation to the higher flows predicted as part of future climate change. Areas where Natural Flood Management may be considered include north and south of Drumfad on the Allan Water. This is different from the areas identified in the SEPA opportunity mapping, as detailed analysis resulted in a different approach. The delivery of this scheme is subject to capital funding being made available by the Scottish Government and within Perth and Kinross Council’s capital programme. Surface water management plans identify areas at high risk of surface water flooding. The flood risk analysis of these areas can inform the design and implementation of suitable drainage systems that may include BGI. There may also be opportunities for creating multi-functional spaces that mitigate flood risk, enhance biodiversity and provide community benefits. Furthermore, through partnership working, SWMPs should foster collaboration with key stakeholders in an area, forming the basis for ongoing collaboration to deliver novel surface water management approaches that could include BGI. Currently, there are completed SWMPs for Milnathort, and Blairgowrie and Rattray, whilst Perth is nearing completion. Aberfeldy, Comrie, Kinross and Scone SWMPs have not formally commenced and are expected to deliver over the next 24 months. Any SWMPs which are significantly progressed or finalised will inform the Proposed Plan. The Surface Water Management Planning Guidance (2018) outlines surface water management principles to be considered when planning or assessing proposals incorporating BGI, particularly in SWMP areas. Flood studies sometimes identify Natural Flood Management opportunities, and where they do, these will be recorded in the SFRA, whilst further studies that become available at Proposed Plan stage will also be considered. Any confirmed Natural Flood Management will be identified and protected in the Proposed Plan and will inform the green blue network. Studies have been carried out for: • Aberfeldy • Blackford
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• Comrie • Invergowrie • Alyth • South Kinross There are currently no Perth and Kinross Council implemented natural flood management within the area, however Alyth, Blackford and potentially Aberfeldy Flood Protection Schemes once confirmed may include natural flood management areas. The Blackford and Aberfeldy schemes are currently at preferred option stage. Whilst the Alyth natural flood management flood study is currently being reviewed by SEPA. Also, there are several landowners undertaking their own natural flood management works, examples include Blackford Farms, in collaboration with Forth Rivers Trust, and Bamff Estate upstream of Alyth. Perth Integrated Catchment Study considers the complex interactions between rivers, surface water drainage and combined sewer systems and identifies at risk areas, and potential interventions to reduce risk. Consideration will be given to any interventions which will add to blue network, with options including both grey and green/blue solutions. River basin management plans for Scotland (RBMP) set out a framework for protecting and improving the water environment and consequentially the benefits provided by the water environment across Scotland. It focuses on reducing resource use, eliminating waste and restoring natural capital. It covers rivers, lochs, transitional waters (estuaries), coastal waters, groundwater, and groundwater dependant wetlands, and sets out actions for public bodies, industry and land managers in Scotland. Information on the current status of a water body, pressures affecting it, measures required to address those pressures, and deadlines for achieving those measures are available on the SEPA’s Water Environment Hub and Water Classification Hub. Analysis of the RBMP will inform the spatial strategy and may identify additional blue green network opportunities. Identify Priorities for Connectivity 20-minute neighbourhood and local living analysis and settlement audit work will be carried out to support the preparation of the Proposed Plan. This analysis will inform the spatial strategy and may identify additional blue green network opportunities within the settlement. It is planned as part of the Settlement Audit work for the Proposed Plan 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. These settlement audits will be informed by results of our LDP3 Big Place Conversation exercise (using the Place Standard Tool) which are being collated to produce summaries for each of the localities. These summaries will be available for inclusion in the Evidence Report and considered through our Settlement Audit work for the Proposed Plan. The accessibility assessment undertaken for the open space strategy forms part of the broader local living and 20-minute neighbourhood analysis. This analysis identifies residential areas that do not meet public open space accessibility standards, which are then assessed against the Scottish Index of Multiple Deprivation (SIMD) to determine priority locations for improving access to green and blue spaces. The mapping highlights areas where access can be improved through new path connections or where new open space provision may be necessary. Green Networks / Nature Networks. Having identified existing green infrastructure networks for nature and people, connections between them will be discussed with communities as we prepare the Proposed Plan. This will build on information gathered during the Big Place Conversation around valued spaces and active travel priorities. Current engagement to identify priorities for Nature Networks is taking place alongside these Topic
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Papers which includes a question regarding the prioritisation of habitats with which to connect nature rich sites via nature networks. Encourage Use of Unused or Underused land The temporary use of unused or underused land as green infrastructure is currently encouraged under LDP2 Policy 42 reflected in NPF4 Policy 21 (d) for temporary proposals. LDP3 may be able to encourage temporary uses through identifying suitable land for BGI opportunities, both for direct community use or supported by development. • The Food Growing Strategy supports the temporary use of land for food growing. • The Open Space Quality Audit will help identify areas of land that could provide a greater functionality of green spaces for both biodiversity and food growing. • Scottish Vacant and Derelict Land Survey. Council data is available on the Open Data portal and provides opportunities where green infrastructure could be utilised. Urban Capacity and Brownfield study - A pilot exercise has so far been undertaken for a specific area of Perth and Kinross which 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. The initial scope of this has been focussed on identifying potential sites for housing, however when it is taken forward across the Council area, it should also consider whether sites have potential for use as blue or green infrastructure. This could be on a temporary or long-term basis. Safeguarding and Promoting Access to Green and Blue Spaces and Active Travel networks 20-minute neighbourhood and local living analysis and settlement audit work mentioned in more detail under Identify Priorities for Connectivity paragraph 46, this work will also inform the spatial strategy in relation to active travel. This analysis will assess accessibility to publicly accessible blue and green spaces, identifying locations where provision or connectivity require improvement. Open Space Quality Audit and Open Space Strategy. An accessibility statement will be produced as part of the Open Space Strategy. While initial data on accessibility of individual open spaces has been collated a wider picture of access to open spaces will be incorporated into the 20- minute neighbourhood analysis. Active Travel Routes will provide connectivity across green networks. LDP2 Policy 15: Public Access currently safeguards core paths, disused railway lines, asserted rights of way and other well-used routes and connectivity proposals identified in the Regional Transport Plan. The Proposed Plan should safeguard access rights and core paths, including active travel routes, and encourage new and enhanced opportunities for access linked to wider networks. This will require consideration of the following existing and proposed recreational routes: Existing routes • Core paths • Rights of way
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• National Cycle Routes • Signposted paths • Ramblers path network dataset • Cateran Trail • Loch Leven Heritage Trail and associated links Proposed future routes/priorities • National long-distance routes: Routes identified in LDP2 are Crieff to Comrie as part of the Pilgrim Way, and Crook of Devon to Kinross via Balado. • Future Potential Routes for footpaths: Perth and Kinross Council data. • Disused railway lines: Safeguarded in LDP2 from inappropriate development. Where there is not a reasonable prospect of being reused for public transport, consideration will then be given to their potential for active travel / green networks. Perth & Kinross Council Data. • The Tactran Regional Network: A spatial prioritisation of the pipeline of strategic active travel projects. • The Mobility strategy action plan (from emerging PKC mobility strategy) • Core Paths Scotland dataset containing potential linkages in neighbouring authorities. A Core Paths Plan was adopted by the Council in January 2012 and revised in 2017. The Plan shows a system of paths, 2043km in total, which provide reasonable public access throughout Perth and Kinross. The emerging Mobility Strategy, the Active Travel Strategy 2018, the Tactran Regional Active Travel Network 2024, and the emerging Kinross- shire Active Travel Masterplan will also be considered, particularly in context of identifying any additional spatial data on existing and proposed access routes or other active travel infrastructure. Progress on the Active Travel Strategy including the Cycling Walking and Safer Routes Projects can be found in the May 2024 report to Council. The Tactran Regional Network provides a spatial evidence base for prioritising and planning a pipeline of strategic active travel projects, to further develop the regional walking and cycling network. It will also include consideration of the Mobility Strategy Action Plan. The Mobility Strategy commonly known as a Local Transport Strategy, sets out Perth & Kinross Council's vision for managing and developing the transport network. The Mobility strategy considers and incorporates on going schemes and projects such as Perth People Place, which takes forward delivery of the Perth cycle network. The programme of active travel routes including shared use and cycling paths provides an opportunity to identify routes which best support access to blue and green infrastructure and active travel routes which present an opportunity for delivering multiple benefits by designing sustainable drainage and vegetation alongside the hard surfaces. Strategic Green Networks. An aspirational green route was set out in TAYPlan along both coasts of Tay Estuary linking Dundee and Newburgh to Perth. In addition, following the requirement in TAYPlan to identify strategic green networks, further work was carried out prior to LDP2 (see p68 of LDP2) resulting in Strategic Green Networks throughout Perth & Kinross centred around the national cycle ways. Perth & Kinross Countryside Trust have established the River Tay Way following core paths from Kenmore to Perth, with a cycling route which follows NCN 7 and 77 from Kenmore to Dundee. PKCT are also currently developing the Bridge of Earn to Newburgh active travel route. These routes should be reviewed, and consideration given to whether there are additional networks strands
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which should be added. The National Cycle Routes, Core Paths Scotland and Ramblers Path Network Scotland will be used to explore regional opportunities and inform engagement with neighbouring authorities in 2025. Identify Land for Temporary Greening or Food Growing Food Growing Strategy. The Food Growing Strategy 2021 for Perth and Kinross responds to the Government’s vision to increase the health and wellbeing of Scotland`s communities by encouraging more people to grow and eat fruit and vegetables. The two main barriers to growing food are the lack of knowledge and lack of suitable growing space. The Local Development Plan states that new developments should incorporate allotments where there is a proven demand in the local area. By identifying areas where there is a shortfall of growing spaces and a proven public demand, the Food Growing Strategy will provide the basis for fulfilling this requirement for future development proposals. Providing other community growing spaces through the planning process is also encouraged, especially for proposed residential developments which will lead to the creation of new communities. This approach is being trialled at Bertha Park near Perth, which will incorporate large community growing spaces. There is a relevant action within the strategy to, ‘Incorporate any potential allotment site, identified by the Food Growing Strategy, into the next revision/update of the Local Development Plan and any development brief work. Encourage/require all large residential development proposals to provide food growing opportunities.’ Identification of land for food growing is being sought during the first phase of the Grow Wild consultation. Further opportunities will arise during development of the Open Space Strategy. Strategy and Principles for Delivering Blue-Green Networks Water-Resilient Places Scottish Government paper considers what improvements we can make to surface water management in communities across Scotland by building on existing policy and by improving how we work together. It highlights blue green infrastructure can bring multiple benefits and meet a wider range of policy objectives including flood risk management, city regeneration, environmental improvement and enhanced wellbeing and health. Scottish Water’s “no more in; what’s in out” surface water policy stating that they will not normally accept any surface water connections into their combined sewer system also requires a shift in favour of blue- green interventions. Resolving surface water flooding issues requires a coordinated effort across organisations which could be difficult to achieve given the current policy and legislative framework. All the actions in this paper are relevant, however the most directly relevant actions for the land-use planning process (development planning and development management) are: • We should take a placemaking approach to achieving blue-green cities and water resilience involving partners in the public and private sectors, the third sector, individuals, and communities. • Climate impact assessments applying to public policies/activities should include assessing the impact of the proposed policy/activity on water resilience i.e. considering if the activity adds to flooding and drainage issues, helps manage flooding and drainage or has no effect on flooding and drainage. • Where appropriate, include a requirement for all sites and development proposals to be assessed and report on how they will contribute positively to the climate emergency and water resilience.
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• Place-making (and masterplanning) should establish blue-green infrastructure needs from the outset where planning authorities’ decisions are informed by a comprehensive water strategy where: o The natural infrastructure is defined; o Strategic flood risk and drainage assessments are carried out; o A blue-green infrastructure plan is defined • The drainage of surface water from all new sites wherever practicable should be by blue-green infrastructure. Land for blue- green infrastructure should be a site pre-requisite and all designs should presume no rainwater connection to sewer. Green infrastructure development will also be guided by the 6 qualities of successful places set out in Annex D of NPF4 and Scottish Government Guidance; and PKC’s Green and Blue Infrastructure Supplementary Guidance sets out the principles for protecting and delivering Green and Blue Infrastructure. This is complemented by Council’s 2021 Adopted Open Space Provision for New Developments Supplementary Guidance which sets out principles for the delivery of open space and associated blue infrastructure.
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Summary of Implications for the Proposed Plan: The initial implications of the evidence for the Proposed Plan which have been identified in this chapter are discussed in detail in this section. In summary, the main implications are: • Safeguarding open space through further engagement with communities and ongoing audit work to identify valued areas of open space for designation in LDP3. • Improving access to natural spaces through interventions in priority locations where the OSS and settlement audits identify poor quantity, quality, and/or accessibility to public open spaces. • Delivering ecosystem services through BGI enhancements identify in opportunity mapping to improve multi-functionality of greenspaces and deliver a range of benefits for both nature and communities. • Implementing nature-based solutions to projected climate change impacts by taking into account the Climate Change Risks and Opportunities Assessment, Strategic Flood Risk Assessment, Surface Water Management Plans, and Natural Flood Management Studies. Opportunity mapping will provide an evidence-base for where and how BGI design can mitigate local impacts. • Developing green networks that, where possible, link to nature networks, connecting natural spaces in rural and urban areas. Green networks include an active travel element that will contribute to Local Living and 20-minute neighbourhoods, mitigating transport related emissions. Cross-boundary strategic green networks will be explored with neighbouring authorities. • Focus on delivery through site-specific developer requirements for on- site or off-site contributions. For large-scale developments, these requirements will be further detailed through site masterplanning processes. As well as delivery through development, opportunities may be realised through other means such as public sector programmes and infrastructure investment. Up to Date Audits and Strategies The Proposed Plan will be informed by the audits and strategies, covering the multiple functions and benefits of blue and green infrastructure considered in this paper. The blue green infrastructure mapping 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, opportunities to enhance and expand green and blue infrastructure, and networks which connect areas for people and nature. The BGI audit will be incorporated into open space audit work and inform the preparation of the Open Space Strategy. Identify and Protect Existing Blue and Green Infrastructure The Proposed Plan will identify blue infrastructure by considering the OS MasterMap Water Network and SEPA’s riparian corridor layers, along with public open spaces mapped in the Open Space Audit. It will also consider existing and potential natural flood management opportunities, SFRA outputs, flood studies, wetland inventory mapping, RBMP, settlement audits, and urban capacity and brownfield assessments. The Proposed Plan will identify green infrastructure by considering the results of the Open Space Audit and the recommendations of the Open
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Space Strategy. The sources discussed will also add to the picture additional natural spaces not considered in the OSS, including how connections for wildlife can be made through urban green networks that provide corridors connecting with wider nature networks. Enhance and Expand Blue and Green Infrastructure As outlined in NPF4 Policy 20b: Blue and Green Infrastructure, development proposals for or incorporating new or enhanced BGI will be supported. Where appropriate, this will be an integral element of the design that responds to local circumstances. Design will take account of existing provision, new requirements and network connections (identified in relevant strategies such as the Open Space Strategy) to ensure the proposed BGI is of an appropriate type(s), quantity, quality and accessibility and is designed to be multi-functional and well-integrated into the overall proposal. Where appropriate, the Proposed Plan will address BGI as part of the Infrastructure First approach, aligning with NPF4 Policy 18. This will ensure BGI strategies inform site layout and design, and are implemented at property, street and development scale. The Open Space Audit evaluates the quantity, quality, and accessibility of publicly accessible green and blue spaces, providing a robust evidence base on the condition and needs of these spaces within the plan area. The resulting strategy serves as a strategic framework for PKC's policies and proposals relating to BGI. It will also identify priority actions that can be delivered through the LDP. The evidence base will inform the Proposed Plan, identifying where and how these priority actions can be implemented to deliver benefits across local placemaking, economy, climate change, environment, communities, and individual health and wellbeing. The Proposed Plan will utilise BGI as nature-based solutions to address the climate crisis by safeguarding, enhancing, and developing new blue-green spaces and network. These spaces will contribute to both climate change mitigation and adaptation, while also delivering a range of co-benefits for people and nature. This approach will be guided by the OSS, which will be developed alongside the Proposed Plan, and will support the promotion and facilitation of development that addresses the climate and nature crises. The effective integration of BGI into the Proposed Plan is therefore essential to achieving the objectives of NPF4 Policy 1: Tackling the Climate and Nature Crises. Additionally, the Open Space Strategy incorporates insights from PKC's Climate Change Risks and Opportunities Assessment to identify projected changes and future needs of places. This ensures that proposals relating to blue and green spaces or networks are designed to be multi-functional and contribute to the objectives of NPF4 Policy 2: Climate Change Mitigation and Adaptation. This includes mitigating climate change through carbon sequestration and the promotion of active travel, as well as adaptation to projected impacts such as through urban cooling and surface water management. Safeguarding and Promoting Access to Green and Blue Spaces and Active Travel Networks The Proposed Plan will also safeguard access rights and core paths, including active travel routes, and encourage new and enhanced opportunities for access linked to wider networks. Its spatial strategy will identify and protect blue and green infrastructure assets and networks;
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and seek to enhance and expand existing provision including new blue and/or green infrastructure. The accessibility mapping undertaken for the open space audit highlights areas where access can be improved through new path connections or where new open space provision may be necessary. These maps will be used to during site appraisals to inform site requirements for allocations in the Proposed Plan. It is important to note that the minimum open space requirements outlined in the Open Space for New Developments Supplementary Guidance (2021) will continue to apply unless superseded by the Open Space Strategy. Engagement on the Open Space Strategy will draw together these strands to inform how green infrastructure and blue networks can be identified incorporating assets to be protected and enhanced, and opportunities to be delivered. This will involve community bodies, community groups, stakeholders, and community greenspace colleagues. The Proposed Plan will identify objectives and actions, which will inform how blue and green infrastructure is delivered through site allocation and requirements. Also requiring consideration is the extent to which the planning system can contribute to improvement, particularly in relation to offsite improvements and strategic interventions. The Planning Circular 4/1998: The Use of Conditions in Planning Permissions prevents delivery where the need for the action would not be created by the new development. Strategy and Principles for Delivering Blue-Green networks Improving connectivity within and delivery of a successful green and blue network will require the Proposed Plan mapping and associated policy to provide: • A strong strategy and objectives which focus on identifying improvements which would deliver multi-functional benefits. • A good evidence base, identifying the existing infrastructure (blue, green and accessibility) with analysis of the relevant datasets, and engagement with communities, and other stakeholders to bring different perspectives, and expertise; • Priorities for connectivity within the network using collective experience and expertise of stakeholders; • A focus on delivery with appropriate linkages from identified priorities and improvements to development opportunities by tying actions to development allocations, and where possible utilising the planning system to assist in offsite and strategic improvements, whilst also recognising the role of other delivery mechanisms. The Council will update existing Blue & Green Infrastructure mapping to meet the requirements of NPF4 by: • considering the information sources mentioned in this paper; and • working with the wider public and stakeholders.
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Gaps, Uncertainties or Key Issues Raised: At the time of writing the Open Space Quality Audit has not been finalised. The audit is expected to be completed in summer of 2025, with the strategy to follow at the end of the year. Green and Blue infrastructure was mapped for the Blue and Green Infrastructure Supplementary Guidance. This will be reviewed and updated to consider the information sources mentioned in this paper alongside wider public and stakeholder input. As there will be no statutory guidance documents anymore, it is considered that the mapping will need to be in the LDP Proposed Plan in some form. Both the Green Infrastructure mapping and Open Space Audit will address accessibility and connectivity. This will be supplemented by consideration of nature networks to develop green networks. Prioritisation of how green networks connect people and nature to green spaces and through settlements will be developed through discussion with key stakeholders and communities as the Plan is developed. An initial consultation on priorities for nature networks is taking place alongside the consultation on topic papers. Identifying and protecting blue and green infrastructure and green networks in the Local Development Plan is the first stage. This will also help development deliver opportunities and connections as part of site planning. NPF4 Policy 3 requires development to deliver enhancement for biodiversity and this may raise opportunities for the realisation of green networks both on and offsite. Offsite delivery however is limited by the current law around planning conditions and in some cases may be difficult to secure until such time that new legal mechanisms are in place. Planning Circular 4/1998: the use of conditions in planning permissions sets out 6 tests for conditions as on several occasions the Courts have laid down the general criteria for the validity of planning conditions. In addition to satisfying the Courts' criteria for validity, conditions should not be imposed unless they are necessary and effective, relevant to the development to be permitted and do not place unjustifiable burdens on applicants. This limits the scope for requiring enhancement particularly where it is offsite.
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Summary of Stakeholder Engagement: The Big Place Conversation PKC completed a programme of community engagement in 2023 to inform the preparation of LDP3. The “Big Place Conversation” consisted of over 100 events and an online survey, receiving approximately 1,600 participants in total. We used the Place Standard approach for our community engagement, which is widely used across Scotland and is advocated by the Scottish Government and other key agencies such as Public Health Scotland. The Place Standard includes questions on the 14 themes. For the purposes of this chapter, comments received for the Natural Spaces theme are summarised below: Positive Comments + Natural heritage is intrinsically linked to local history, identity and character + Scenic landscapes, including hills, glens, woodlands, rivers, and lochs are highly valued for their beauty and ecological significance + Notable natural assets include the River Tay, Loch Tay, Birks of Aberfeldy, Den of Alyth, Ben Vrackie, Faskally Woods, Glen Lyon, and Kinnoull Hill 13 + An extensive path network provides excellent connectivity to natural spaces, making them easily accessible + Prominent nature walks include the Rob Roy Way, Loch Leven Heritage Trail, and Cateran Trail + High-quality greenspaces enhance access to nature within urban areas + Strong biodiversity thrives across both rural and urban settings, supporting abundant wildlife and healthy ecosystems + Local volunteer groups play an active role in managing and improving natural spaces, contributing to conservation efforts and enhancing biodiversity Negative Comments - Some areas have poor access to nature despite their rural surroundings, requiring residents to drive to natural spaces - Limited parking near natural spaces restricts access - Noise pollution from traffic detracts from the enjoyment of natural spaces - Certain neighbourhoods lack adequate urban greenspaces, due to poor provision, accessibility, connectivity, and/or quality. - The path network is fragmented in places, with missing links between key locations - Poor path conditions restrict access to natural spaces for those with reduced mobility - Gradual loss of natural spaces due to development on greenfield sites, including greenbelt and open spaces. - Concerns over the cumulative impact of new developments and land management practices on ecosystem health - Common maintenance issues include littering, dog-fouling, and changes in grassland management, such as “no-mow” areas - Conflict with landowners over access rights - Insufficient seating and sheltered areas in natural spaces and along paths to them
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Suggestions: o Safeguard the environment with effective policy measures, such as protecting greenbelt land, promoting brownfield regeneration, and increasing open space designations in the Local Development Plan o Enhance biodiversity and naturalness in both rural and urban areas through, for example, tree planting, conservation initiatives, and well-designed blue-green infrastructure o Improve the overall quality, connectivity, and promotion of the path network, linking settlements with natural spaces o Ensure new developments contribute to creating or enhancing greenspaces and path network linkages. o Promote natural attractions and path network more effectively o Increase opportunities around prominent natural assets (e.g. River Tay) o Encourage collaborative management of parks and nature-rich sites with communities, including improved access to funding and updated site management plans o Increase parking provision at key natural sites o Increase opportunities for community growing, such as orchards, allotments, and gardens o Provide more seating and sheltered areas at key sites and along the path network o Address dog-fouling and littering with more bins and clearer penalty signage 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. The feedback received is summarised in the Statements of Agreement/Dispute table below. Blue-Green Infrastructure Data Collection To inform the preparation of this Evidence Report chapter, the stakeholders listed below were consulted. They provided additional datasets and relevant information that have been included in this chapter. Additionally, the data provided has been included in our BGI mapping and will be used to inform preparation of the Open Space Strategy. • PKC Community Greenspace • PKC Climate Change and Sustainable Development
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• PKC Transport Planning • PKC Data Services • SEPA • NatureScot • Sustrans • Tayside Biodiversity Partnership • Perth and Kinross Countryside Trust Open Space Audit – Quality Survey Form Preparation and Site Visits The survey form produced to carry out quality assessments for the open space audit was created in collaboration between PKC’s Community Greenspace, Development Plans, and Climate Change and Sustainable Development Teams. The original survey template was created in 2020, however the project was paused due to the Covid-19 pandemic. A cross- team workshop was held in March 2023 to trial the template on sites in Perth and complete a final version of the survey form. Site surveys were primarily conducted by the planning department, with guidance from Community Greenspace Rangers. Joint site visits were conducted with the Rangers for key Parks and Countryside Sites in their respective localities.
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Statements of Agreement/ Dispute 12 responses were received on our Blue and Green Infrastructure Topic Paper. Most respondents (9 out of 12) either agreed with or had no comment to make on the evidence identified through Topic Paper 022, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered. A summary of these comments, their status, and the Council’s response are provided in the table below. There were no responses on the Blue and Green Infrastructure issue which the respondents wished to be treated as a formal dispute to the Evidence Report. Those responses have been highlighted in red in the table. Two respondents disagreed with the sufficiency of the list of evidence, and one disagreed with the implications of the evidence for the Proposed Plan. Those response are highlighted in orange. Respondent Agree or Dispute Summary of Comments PKC’s Response Unknown Disagree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The respondent indicated that they disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21. Further Comments: Disagree that evidence is sufficient, noting that the paper does not recognise key active travel routes. The respondent makes specific reference to the Loch Leven Heritage Trail and associated linking paths. Formal Dispute: The respondent did not wish for their response to be treated as a formal dispute. Reference added to Loch Leven Heritage Trail and associated links. Please see full list of active travel datasets provided at beginning of the paper. NatureScot Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): NatureScot indicated that they neither agreed nor disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21, and our summary of implications of that evidence for the proposed plan. Further Comments: NatureScot welcomed consideration of green networks and how they relate to nature networks and active travel networks. It was recommended that PKC explores new regional active Reference added to regional active travel datasets and plans for engaging with neighbouring authorities in 2025 to develop strategic green networks.
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Respondent Agree or Dispute Summary of Comments PKC’s Response travel routes across Tayside through discussions with other local authorities. Formal Dispute: NatureScot did not wish for their response to be treated as a formal dispute SEPA Disagree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): SEPA indicated that they disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21. Further Comments: Disagree that evidence is sufficient, noting that the paper does not include sufficient evidence to identify blue networks. Mapped sources which identify the river network and other water environment features along with the output of the finalised SFRA and the geomorphic risk layer would provide relevant evidence. The respondent made specific reference to the water classification hub, which provides the most recent classification data regarding the water environment. The respondent stated the implications of BGI as part of an infrastructure first approach to the spatial strategy should be highlighted. Furthermore, the benefits of BGI for climate adaptation should be expanded and strengthened, with links to NPF4 policies 1, 2 and 18 highlighted. Formal Dispute: SEPA did not wish for their response to be treated as a formal dispute. Datasets are now listed at the top of the paper and grouped by category. Please see datasets related to Water Environment as well as Flooding and Geomorphic Risk. Reference to Water Classification Hub has been included. SFRA map has been referenced and datasets will be incorporated into BGI mapping once available. TACTRAN Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): TACTRAN indicated that they neither agreed nor disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21, and our summary of implications of that evidence for the proposed plan. Further Comments: TACTRAN responded in relation to sustainable travel and the quality of places, noting that it is important to establish the risks to the viability of communities, such as risk of transport Reference to the 20-minute analysis taking place in 2025 has been strengthened. This analysis will assess accessibility to publicly accessible blue and green spaces, identifying locations where connectivity
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Respondent Agree or Dispute Summary of Comments PKC’s Response poverty. Reference was made to the series of 20-minute neighbourhood and local living analysis that will be carried out to support the preparation of LDP3. The respondent states it is difficult to understand the scale of the problem and the potential impact new development can have on access to play, sport and recreation without knowing the baseline data, e.g. in relation to the walking distance to the nearest useable green or blue space. Furthermore, the respondent highlights the scale of the Active Travel Routes map makes it difficult to establish the relevant information for the evidence report, i.e. distance to the nearest blue or green space. Formal Dispute: TACTRAN did not wish for their response to be treated as a formal dispute. requires improvement or provision increased. Furthermore, this includes an assessment of levels of deprivation using Scottish Index of Multiple Deprivation to identify priorities for intervention based on levels of deprivation. The Active Travel Routes data has been incorporated into the interactive BGI webmap. Kenmore & District Community Council Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Kenmore Community Council indicated that they neither agreed nor disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21, and our summary of implications of that evidence for the proposed plan. Further Comments: The respondent states the Community Council is in the process of creating a Local Action Plan in partnership with Loch Tay and Glen Lyon covering the “Loch Tay” area. The response highlights key issues that will be focused on, including the designation and safeguarding of open space identified by the community. Formal Dispute: Kenmore & District Community Council did not wish for their response to be treated as a formal dispute. PKC welcomes the reference to the upcoming Local Action Plan covering the Loch Tay area. The suggestions for open space designation and safeguarding included in the response have been saved with other early site suggestions. Reference to Local Place Plans has also been provided in this Evidence Report chapter.
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Respondent Agree or Dispute Summary of Comments PKC’s Response PKC Transport Planning Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): PKC Transport Planning indicated that they neither agreed nor disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21, and our summary of implications of that evidence for the proposed plan. Further Comments: The Mobility Strategy’s Strategic Action 161 supports a focus on green infrastructure and aims to protect and incorporate green infrastructure within all new infrastructure schemes and developments, capitalising on opportunities across Perth and Kinross to promote active travel and make connections where possible to blue and green networks to provide a multifunctional network with multiple benefits for climate and nature. Formal Dispute: PKC Transport Planning did not wish for their response to be treated as a formal dispute. PKC Transport Planning has been consulted during the collection of data for the BGI mapping exercise. We will continue to collaborate during the identification and delivery of green networks. No further action required. Homes for Scotland Disagree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Homes for Scotland indicated that they agreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21, however disagreed with our summary of implications of that evidence for the proposed plan. Further Comments: The respondent suggest stronger reference should be made to implications of NPF4 Policy 20b “development proposals for incorporating new or enhanced blue and/or green infrastructure will be supported.” The respondent notes that biodiversity requirements can have a detrimental impact on the cost of maintaining open spaces for residents. Therefore, it is important for LDP3 to recognise that alongside matters relating to BGI, other factors must also be taken into consideration, including marketability and deliverability, to ensure Scotland’s housing needs are met. Reference to NPF4 Policy 20b: Blue and Green Infrastructure has been provided in the Summary of Implications for the Proposed Plan section. In preparing the Proposed Plan PKC will be guided by the suite of NPF4 policies, six qualities of place and the many other pieces of guidance set out in this evidence report, to ensure that all factors of relevance are considered including BGI and deliverability. As per the Council’s
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: Homes for Scotland did not wish for their comments to be treated as a formal dispute. response to HfS under the Homes issue of this Evidence Report, their proposed deliverability checklist has been taken into consideration in compiling the site assessment methodology template for LDP3. Open space requirements, design standards and maintenance arrangements are set out in the Open Space Provisions for New Development Supplementary Guidance. Consideration will be given to its review in line with policy development for LDP3. Montagu Evans LPP on behalf of Loch Developments Ltd Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Montague Evans LPP indicated that they neither agreed nor disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21, and our summary of implications of that evidence for the proposed plan. Further Comments: No further comments provided. Formal Dispute: Montague Evans LPP did not wish for their comments to be treated as a formal dispute. No further action required. Scottish Water Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Scottish Water indicated that they agreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21, and our summary of implications of that evidence for the proposed plan. Reference to Surface Water Management Planning Guidance (2018) and surface
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Respondent Agree or Dispute Summary of Comments PKC’s Response Further Comments: Scottish Water agrees with the high-level overview of implementation of blue and green infrastructure contained in this topic paper and supports a cross-agency partnership approach to implementing blue-green infrastructure. Scottish Water encourages the inclusion of green and blue infrastructure as well as integrated green and blue networks when making place-based assessments. The intention for Perth and Kinross Council, through LDP3, to assess areas of land which could be used for temporary growing purposes to increase greenspace within communities is positive. Scottish Water strongly supports this approach of utilising existing brownfield sites, or areas of vacant and derelict land, in a manner that delivers both community placemaking benefits and positively impact on surface water management within catchments. Scottish Water also strongly recommends the inclusion of sustainable surface water management principles and plans to inform and influence the design and planning process for new developments. Green and blue infrastructure must be considered as a vital requirement in an infrastructure first approach. The topology of a development site should be used as a guide to form conveyance routes and place attenuation, with green and blue approaches being implemented at the property, street and development scales. Scottish Water encourage that consideration should be given as to how these Surface Water Management Plan outputs could influence future blue-green network strategies within the region. Formal Dispute: Scottish Water did not wish for their comments to be treated as a formal dispute. water management principles has been added. Consideration of surface water management has been strengthened in the Summary of Implications for the Proposed Plan section.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Kinross-shire Civic Trust Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Kinross-shire Civic Trust indicated that they neither agreed nor disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21, and our summary of implications of that evidence for the proposed plan. Further Comments: The respondent welcomes reference to plans for working with the wider public to map green infrastructure. Specific reference is made to the safeguarding of trees out with conservation areas or TPOs. The respondent notes that they do not believe trees are not adequately protected. Past experience highlights that TPO requests can take years to implement or are ignored, and that notifications of unauthorised felling (in a conservation area) have also been ignored. Formal Dispute: Kinross-shire Civic Trust did not wish for their comments to be treated as a formal dispute. NPF4 Policy 6(b): Forestry, Woodland and Trees states development proposals will not be supported where they will result in the loss or adverse impact on ancient or veteran trees, as well as individual trees of high biodiversity value, or identified for protection in the Forestry and Woodland Strategy. PKC welcomes further input from the Kinross-shire Civic Trust during the Open Space Strategy engagement and mapping exercise to identify trees that should be considered for safeguarding. Earn Community Council Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Earn Community Council indicated that they agreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21, and our summary of implications of that evidence for the proposed plan. Further Comments: Earn Community Council stated the plan is reasonable and Bridge of Earn has good facilities compared to most, but they need maintained and improved as part of an integrated plan. The respondent supports the use of green infrastructure to tackle climate change, enhance biodiversity, and improve health and Reference to PKC’s Community Groups and Projects Maps, including the Environmental Youth Groups and Projects Map, has been provided. These groups will be contacted during the Open Space Strategy consultation.
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Respondent Agree or Dispute Summary of Comments PKC’s Response wellbeing. They suggested community groups and schools can help deliver BGI. Formal Dispute: Earn Community Council did not wish for their comments to be treated as a formal dispute. Savills on behalf of Scone Estate Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Savills indicated that they neither agreed nor disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 21, and our summary of implications of that evidence for the proposed plan. Further Comments: Savills consider that it should be specifically recognised that landowners are critical to achieving strategic scale environmental benefits that, in turn, help achieve LDP aims. This is down to the scale of available land but also the potential to cluster such initiatives to maximise benefits. 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. The respondent references the upcoming 20-minute neighbourhood analysis and highlights that it must be remembered that PKC is predominantly rural. It was noted that work should be done to increase resilience of settlements via innovative means to deliver critical Local Living focused services. This 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 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
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Respondent Agree or Dispute Summary of Comments PKC’s Response availability of housebuilders form their own deterrent to any proliferation of rural housing. Formal Dispute: Savills did not wish for their comments to be treated as a formal dispute. 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 Perth and Kinross Area, including landowners and their agents, to deliver sustainable, liveable and productive places
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Respondent Agree or Dispute Summary of Comments PKC’s Response for further information, please refer to 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,
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Respondent Agree or Dispute Summary of Comments PKC’s Response 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.
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Issue: Play, Recreation, and Sport (Including Play Sufficiency Assessment) Corresponding NPF4 Policy/Policies: NPF4 Policy 21 – Play, recreation and sport Policy connections: • Policy 1 - Tackling the climate and nature crises • Policy 2 - Climate mitigation and adaptation • Policy 3 - Biodiversity • Policy 4 - Natural places • Policy 6 - Forestry, woodland and trees • Policy 7 - Historic assets and places • Policy 8 - Green belts • Policy 9 - Brownfield, vacant and derelict land, and empty buildings • Policy 13 - Sustainable transport • Policy 14 - Design, quality and place • Policy 15 - Local Living and 20-minute neighbourhoods • Policy 18 - Infrastructure first • Policy 16 - Quality homes • Policy 17 - Rural homes • Policy 20 - Blue and green infrastructure • Policy 22 - Flood risk and water management • Policy 23 - Health and safety • Policy 27 - City, town, local and commercial centres • Policy 31 - Culture and creativity Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 022: Play, Recreation and Sport Information required by the Act and NPF4 regarding the topic: Assessment of Sufficiency of Play Opportunities Part 2, Section 16D(1) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to include an assessment of the sufficiency of play opportunities in its area for children. This is delivered through the preparation of a Play Sufficiency Assessment. NPF4 Under NPF4 Policy 21, LDPs are expected to: • identify sites for sports, play and outdoor recreation for people of all ages. This should be based on an understanding of the needs and demand in the community and informed by the planning authority’s Play Sufficiency Assessment and Open Space Strategy. These spaces can be incorporated as part of enhancing and expanding blue and green infrastructure, taking account of relevant agencies’ plans or policy frameworks, such as flood risk and / or water management plans. New provisions should be well-designed, high quality, accessible and inclusive. This section also provides information relating to the policy subject of play, recreation and sport as contained in the ‘Local Development Planning Guidance’ (2023, p.73, 134-5). This includes information relating to the
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NPF4 Policy Advice & considerations referenced in the Evidence Report Guidance for the play, recreation and sport policy topic (NPF4 Policy 21). Specifically, the Guidance (p. 112) sets out that: “The spatial strategy should seek to identify and maximise the opportunities for play in the community, in the neighbourhood and in the natural environment. Apart from identifying specific sites for sports, play and outdoor recreation, the spatial strategy should address the wider concept of play and playability, in the form of informal play spaces, in the built and natural environment. It should recognise that accessible blue and green infrastructure may provide outdoor opportunities for formal and informal play and recreation. Consideration should be given to key policy connections and other opportunities for play, recreation and sports such as within natural places, forestry and woodlands, appropriate water environments and in the public realm and civic spaces. Formal and informal play provisions should be designed consistent with the six qualities of successful places. They should be of high quality, accessible and suitable for children and people of different ages and abilities, to meet current and likely future needs and demand in the community. Sports pitch strategies may inform the needs and demand for outdoor sports provision, and where relevant suitable provision should be considered through the spatial strategy. Plans should prioritise actions in disadvantaged communities, to ensure the sufficiency of provision of publicly accessible, high quality outdoor play opportunities for formal and informal play. This will help to tackle inequality in access to play and improve health and wellbeing outcomes for children in those areas.” Links to Evidence: National / Local Policy Context • Active Scotland Outcomes Framework • Play Strategy for Scotland (2013) • Progress Review of Play Strategy • Physical Activity for Health: Scotland’s National Framework • PKC Corporate Plan (2022-2027) Existing Facilities • SportScotland Facilities Report (2024) • PKC - location of existing play areas • PKC Play area improvements • PKC leisure centres and swimming pools • PKC - Council decision on leisure assets in Perth • PKC - Public consultation on future of Bells • PKC - Pitlochry Asset Review council committee decision • PKC - location of existing outdoor sports pitches • PKC - Policy on Provision for Outdoor Sports (2017) • PKC - major parks • PKC - open space areas • PKC - skate park facilities • PKC - community sport hub facilities • PKC - paths and trails
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• PKC - Core Paths • PKC - Water Safety Policy PKC Policy – Asset Management • PKC Transformation Review of Leisure Assets • PKC Transformation Review of Leisure Assets - Appendix • PKC Transformation Review - meeting minute • PKC Committee Report - Perth City (2024) • PKC Committee Report - Perth City (September 2024) • Perth and Kinross Community Green Asset Management Plan (2017-2022) PKC Policy – Enhancing Opportunities for Play, Recreation & Sport • Perth and Kinross Physical Activity and Sport Strategy (2023-2028) • Play Framework for Perth and Kinross (2019-2022) Understanding Need • SportScotland Facilities Planning Modelling • Play Sufficiency Assessment - Regulations • Play Sufficiency Assessment - Guidance • PKC Play Sufficiency Assessment • PKC Big Place Conversation • PKC Big Place Conservation Results • Scottish Index of Multiple Deprivation data
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Summary of Evidence: National / Local Policy Context The Scottish Government has outlined ambitions for sport and physical activity in the Active Scotland Outcomes Framework and these are: • We encourage and enable the inactive to be more active • We encourage and enable the active to stay active throughout life • We develop physical confidence and competence from the earliest age • We improve active infrastructure – people and places • We support wellbeing and resilience in communities through physical activity and sport • We improve opportunities to participate, progress and achieve in sport These link to a number of the national outcomes that the Government is seeking to achieve, most relevant to sport is that ‘We are healthy and active’. SportScotland is the national agency for sport, with the vision of an active Scotland where everyone benefits from sport. SportScotland has provided an Evidence Report guidance note to local authorities which notes that: “The availability of a network of places, of the right quality and capacity to meet the needs of sport, is crucial to deliver these outcomes. Spatial policy should, therefore, consider the needs of sport and physical activity, and the evidence report should consider what the needs of the local community is in relation to this.” The guidance note highlights that the Evidence Report should consider the following two key areas, both of which are considered in the Topic Paper below: • ‘Understanding need’ • ‘Sport in your council area’ The Scottish Government published a Play Strategy for Scotland (2013) with the overall vision that “We want Scotland to be the best place to grow up. A nation which values play as a life-enhancing daily experience for all our children and young people; in their homes, nurseries, schools and communities.” The Strategy includes a number of outcomes, with associated actions, to support play opportunities for children and young people including in their communities. A progress review of the Play Strategy was undertaken in 2019, which includes a range of recommendations including actions for closer links to land use planning e.g. through Play Sufficiency Assessment process. The Scottish Government also recently published ‘Physical Activity for Health: Scotland’s National Framework’ to set out a coordinated and evidence-led approach towards improving levels of physical activity in Scotland. Key Strategic Delivery Outcomes of the Framework include: • Active Travel Framework • Active Places and Spaces • Active Sport and Recreation
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Under each of the Delivery Outcomes there are a number of evidence based actions that are relevant for the next Plan, including: • Continue to prioritise investment in walking, wheeling and cycling infrastructure • Engage communities in urban and rural transport planning processes • Integrate urban design, transport planning and land-use policies • Strengthen access to good quality indoor and outdoor public park and open spaces, green (including blue) spaces and infrastructure • Strengthen access to places, spaces and services that enable equitable and inclusive access and reduce inequalities At the local level, the Topic Paper links to the following priority from the Perth and Kinross Council Corporate Plan (2022-2027): • Supporting and promoting physical and mental wellbeing There is a particular need for the Spatial Strategy of the next LDP to take in to account the following key action contained in the Corporate Plan linked directly to the policy topic of play, recreation and sport: • Improve health and wellbeing in Perth and Kinross by increasing overall participation in sport and physical activity and promoting the wellbeing benefits of time spent in our natural surroundings
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Summary of Evidence The following section sets out the evidence which is needed so that the Proposed Plan can address the issues raised in the Act and NPF4. Existing Facilities SportScotland Facilities Report (2024) To support the Evidence Report process, SportScotland have prepared a Facilities Report spatial dataset covering a wide range of facilities within the Perth and Kinross area. A SportScotland Facilities Report 2024 interactive map has been prepared, including the following facilities: • Sports Halls • Fitness Suites • Squash Courts • Swimming Pools • Ice Rinks • Athletics Tracks • Golf Courses • Bowling Greens • Tennis Courts (indoor and outdoor) • Pitches (outdoor, various sports) This information provides an overview of the existing facilities available within the Perth and Kinross area. This is informed and supplemented by local data and information on existing sport and recreational facilities. Live Active Leisure are the main operator of public sport and recreational facilities in PKC. The following sections provide a summary of play, recreational and sporting facilities available in Perth and Kinross: Play Areas There are over 145 Council maintained play areas and there is a map to show the location of existing play areas. Play area improvements are also programmed for Council maintained sites. Leisure Centres and Swimming Pools There are a number of leisure centres and swimming pools across Perth and Kinross, with public leisure provision served by Live Active Leisure. The table below includes the Live Active Leisure centres and swimming pools in Perth and Kinross: Leisure Centres and Swimming Pools in Perth and Kinross Leisure Centre Facilities Perth City Perth Leisure Centre 25m swimming pool, leisure pool with flumes, fitness gym, health suite, beauty spa, power plates studio *Note: Council decision on leisure assets in Perth * Bell’s Sports Centre Following Council decision on leisure assets in Perth, gym equipment and fitness studios from Bell’s Sport Centre have been re-located to Dewars Centre, while other leisure services are being moved across the Perth education estate. Further information is available on the Live Active website.
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Public consultation on the future of Bell’s Sport Centre, awaiting confirmation of future use/re-use of facility Dewars Centre Curling, ice skating, fitness gym and classes North Inch Community Campus Large sports hall, fitness gym, outdoor pitches and dance studio Glenearn Community Campus Large sports hall, outdoor pitches and dance studio Kinross-shire Live Active Loch Leven, Kinross 25m swimming pool, fitness gym and glass backed squash courts Loch Leven Community Campus, Kinross Large sports hall, fitness gym, dance studio, outdoor pitches and climbing wall Strathearn Strathearn Community Campus 20m swimming pool, fitness gym, glass backed squash courts and dance studio Highland Perthshire Breadalbane Community Campus Swimming pool, pool-side sauna and jacuzzi, fitness gym, large sports hall, dance studio, outdoor pitches, climbing wall and squash courts Live Active Atholl Fitness gym and sports hall *Note Council committee decision to create Pitlochry Community Campus at the school site including new leisure facilities. This investment will result in the repurposing of the existing Live Active Atholl building into affordable housing* Eastern Perthshire Blairgowrie Community Campus Sports hall, dance studio and outdoor pitches Live Active Blairgowrie Swimming pool, fitness gym and large sports hall *New Blairgowrie Recreational Facility is due to open in 2025* Outdoor Sports Pitches & Athletics Tracks The Council has a map showing the location of existing outdoor sports pitches. The Council’s Policy on Provision for Outdoor Sports (2017) sets out a policy aiming to ensure the effective and efficient management of Council facilities for outdoor pitch sports for present and future needs. The policy covers all sports using pitches provided by the Council, with football being the most popular. The policy – at that time – notes that for all sports, there are adequate pitches to meet current demand, although quality is variable and new or improved changing facilities are required in many locations. The section below regarding the P&K Physical Activity & Sport Strategy notes that feedback received during consultation is used to highlight demand pressure in certain areas in terms of sport facilities. The policy also notes the role for developer contributions to secure new facilities or contributions for facilities from major housing developments. There are 9 athletics tracks available at educational facilities across Perth and Kinross: 4 in Perth, and one each in Blairgowrie, Aberfeldy, Kinross, Pitlochry, and Crieff. Bowling Greens & Tennis Courts (outdoor)
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There are a large number of bowling greens and outdoor tennis courts available across Perth and Kinross, with many settlements served by these facilities. Parks, Countryside sites and Maintained Open Space There is a wide range of parks and countryside sites available in Perth and Kinross, with most settlements being served by at least one park, play area and/or other green space near them. There are major parks that offer a range of attractions for all ages, attracting visitors from near and far due to their facilities and locations. Countryside sites are more natural spaces, offering a different experience as these are particularly good places to walk, enjoy views and watch for wildlife.. The Council maintains a large number of open space areas. The major parks and countryside sites are listed below: Major Parks • MacRosty Park, Crieff • North Inch, Perth • South Inch, Perth • Kirkgate Park, Kinross • Larghan Park, Coupar Angus • Victoria Park, Aberfeldy • Davie Park, Rattray/Blairgowrie • Perth Riverside Park • Scone Park • Auchterarder Western Road/Primrose Park • Pitlochry Recreation Ground • Alyth Diamond Jubilee Park Countryside sites • Birks of Aberfeldy • Kinnoull Hill Woodland Park, Perth • St Magdalene’s Hill and Buckie Braes, Perth • Den o’ Alyth Skate parks The Council also has a map of the locations of the 10 existing skate park facilities across the area. Golf Courses There are over 30 golf course and practice range facilities in Perth and Kinross, some of which are internationally renowned including Gleneagles Golf Course. North Inch Golf Course is also regarded as one of the oldest courses in the world. Community Facilities including Sports Hubs SportScotland has information for community sport hub facilities across Scotland. In the Perth and Kinross area, the following community sports hubs are included: • Kinross-shire Community Sports Hub • Auchterarder Community Sports and Recreation
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• Crieff and Comrie Community Sports Hub • Bridge of Earn Community Sports Hub • SMASH (St Madoes Active Sports Hub) • River Tay Community Sports Hub • Perth High Community Sports Hub • Perth College Community Sports Hub • Sport for Change Network – Perth City • Eastern Perthshire Community Sports Partnership • Spittalfield and District Active Recreation • Dunkeld and Birnam Sport Hub • Aberfeldy Community Sport Hub • Active Blair Atholl Community halls and facilities also provide an invaluable space for local communities for sport and recreation opportunities. These can be owned/operated by the Council or local community groups. Live Active Leisure currently operates 3 halls in Perth, as well as halls in Coupar Angus, Blackford, Auchterarder, Dunning and Pitlochry. There are also community- run village halls elsewhere across PKC. Emerging proposals for community facilities will also form part of the evidence base, including where these are identified in community-led plans such as Local Place Plans. Path infrastructure The Council supports the use of a wide range of paths and trails for outdoor recreation including walking. The webpage has a resource of paths and trails for each locality, including Core Paths. As well as local trails the Council area includes a number of Scotland’s Great Trails including the Cateran Trail and Rob Roy Way. The area also includes popular hill-walking routes in the upland areas such as Ben Lawers, Ben Vorlich, and Schiehallion, as well as forest walks (e.g. Hermitage, Tay Forest National Park) and loch-side trails (Loch Leven Trail). Water based recreation For water based recreational interests, the Council has a Water Safety Policy in place including for Council owned/maintained sites. Perth and Kinross is popular for a range of water based recreational activities across many sites including for wild swimming, kayaking/canoeing, stand up paddleboarding, canyoning, fishing, and boating/sailing. Popular locations for water-based recreation where a variety of organisations and activities can be found include, Loch Tay, Loch Earn, and along the River Tay. Informal play and recreation As detailed in the ‘understanding need’ section, qualitative and spatial data has been gathered through community engagement exercises which identifies existing locations of informal play and recreation. These sites are being reviewed as part of the ongoing Open Space Audit and will form part of the evidence base to be used to inform the Spatial Strategy, which is particularly advocated for in the LDP Regs Guidance (p.112). Public open space identified through the ongoing Open Space Audit has been used to provide statements on informal play and recreation areas. So far, the audit has identified 1,360ha of open space within or adject to
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settlements, of which 704ha are considered publicly accessible open space. These spaces have been mapped in the (DRAFT)Play Sufficiency Assessment Storymap. PKC Policy - Asset Management Perth and Kinross Council Transformation Review of Leisure Assets (2024) In January 2024, a Committee Report and associated Appendix (key issues per locality) was presented to Full Council to consider the findings and recommendations of the Transformation Review of Leisure Assets. The Committee Report summarises review findings and made 10 recommendations to maintain accessible, affordable and sustainable leisure provision for our communities over the next 5-10 years. The Appendix, in particular, includes a breakdown of leisure assets at the locality/settlement level as well as consideration of issues such as demand and accessibility. A minute of the Committee meeting outlines the Full Council’s decisions in relation to the Transformation Review of Leisure Assets which sets out the approach for the next 5-10 years. Perth City Following the Committee decision in January 2024, a report on the future of Bell’s Sport Centre (and implications on the provision of services at Dewars) was approved by Council Committee in May 2024. Further to this report, in September 2024 the Council approved plans for consolidation of leisure facilities in Perth City, including: • The demolition of the existing Leisure Centre and replacement with a new facility (PH2O) at the Thimblerow site • Programme of public consultation on the future use of the existing Bells Sport Centre Facility , and • Potential for user-led operation of Dewars ice-rink facility, following completion of PH2O project Pitlochry In June 2024, the Council approved the Pitlochry Asset Review. This includes the provision of a Community Campus facility at the existing school site, including new leisure facilities, and the repurposing of the existing Live Active Atholl facility into affordable housing. Perth and Kinross Green Asset Management Plan (2017-2022) The Perth and Kinross Community Green Asset Management Plan (2017- 2022) sets out the investment and services being provided by the Council in relation to community greenspaces. The Plan highlights the current greenspace assets, key drivers and demands, as well as an asset investment strategy highlighting where there may be risks for investment/delivery. PKC Policy – Enhancing Opportunities for Play, Recreation and Sport Perth and Kinross Physical Activity & Sport Strategy (2023-2028) The Council published the Perth and Kinross Physical Activity and Sport Strategy (2023-2028) in 2023. The Strategy’s over-arching vision for the future of physical activity and sport in Perth and Kinross is: “We will support everyone’s physical and mental wellbeing through physical activity and sport”. The Strategy recognises the important role that physical activity and sport have in creating places where people can live healthy, fulfilling, and productive
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lives, linked to the Council’s Corporate Plan objectives around living well, free from poverty and inequality. The Strategy is intended to help partners and stakeholders with their own planning and delivery, services, and opportunities through a clearly defined set of strategic priorities, and a robust measurable action plan. The Strategy includes a section ‘Our Story of Place’ which sets out the place-based context for physical activity and sport in Perth and Kinross. A summary of the context of physical activity and sport is set out below: “It is one of the most diverse parts of the country, with the ancient City of Perth and 6 large towns. The geography ranges from vast Highland landscapes of mountains, glens, lochs and rivers; the glacial plains of the Carse of Gowrie, Strathearn and Strathmore and the Lowlands of Kinross- shire. The Tay connects all these localities along with the Earn, the Almond and other riverways. The natural landscape is itself a huge asset for physical activity and sport in many forms. Our sports facilities: swimming pools, gyms, indoor and outdoor courts, sports pitches, Community Campuses and schools are used for more structured forms of physical activity and sport, delivered by many partners. All of these combine to provide an outstanding setting for sport and physical activity of all kinds, for everyone.” Stories of Place are also included for each of the Perth and Kinross localities, providing a place-based context for the provision of facilities and opportunities for physical activity and sport in these areas. The Strategy also includes baseline data (p.23-25) to support the development of strategic priorities. Notable statistics include: • 48% of children currently meeting recommended levels of physical activity • 60% of children between the ages of 8-11yrs currently meeting recommended levels of physical activity • 43% of children between the ages of 12-17yrs currently meeting recommended levels of physical activity • Numbers of young people reaching the recommended level of physical activity are lower for those from the most deprived areas of Perth and Kinross. Numbers are higher for males when compared to females, 52% compared to 42%. • 42% of adults (female) and 51% (male) were meeting the recommended amount of physical activity (Scottish Health Survey 2020). • A third of clubs who responded to the survey said that the facilities they use don’t meet their needs. • 84% of population within a 20-minute drive of a leisure centre • 66% of population within a 20-minute drive of a swimming pool • 100% of population within a 20-minute drive of a sports pitch • 100% of population within a 20-minute drive of a community hall A SWOT analysis has also been completed using stakeholder feedback to identify the strengths, weaknesses, opportunities and threats for physical activity and sport provision in Perth and Kinross, with a detailed breakdown of the SWOT analysis undertaken at a settlement level. The SWOT analysis is summarised below in the table below.
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Strengths • Facility provision and spread across Perth and Kinross • Outdoor parks and natural resources for sport and physical activity • Partnerships working across different agencies • Range of sports, activities and programmes • Number of clubs and volunteers • Active schools and community sports hubs • Significant sources of external funding focussed on inequalities • Motivated stakeholders and communities • Some concessionary access schemes e.g. compass membership • Social Prescribing • Community youth work organisation Weaknesses • Facilities ageing and in need of maintenance and upgrade • Recruitment and retention of staff, volunteers, coaches etc. • Limited access to campus facilities • Fragmented and bureaucratic booking systems • Stakeholders working in silos • Rural provision and inequality • Use of technology and data • Lack of awareness of opportunities and provision • Rural transport infrastructure • Lack of facility capacity in some areas and at some times e.g. 3G pitches • Lack of monitoring and evaluation evidence of impact of sport and physical activity on individuals, families and communities • Social Prescribing structure is fragmented Opportunities • Opportunity to improve collaboration across partners • New investment in facilities i.e. Blairgowrie, PH20 • Greater collaboration and coordination between stakeholders • Improve targeting and prioritisation of resources where inequalities are greatest • Greater involvement of communities in accessing facilities • Community asset transfer • better use of technology and data • Need to focus on developing people based resources and capacity • Better utilisation to be made of existing physical activity and sporting assets • Invest in early intervention and prevention • Extend Social Prescribing model to young people • Opportunity to streamline management and booking arrangements for facilities Threats • Financial pressures in the public sector • Cost of living crisis and affordability of sport and physical activity, transport, equipment, clothing etc. • Lack of people - staff, volunteers and coaches in clubs and communities • Competition for access to facilities • Cost of facilities and activities become too high • Inflationary costs impact on viability of facilities • Ageing population • targeted wellbeing programmes are conditional upon temporary funding sources • Absence of shared vision for SPA • Environmental sustainability Various ‘barriers to participation’ are also included in the Strategy to inform the Action Plan, including: • Facilities • Confidence in participation
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• Cost • Disability/condition • Capacity • Transport • Awareness In order to support and help deliver on the Strategy’s vision, the following priorities are identified: • We will improve everyone in P&K’s health through increased participation in physical activity. • We will increase the levels of activity for children and young people, particularly those who currently don’t meet the recommended levels of participation. • We will reduce the inequalities which prevent people participating. • We will make physical activity central to our Climate Change response. • We will support our community-led physical activity and sport to grow and flourish and strengthen collaboration between all partners. • We will make physical activity and sport part of Placemaking so our public spaces are activity-friendly, inclusive and fun. The Action Plan is underpinned by 5 Strategic Enablers: building blocks to support the delivery of the Strategy’s priorities. Feedback received during consultation on the Strategy highlighted demand pressure in some areas, including: • Not enough pitch provision to meet demand in Perth for football (grass and 5-a side) • Rugby pitch provision at North Inch insufficient to meet needs of those in Perth. • Communities in Auchterarder and Kinross highlighting investment and provision in play/sports facilities no longer met need as a result of significant house building in towns with no equivalent investment in play and sport Play Framework for Perth and Kinross (2019-2022) The Play Framework for Perth and Kinross (2019-2022) sets out the Council’s commitment to delivering high quality play opportunities for children and young people. Actions of particular relevance include: • further enhance accessible and inclusive, fun, exciting and challenging spaces for play which support children’s natural instinct to play • develop and promote the of use community resources and spaces creatively to increase opportunities for play, e.g. streets and natural spaces • promote and enable play in communities appropriate to children and young people’s ages, stages, preferences, and individual need
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Open Space Provision for New Developments Supplementary Guidance (2021). This current guidance accompanies LDP2 Policy 14: Open Space Retention and Provision, providing: • The quantity, accessibility and design standards for open space (including play) in new developments • Information as to the types of open space required for different scales of development • Conditions for on-site and off-site developer contribution requirements • The mechanisms for the maintenance of open space. The guidance seeks to ensure there is appropriate mitigation for the impact new development has on existing open spaces and determine whether or not new public open space will be required to support the development (see Determining the Required Provision table). Furthermore, the document provides guidance on landscaping and the design of development. It encourages well-connected, high quality open spaces which are designed with long-term maintenance implications in mind. Understanding need SportScotland Facilities Planning Modelling SportScotland have prepared a report of the Facilities Planning Modelling for the PKC area. This provides an objective assessment of the relationship between the likely demand for sports facilities in an area and their supply, using a nationally-consistent methodology. It is important to note that this is modelled using national trends and therefore does not represent actual usage of assets. The Facilities Planning Modelling is supplemented by detailed monitoring of leisure facilities by relevant officers in the Council and Live Active Leisure. As noted above, a recent Transformation Review of Leisure Assets has been undertaken by the Council which is guiding investment decisions made for leisure facilities across PKC.
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Play Sufficiency Assessment As required by Section 16D(1) of the Act1, the Council is required to prepare a Play Sufficiency Assessment to be prepared for the Evidence Report. Guided by the relevant Regulations and associated Guidance, the Council has prepared a PSA Storymap providing background, key findings, methodology, results, maps and next steps. The PSA has involved: • Site Identification • Site Assessments • Accessibility Analysis, and • Community Engagement Through the PSA, an assessment has been made of the quality, quantity and accessibility of formal/adopted play spaces in the PKC area. Statements on these criteria are provided for the planning authority area, and individual settlement level, to identify the sufficiency of the play provision. Key findings are provided below and the outputs are discussed in detail in the PSA Storymap. The PSA included the 145 equipped play areas adopted and managed by PKC, this includes: • 54 Local Equipped Areas for Play • 53 Rural Equipped Areas for Play 1 The Town and Country Planning (Scotland) Act 1997, as amended by the Planning (Scotland) Act 2019 • 29 Neighbourhood Equipped Areas for Play • 9 Premier Equipped Areas for Play Site surveys were conducted to assess the quality of these sites and found: • 21% were high quality • 32% were good quality • 37% were reasonable quality • 10% were poor quality The graph below shows the quality scores by typology.
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Accessibility was assessed against two existing standards, the analysis found: • 39% of dwellings are within the 400m LEAP catchment • 71% of dwelling are within the 1000m catchment for NEAPs, REAPs, or PEAPs. The ongoing open space audit has identified 704ha of public open space, where community feedback tells us that informal play primarily occurs. The audit expected to be completed in 2025 and will include statements on quality and accessibility. As noted above, an assessment of the sufficiency of play opportunities in PKC has been informed by engagement with a range of specific groups: • A ‘Playing Out in Perth and Kinross’ online survey was targeted at children and young people, parents, carers and guardians. The survey sought feedback on formal and informal play spaces and was open from July to October last year (2023). There were over 300 individual responses to the survey. • Alongside the ‘Playing Out’ survey, the team undertook a significant programme of community engagement throughout 2023 called the ‘Big Place Conversation’. Full details of this engagement are noted below. The PSA provides evidence on the sites for play and recreational opportunities as well as an understanding – from users – of the needs and demands in communities. Big Place Conversation – Early LDP3 Engagement Throughout 2023, the Council carried out an extensive engagement programme called the ‘Big Place Conversation’ across Perth and Kinross communities. This was an engagement exercise involving over 100 events throughout the Council Area to gather place-based evidence from communities to inform the next LDP. 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
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communities about different aspects of their places. There were also targeted sessions held with schools/youth groups, service user groups, and minority groups. The results of the Big Place Conversation have been collated and summary reports are available at community council, ward, and PKC-wide levels. Key PKC-wide issues highlighted by communities under the ‘Play and Recreation’ theme include: Positives (+) • Outdoor spaces are widely used for play, recreation and sport, with most residents enjoying having good access to paths, parks, and other natural areas • A diverse range of formal and informal outdoor opportunities is available, including walking, cycling, play, and various sport or other organised activities • The area benefits from excellent facilities, including playparks, swimming pools, skateparks, MUGAs (multi-use games areas), 3G football pitches, and golf courses. • Larger settlements feature high-quality premier play areas offering a range of exciting and challenging activities for children and young people • Indoor community facilities, such as leisure centres, village halls, and churches, are well-utilised for recreation, play and sport • A good variety of clubs, events, and organised activities are available for all age groups, with children and older adults provided with the most opportunities • Local volunteer groups play a key role in supporting play, recreation, and sporting opportunities • Activities organised by youth groups and schools are highly valued by young people • Most residents have good access to formal play provision Areas for improvement (-) • Insufficient provision of spaces and activities for older children and young people (12+) • Existing play areas lack a variety of exciting and challenging equipment for older children and young people (12+) • Limited facilities for children and young people in inclement weather • Children have significant concerns about anti-social behaviour in play areas and parks • Inadequate play and sporting opportunities for girls, with some options perceived as gender-exclusive • Insufficient facilities and activities for people with disabilities • Very limited facilities and organised activities in rural communities, often requiring travel by car to access formal opportunities
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• Limited availability of indoor facilities and activities, particularly in rural areas • Accessibility is hindered by issues with active travel options and public transport • Hiring venues and participating in activities can be cost-prohibitive • Many facilities are outdated or in poor condition, requiring maintenance or upgrades • Loss of informal play and recreation spaces due to No Mow grassland management • New play provision through developments is either insufficient or delayed until later project stages • It can be difficult to access information on groups, events, and activities happening Suggestions for improvement • Upgrade parks to offer a diverse range of free activities, including picnic areas, exercise equipment, and informal gaming (e.g. chess tables) • Create more challenging and varied play opportunities for all groups and users • Increase variety of outdoor facilities, such as skate parks, pump tracks, bridle trails, and mountain bike trails • Provide better segregation of play areas and parks for children and young people • Develop more free activities and dedicated spaces for young people • Enhance the active travel network to improve access to facilities and provide more opportunities for recreational walking and wheeling (i.e. cycling, skating, scootering) • Improve public transport links to key facilities • Improve accessibility and make better use of existing indoor venues e.g. village halls, churches, and schools • Develop more adaptable, multi-use facilities for play, recreation, and sport, including both indoor and outdoor spaces (e.g. MUGA or leisure centres) • Improve the maintenance of facilities and secure funding for upgrades • Create a central online platform for sharing information about groups, activities and events The Big Place Conversation (BPC) included nearly 400 children and young people participants across 28 events with primary and secondary schools, and youth groups. ‘Play and Recreation’ was a key focus during the children and young people engagement sessions, including identifying locations important for the under-18 age group. The diagram below presents the quantitative outputs of the engagement with this demographic, showing that access to good quality play and recreation opportunities ranked 5th out of the top priorities, indicating perceived room for improvement based on current provision.
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Key issues highlighted by children and young people in relation to ‘Play and Recreation’ across PKC include: • Lots of examples of being connected to nature with good walks and informal play opportunities • Young children generally have good access to range of play opportunities • Older children and young people commonly highlighted lack of things to do, with improvements needed for both existing facilities/parks, new facilities and free access to spaces • Improve naturalness and biodiversity of open spaces • Lack of places for older children and young people to socialise with suggested improvements for shelters/seating in parks and more places to go • Lack of places to go in poor weather • For rural areas, need to travel to bigger settlements was highlighted which can limit access particularly where public transport is limited/non-existent • Youth groups highlighted as positive • Improvements to leisure opportunities highlighted Perth and Kinross Open Space Audit and Strategy An Open Space Strategy is currently being prepared in fulfilment of duties set out in The Planning (Scotland) Act 2019. To inform the preparation of the strategy, an Open Space Audit has been undertaken by the planning department and the results are currently being reviewed by the Council's Community Greenspace team. The Open Space Audit includes an assessment of the quantity, quality, and accessibility of publicly accessible open spaces in the planning authority area. Statements will also be provided on a settlement level to identify areas of insufficient provision of good quality open spaces for the Spatial Strategy. Furthermore, the audit will be used to review LDP2 Open Space Designations, which are the main mechanism for safeguarding open spaces from development. The Open Space Audit has included: • Aggregation of existing greenspace spatial datasets including: LDP2 Designated Open Space, Maintained Open Space, Countryside Sites, and OS Greenspaces • Site visits and quality surveying
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• Desk-based analysis To date, the audit has identified 1,360ha of open space within or adjacent to settlements, of which 704ha are considered publicly accessible open space. These spaces have been mapped in the (DRAFT)Play Sufficiency Assessment. This data was benchmarked against two open space quantity standards outlined in the Open Space Provision for New Developments Supplementary Guidance (2021). Overall, Perth and Kinross exceeds both standards, as shown below: Quantity Standard 1: 80m² of open space per dwelling. With 70,120 residential properties, the provision equates to 100m² per dwelling. Quantity Standard 2: 3.5ha of open space per 1,000 people. Based on an estimated population of 150,800, the provision is 4.67ha per 1,000 people. As the Open Space Audit is still ongoing, only quantity figures have been provided at this time. This audit is expected to be completed in early 2025, after which quality and accessibility statements will be provided. Health Inequalities The LDP Guidance notes that “plans should prioritise actions in disadvantaged communities to ensure the sufficiency of provision of publicly accessible, high quality outdoor play opportunities for formal and informal play. This will help to tackle inequality in access to play and improve health and wellbeing outcomes for children in those areas.” Scottish Index of Multiple Deprivation data provides data-zone level information across a range of indicators including: • Income and employment • Health • Education/skills • Housing • Geographic accessibility • Crime Data-zones are ranked based on the multiple scores across the indicators. In the Perth and Kinross area there is significant disparity between most and least deprived areas. For example, there are areas identified within the most deprived 10% including in Perth and Blairgowrie/Rattray.
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Summary of Implications for the Proposed Plan: The initial implications of the evidence for the Proposed Plan which have been identified in this chapter are discussed in detail in this section. In summary, the main implications are: • Addressing play provision in low density settlements (<50 dwellings). • Increasing playground provision for children aged 4-8. Currently only 39% of dwellings in settlements meet the 400m accessibility standard for this age group. • Prioritisation of new play, recreation and sport opportunities for the demographics reported to have the lowest levels of activity: females, young people aged 12-17, and those living in the most deprived areas. • Target development of new facilities in rural hubs in areas experiencing or expecting significant growth (e.g. Auchterarder and Kinross) • Address demand pressures for new football and rugby pitch provision in Perth. • Facilitate development of sports halls: Only 42% of the population can walk to a sports hall within 20-minutes. 60% of which are living in the 10% most deprived areas. Average build date of sports halls is 1980 - the national average is 1990. • Facilitate development of sports pitches: Only 35% of the population is within a 20-minute walk of a pitch. 50% of which are from the 10% most deprived areas. • Improve multi-functionality of open spaces through the provision of new opportunities to address current and future requirements. Information on existing assets/facilities Information on existing assets/facilities will form part of the evidence used to consider where there are existing opportunities for play, recreation and sport. This provides a baseline information which will be used to inform the Spatial Strategy and policy framework development. In particular this information will be used to protect existing assets/facilities (including through land use designations) and identify opportunities for enhancement/improvement including the delivery of new opportunities which can provide multiple benefits as blue/green infrastructure. The future use and provision of assets and facilities will be guided by the Council’s Transformation Review of Leisure Assets (2024) and associated Committee Reports. SportScotland Facilities Planning Modelling also supplements data at the local level, using national trends/patterns to model how leisure facilities may be used in the future. Local and National plans & strategies To support the development of the spatial strategy and policy framework, future provision of, and opportunities for, play, recreation and sport, will be informed by the following national plans, policies and strategies: • Active Scotland Outcomes Framework (2018) • Play Strategy for Scotland (2013) and Progress Review (2018) • Physical Activity for Health: Scotland’s National Framework (2024)
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In terms of opportunities for play, recreation and sport, the spatial strategy and policy framework development will be informed by the following local plans, policies and strategies: • PKC Corporate Plan (2022-2027) • PKC Play Area Improvement Programme (ongoing) • PKC Policy on Provision for Outdoor Sports (2017) • PKC Transformation Review & Leisure Assets (2024) & associated Committee Reports • PKC Green Asset Management Plan (2017-2022) • PKC Physical Activity & Sport Strategy (2023-2028) • PKC Play Framework for Perth and Kinross (2019-2022) The LDP will continue to support local and national legislation and policy objectives to safeguard access to play, recreation and sport opportunities. Furthermore, it will look to increase opportunities for physical activity in demographics reported to have the lowest level in Perth and Kinross, these are: females, young people aged 12-17, and people living in the most deprived areas. Play Sufficiency Assessment and Open Space Strategy The Play Sufficiency Assessment and Open Space Strategy will be used to inform the Spatial Strategy and policy framework development, in particular with a focus on protecting existing assets/facilities (including land use designations) and identify opportunities for enhancement/improvement including the delivery of new opportunities which can provide multiple benefits as blue/green infrastructure. The spatial strategy will consider the multi-faceted nature of blue/green infrastructure and what opportunities there are for play, recreation and sport within this context. The PSA identified 52 designated settlements with no formal equipped areas for play adopted by PKC, however it is important to note these areas may be serviced by privately managed playgrounds. Settlements with <50 dwellings are currently not included in PKC's Playground Strategy due to low density. This is being reviewed as part of the Playground Strategy update being undertaken by PKC's Community Greenspace Service. Since the last Playground Strategy update, 12 of the settlements with no PKC adopted play now have more than 50 dwellings. The Open Space Audit has included an assessment of the various functions provided from open spaces, including play, recreation and sport. This will be used to identify sites where multi-functionality could be improved to offer a wider range of opportunities that address current and future requirements. Local Living and 20-minute Neighbourhoods Accessibility analysis conducted for both the PSA and OSS will inform the wider local-living and 20-minute neighbourhood analysis. Accessibility is assessed against existing standards referenced in this chapter. Catchment zones will provide an evidence-base for site-specific developer requirements, defining whether on-site or off-site contributions are required. Playground catchment zones mapped in the PSA will be used to identify locations with insufficient provision of play opportunities for 4-8 (400m) and 8-14 (1000m) age groups. At a minimum, the OSS will map catchment zones for public parks (700m), playing fields (1200m), and paths/green corridors (500m). Please note, accessibility standards are subject to review during the OSS development and thresholds may change. As a predominantly rural area, it is recognised that in lower density settlements it may not be feasible to develop new facilities. Perth and Kinross’ approach to Local Living will include a focus on rural hubs that
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provide facilities to service smaller rural settlements. Areas where significant growth has occurred or is expected will include an assessment of sports and leisure needs and demands. Big Place Conversation The Big Place Conversation results include detailed place-based comments on existing opportunities for play, recreation and sport in communities, as well as suggestions for improvements. This place-based evidence will be used to inform the spatial strategy and policy framework development in terms of the adequacy of existing assets/facilities and opportunities for improvement. This information can also support the development of community-led plans including Local Place Plans and Community Action Plans. Targeting areas of deprivation SIMD information will be used to inform the Spatial Strategy and policy framework development, in terms of targeting opportunities for improved play, recreation and sport in areas of deprivation and disadvantaged communities. Focus on Delivery LDP3 will have a focus on delivery through site-specific developer requirements for on-site and off-site contributions. For large-scale developments, these requirements will be further detailed through site masterplanning processes to ensure open space and play requirements and design standards are met. As well as delivery through development, opportunities may be realised through other means such as public sector programmes and infrastructure investment. Gaps, Uncertainties or Key Issues Raised: The provision of opportunities for play, recreation and sport is an evolving process as demonstrated by the asset review across the Council area. Close collaboration with relevant partners will be key to ensuring that the next Plan incorporates the most accurate information and provides an appropriate spatial strategy and policy framework to promote opportunities for play, recreation and sport. SportScotland data SportScotland Facilities Report (2024) is dependent upon feedback from key stakeholders and therefore may not be complete/accurate. This information is used alongside existing local information and datasets, including evidence presented above under ‘Existing Assets’. SportScotland Facilities Planning Modelling (2024) is based on modelling and not actual usage of facilities, and demand levels are based on national surveys. To support an accurate as possible evidence base on facilities modelling, local data held by PKC and Live Active Leisure (as operators) is used to determine existing and modelled usage. PSA limitations The PSA does not include privately managed equipped play areas. These will be identified, assessed, and included in the PSA outputs to help address the gaps in provision and accessibility. The current Playground Strategy considers the 4-8 and 8-14 age groups. This has resulted in a data gap regarding provision of activities for children and young people out with this range. The Strategy recognises there will be children on either side of the 4-14 target age range that will use the equipment, but that younger children require more supervised facilities, such as nurseries, and older children seek other forms of play such as sporting, cycling and skating opportunities. The PSA only includes equipped playgrounds.
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Additionally, it is important to note the Playground Strategy excludes settlements of less than 50 houses as the density is too low to justify provision. This is being reviewed as part of this PSA and forthcoming Playground Strategy Update. Summary of Stakeholder Engagement: Engagement took place with relevant internal teams and SportScotland in preparing the Evidence Report. The views of the following stakeholders were also sought: • A Place in Childhood • Play Scotland
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Statements of Agreement/ Dispute Eight responses were received on our Play, Recreation and Sport Topic Paper. Most respondents (6 out of 8) either agreed with or had no comment to make on the evidence identified through Topic Paper 022, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered. A summary of these comments, their status, and the Council’s response are provided in the table below. There was 1 response on the Play, Recreation and Sport 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. One respondent disagreed with the sufficiency of the list of evidence and implications of that evidence for the Proposed Plan. That response is highlighted in orange. Respondent Agree or Dispute Summary of Comments PKC’s Response Errol Community Council Disagree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The Community Council indicated that they disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 022, and our summary of implications of that evidence for the preparation of the Proposed Plan. Further Comments: Disagree that evidence is sufficient noting that the Play Sufficiency Assessment has not been published, the Open Space Strategy is only being prepared, and the SportScotland Facilities Planning Modelling is incomplete. Concern is also raised regarding the summary of facilities for Eastern Perthshire (Appendix 3) is representative of the Carse of Gowrie and Errol Community Council. Formal Dispute: Errol Community Council do not wish for their response to be treated as a formal dispute. The Play Sufficiency Assessment Storymap is now publicly available and key findings have been included in this chapter. Open Space Strategy. Initial site visits for the Open Space Audit were concluded in 2024 and are currently under review. Results are expected to be published in Q2 of 2025. Resource constraints are a factor, and the timeline largely depends on whether further site visits are needed. The audit outcomes will inform the development of the Open Space Strategy, as well as the settlement audits for the preparation of LDP3 in 2025.
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Respondent Agree or Dispute Summary of Comments PKC’s Response SportScotland Facilities Planning Modelling has been published for use by local authorities. As noted in the chapter, this forms part of the evidence – alongside local information sources - to be used to help forecast potential future facility use. Appendix 3 of the Topic Paper (022) presents a high-level summary of the facilities for Eastern Perthshire included in the PKC Sport & Physical Activity Strategy. A comprehensive list of facilities for each settlement forms part of the Evidence to be used to inform the next Plan’s Spatial Strategy, including through the Council’s Transformation Review of Leisure Assets (2024). NatureScot Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): NatureScot indicated that they neither agreed nor disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 22, and our summary of implications of that evidence for the preparation of the Proposed Plan. No further action required.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Further Comments: NatureScot welcomed consideration of play spaces into blue green infrastructure. Formal Dispute: NatureScot do not wish for their response to be treated as a formal dispute. SportScotland Dispute List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): SportScotland indicated that they disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 022, and neither agreed nor disagreed with our summary of implications of that evidence for the preparation of the Proposed Plan. Further Comments: Sport Facilities Report (2024) Note that Sport Facilities Report (2024) has been published on the Improvement Service Spatial Data Hub and should be referenced in the Evidence. In addition, the Sport Facilities Report (2024) is dependent upon feedback from key stakeholders and therefore may not be complete/accurate. As such, the Evidence Report is recommended to be updated to reflect the limitations of the shared dataset as well as to reference other supplementary sources of information/data. Understanding Need: SportScotland Facilities Planning Modelling SportScotland highlight that the Facilities Planning Modelling is based on modelling and not actual usage of facilities, and demand levels are based on national surveys. Therefore additional local sources of Comments noted. The Evidence Report has been updated and includes a reference to the data limitations of both the Facilities Report (2024) and Facilities Planning Modelling (2024) in the ‘Gaps & Uncertainties’ section. Reference is also made to local data held by PKC and Live Active Leisure which supports the future of leisure assets in the Council area. This is reflected in the Council’s Transformation Review of Leisure Assets (2024). A SportScotland Facilities Report 2024 map has been produced and linked to in this chapter.
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Respondent Agree or Dispute Summary of Comments PKC’s Response information are recommended to be included and referenced within the Evidence Report. Formal Dispute: SportScotland wish for their response to be treated as a formal dispute. Montagu Evans LLP 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 022, and our summary of implications of that evidence for the preparation of the Proposed Plan. Further Comments: No further comments to make. Formal Dispute: The respondent does not wish for their response to be treated as a formal dispute. No further action. Scottish Water Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Scottish Water indicated that they neither agreed nor disagreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 022, and our summary of implications of that evidence for the preparation of the Proposed Plan. Further Comments: Scottish Water note importance of including areas that facilitate play, recreation and sport within PKC catchment areas. Scottish Water supports the need to incorporate measures that assist managing climate change as well as promoting delivering of nature based blue-green infrastructure that facilitate play, recreation and sport. Scottish Water also support recognition of PKC Water Safety Policy highlighting importance of safety around water-based assets. Comments noted. No further action.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: Scottish Water do not wish for their response to be treated as a formal dispute. Private Individual 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 022, and our summary of implications of that evidence for the preparation of the Proposed Plan. Further Comments: Respondent highlights that importance of local community led and development facilities and opportunities is not given sufficient weight. Formal Dispute: The respondent does not wish for their response to be treated as a formal dispute. Comments noted. The section on ‘Community facilities’ has been updated to highlight the importance of existing community facilities as well as to recognise the role for the next LDP, where appropriate, in supporting emerging proposals identified through community- led plans. Earn Community Council Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Earn Community Council indicated that they agreed with the sufficiency of the list of evidence/datasets identified in Topic Paper 022, and our summary of implications of that evidence for the preparation of the Proposed Plan. Further Comments: A number of proposed improvements/suggestions are made to improve play, recreation and sport opportunities in the local area. The Community Council also note that the Story Board for Kinross, Almond & Earn (Appendix 7, p.24) does not include listing for Forteviot, and Abernethy and Bridge of Earn are two separate communities. Formal Dispute: Earn Community Council do not wish for their response to be treated as a formal dispute. Suggestions for enhanced play and recreational opportunities within the community will be included as part of the evidence to be used to shape the Spatial Strategy, alongside the results of the Big Place Conversation and other engagement activities. The Appendix of the Topic Paper (TP022) presents a high-level summary of the facilities for Kinross-shire, Almond & Earn included in the PKC Sport & Physical
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Respondent Agree or Dispute Summary of Comments PKC’s Response Activity Strategy. A comprehensive list of facilities for each settlement forms part of the Evidence to be used to inform the next Plan’s Spatial Strategy including through the Council’s Transformation Review of Leisure Assets (2024). Savills o/b/o Dupplin Estate 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 022, and our summary of implications of that evidence for the preparation of the Proposed Plan. Further Comments: Reference is made to Perth Sustainability Park and the opportunities for play, recreation and sport that this would provide including for people with impaired mobility. It is also noted that the development will add critical mass to the local area supporting the golf course viability. Formal Dispute: The respondent does not wish for their response to be treated as a formal dispute. Comments noted. The merits of sites, including benefits of improved play, sport and recreational opportunities associated with these, will be assessed further as part of the development of the Spatial Strategy of the Proposed Plan.
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Issue: Flood Risk and Water Management (Including Drainage and Water Supply Systems) Corresponding NPF4 policies: • NPF4 - policy 22 Flood risk and water management • Other key NPF4 policy connections - 1 Tackling the climate and nature crises, 2 Climate mitigation and enhancement, Policy 3 Biodiversity, Policy 8 Green belts, Policy 10 Coastal Development Policy 14 Design, Quality and place, Policy 15 Quality Homes, Policy 18 Infrastructure first, Policy 20 Blue and Green Infrastructure, Policy 23 Health and Safety, and Policy 26 Business and Industry Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 023: Flood Risk and Water Management (https://consult.pkc.gov.uk/communities/topicpapers/supporting_doc uments/TP0023_Flood_Risk_and_SFRA.pdf) Information required by the Act and NPF4 regarding the topic: In line with the requirements of the Act, section 15 (5) this paper will have regard to: • principal environmental characteristics of the district and Regulations 9, require Local Authorities to have regard to: • any river basin management plan; • any flood risk management plan; and • any local flood risk management plan; • any other flood risk management projects that support or align with the above noted bullets Additionally, under NPF4 Policy 22, NPF4 expects Local Development Plans to: • strengthen community resilience to the current and future impacts of climate change, by avoiding development in areas at flood risk as a first principle. Resilience should also be supported by managing the need to bring previously used sites in built up areas into positive use; planning for adaptation measures; and identifying opportunities to implement improvements to the water environment through natural flood risk management and blue green infrastructure • take into account the probability of flooding from all sources and make use of relevant flood risk and river basin management plans for the area. A precautionary approach should be taken, regarding the calculated probability of flooding as a best estimate, not a precise forecast. For areas where climate change is likely to result in increased flood exposure that becomes unmanageable, consideration should be given to alternative sustainable land use 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 22, this guidance also expects Local Development Plans to: • take a strategic ‘whole systems’ approach to flood risk and water management, aligning with infrastructure first principles, blue and green infrastructure, and open space, active travel and nature networks
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• consider preparing, or reviewing for spatial implications Surface Water Management Plans • reference a Strategic Flood Risk Assessment (SFRA) in the Evidence Report and the at risk areas identified Links to Evidence: Flood risk • Strategic Flood Risk Assessment (February 2025) (Core Doc Ref: CD25) • SEPA Future Flood Maps • SEPA low likelihood (present day) surface water flood risk mapping • Planning Information Note 4 (PIN4) SEPA position on development protected by a flood protection scheme • SEPA Flood Risk Standing Advice for Planning Authorities (July 2024) • Scottish Government Flood resilience strategy (December 2024) • Scottish Water's Climate Adaptation Plan 2024 • SEPA Flood Risk and Land Use Vulnerability Guidance • Strategic Environmental Assessment: Development Plan Site Assessment • Tay Flood Risk Management Plan (December 2021) • Forth Flood Risk Management Plan (December 2021) • Forth Estuary Flood Risk Management Plan (December 2021) • Tay Estuary and Montrose Basin Flood Risk Management Plan (December 2021) • Tay Local Flood Risk Management Plan (December 2022) • Forth Local Flood Risk Management Plan (December 2022) • Forth Estuary Local Flood Risk Management Plan (December 2022) • Tay Estuary and Montrose Local Basin Flood Risk Management Plan (Interim issue May 2019) • Mapping flood disadvantage in Scotland 2015 • Futurefloodmap_explanatory_note_version_4_(November_2023) • Big Place conversation summary report Climate change and coastal changes • Dynamic Coast webmaps (2021) • Coastal Change Adaptation Guidance • Climate Change Risk and Opportunity Assessment (August 2023) • Climate Change Master Action Plan (August 2024) (Core Doc Ref: CD6) • River basin management plans for Scotland (December 2021) • SEPA Recommended Riparian Corridor Layer for use in Land Use Planning (July 2024) (Core Doc Ref: CD23) Water environment • SEPA’s water environment hub • SEPA’s water classification hub • River basin management plans for Scotland (December 2021) • Drinking water protected areas - Scotland river basin district maps (2014) Private Water Supplies • SEPA information on water scarcity • Water scarcity in Scotland (arcgis.com) (November 2023) knowledge review on water scarcity by University of Dundee
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• James Hutton Institute Executive Summary of Climate Trends (July 2023) • CREW (Centre for Expertise for Waters) report, Private Water Supplies and Climate Change • PKC call out records to private water supplies which have previously dried up (Core Document Ref: CD24) Summary of Evidence: Flood risk Strategic Flood Risk Assessment (February 2025) is designed to inform the development planning process, primarily to reduce vulnerability of development to flooding by avoiding the flood risk area as defined in NPF4. This is prepared by the planning authority in consultation with Scottish Environment Protection Agency (SEPA). The draft SFRA has been finalised after taking onboard feedback from this consultation. 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. 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 extent, as identified in the SFRA, taking account of both SEPA and flood study mapping. SEPA low likelihood (present day) surface water flood risk mapping when future surface water flood map layer is available (expected by Spring 2025 latest), this will be used instead. However, the surface water present day low likelihood flood map layer, available in the Flood Map Viewer, is the best proxy in the meantime. This layer used the medium likelihood flood event with an increase in rainfall intensity of 20% nationally. This layer may provide a first indication of those areas potentially at risk from surface water flooding in the future, however due to projected changes in rainfall intensity it may not show all locations that may be affected in the future. A Surface water management plan is currently being prepared for several communities, and where available timeously, these plans will be used to inform identification of areas at risk. Planning Information Note 4 (PIN4) SEPA position on development protected by a flood protection scheme (July 2024) supports interpretation of NPF4 policy 22 Flood risk and water management. This document clearly articulates the SEPA position regarding development behind existing formal flood defences, and how informal defences should be accounted for. SEPA Flood Risk and Land Use Vulnerability Guidance (July 2024) supports interpretation of NPF4 policy 22 Flood risk and water management.
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SEPA Flood Risk Standing Advice for Planning Authorities (July 2024).supports interpretation of NPF4 policy 22 Flood risk and water management. Scottish Government Flood resilience strategy (December 2024) sets out views on what is needed to make places more flood resilient in the longer term. Scottish Water's Climate Adaptation Plan 2024 sets out Scottish Water's long term priorities in dealing with and adapting to climate change which is putting pressure on our infrastructure serving Scotland. This includes, flood risk increase, water scarcity and drought management planning as well as consumer water use. Strategic Environmental Assessment: Development Plan Site Assessment prepared jointly by Historic Environment Scotland, Nature Scot and Scottish Environment Protection Agency provides a template for site assessment which will be the basis for assessment (some additions anticipated) and will be used at Proposed Plan stage. There is a Tay Flood Risk Management Plan (December 2021), a Forth Flood Risk Management Plan (December 2021), a Forth Estuary Flood Risk Management Plan (December 2021), and a Tay Estuary and Montrose Basin Flood Risk Management Plan (December 2021) which have been prepared by SEPA produced with the support and collaboration of the relevant local authorities. Land use planning objectives and actions have been agreed with responsible authorities, which will ensure flood risk is adequately considered in local planning decisions, and the Proposed plan will support their implementation. There is a Tay Local Flood Risk Management Plan (December 2022), a Forth Local Flood Risk Management Plan (December 2022), and a Forth Estuary Local Flood Risk Management Plan (December 2022) which Perth and Kinross Council prepared , and a Tay Estuary and Montrose Basin Local Flood Risk Management Plan (Interim issue May 2019), which Perth and Kinross Council contributed to the preparation of. These plans set out in more detail how the actions of the Flood Risk Management Plans will be achieved. A Surface water management plan is currently being prepared for several communities. Scottish Water and Perth and Kinross Council are working in partnership on the outputs from the Perth Integrated Catchment Study (ICS), and Perth & Kinross Council are engaging consulting engineers to complete the flood study and to develop the Perth Surface Water Management Plan which has an estimate timescale completion of the initial phase is Spring 2025. The Proposed plan will support their implementation. Climate change Dynamic Coast webmaps (2021) provides a broad planning tool and makes necessary assumptions about our future climate and management action. This information will be used to inform site selection, and settlement summary text in the Proposed Plan. This is discussed in greater detail in the Evidence Report section on Coastal Development and Aquaculture. Coastal Change Adaptation Guidance supports Local Authorities to develop their Coastal Change Adaption Plans (CCAP). PKC received funds for a Coastal Change Adaption Plan, to enable its production and if available in time it will inform the Proposed Plan. This is discussed in greater detail in
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the Evidence Report section on Coastal Development and Aquaculture Appendix A8. Climate Change Risk and Opportunity Assessment (August 2023) 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. Climate Change Master Action Plan (August 2024) (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. Mapping flood disadvantage in Scotland 2015 is most relevant to Flood Risk Management Planning. Nearly all of the acutely and extremely socially vulnerable and flood-disadvantaged data zones were located within PVAs, despite differences in the underlying data and methodology. Therefore, the results of the disadvantage assessment can be used to support Flood Risk Management Strategies / Plans developed for each of the 14 Local Plan Districts covering Scotland that take into account PVAs. It notes that alongside Stirling, the Scottish Borders, and Moray, Perth and Kinross has the highest average proportion of residential properties exposed to river flooding. The Mapping flood disadvantage in Scotland 2015 study also expresses concerns about and conclusions on the reasons for properties built on floodplains after January 1st, 2009. These were broadly either: firstly, that they were in process for a long time before construction and the FRA was based on earlier data; secondly, a sense that there were many competing priorities besides flooding and planners must make pragmatic decisions; or thirdly, that elected members can go against officer recommendation and approve planning applications. Recommended Riparian Corridor Layer for use in Land Use Planning (July 2024) A GIS layer has been prepared which indicates the minimum space needed along rivers to give rivers space to adapt to changes in flood frequency and magnitude and to provide a range of benefits. This layer will be used to inform Blue Green Infrastructure and Nature Network mapping, as well as for site specific considerations regarding allocations through the Strategic Environmental Assessment site assessment which will be used at Proposed Plan stage, but will be adapted to include consideration of the riparian corridor. Geomorphic Risk Layer which identifies sections of river where channel adjustment was likely to be significant (e.g. high erosion or deposition). Development adjacent to these zones which have greater risk of river erosion should be considered (to ensure sufficient space around these sections). A guidance document is still being finalised, but a summary is provided on SEPA publication data website under i. This layer will be used to inform Blue Green Infrastructure and Nature Network mapping, as well as for site specific considerations regarding allocations through the Strategic Environmental Assessment site assessment which will be used at Proposed Plan stage, but will be adapted to include consideration of potential channel adjustment.
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Water environment River basin management plans for Scotland (December 2021) set out a framework for protecting and improving the water environment and consequentially the benefits provided by the water environment across Scotland. It focuses on reducing resource use, eliminating waste and restoring natural capital. It covers rivers, lochs, transitional waters (estuaries), coastal waters, groundwater, and groundwater dependant wetlands, and sets out actions for public bodies, industry, and land managers in Scotland. Information on the current status of a water body, will be taken from the water classification hub, whilst pressures affecting it, measures required to address those pressures, and deadlines for achieving those measures will be extracted from the SEPA’s water environment hub. The Strategic Environmental Assessment site assessment (as a base although there may be some additions to it) which will be used at Proposed Plan stage to consider potential allocations considers flood risk, and water environment, and when considering impact on the water environment condition there will be reference to the RBMP and to the most recent water classification data, and to information on drinking water protected areas. Private Water Supplies Private water supplies are presumed against in NPF4 unless they will be sourced from a sustainable water source that is resilient to periods of water scarcity. SEPA ‘regulate’ water abstractions under CAR, abstractions of less than 10m3/day (equivalent of 50 population) (single property to group of properties) are controlled by General Binding Rule 2 which means that there should be a method of demonstrating the abstraction is less than 10m3 in any day ie flow measurement, and that water leakage must be kept to a minimum. There are a series of generic conditions contained in the CAR that must be complied with. Further ‘regulation’ is not required if these 2 factors are met. Larger abstractions up to 50m3/day (equivalent population 250) (eg decent sized caravan site) need ‘registration’ under CAR. Larger abstractions are dealt with by SEPA issuing either a simple or complex licence. However, the CAR process does not take into account the adequacy of the source water eg stream, loch, spring, borehole etc (especially when controlled by GBR2 which would likely be the largest chunk of proposals) and therefore there is a need for the planning system to assess whether private water supplies are sourced from a sustainable and resilient water source. SEPA provides information on water scarcity. Also, there is a knowledge review on water scarcity by University of Dundee Water scarcity in Scotland (arcgis.com) (November 2023). This refers to a recent study commissioned by NatureScot which shows how these changes could result in droughts becoming more frequent, longer and more severe even over the next 2 decades. For more details on climate trends there is also a James Hutton Institute Executive Summary of Climate Trends (July 2023) projections and extremes in Scotland and implications for Natural Capital and Policy paper. There is also a CREW (Centre for Expertise for Waters) report, Private Water Supplies and Climate Change which considers the vulnerability of existing Private Water Supplies to climate change and potential mitigations. Using risk mapping, this study estimates that approximately half of the Private Water Supplies in Scotland are estimated to be within areas of High or Very High (risk categories between 2020 and 2050). This
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study identifies at risk areas through a Drought Risk Indicator (figure 15) to help identify locations of high Private Water Supplies density and high probability of experiencing dry years in the future. The category is a combination of the density of Private Water Supplies and probability of dry years increasing. The purpose of this indicator is to illustrate where in Scotland the highest probability of increased precipitation deficit is. However, The James Hutton Institute Climate Data Visualisation paper includes the Climatic Water Balance and is an improved estimate of meteorological water scarcity, at a 1km resolution (whilst figure 15 from the CREW Private Water Supplies and Climate Change report was 12km). Also supplementing this research, the Council has its own records of where there have been callouts for private water supplies due to a water scarcity issue, and whilst this is not going to be an exhaustive list, as it is dependent on users making contact, it could be useful in identifying areas of concern. The CREW report recommends policy prescription on fit-for-purposes technologies for collection and treatment of water is a feasible way to help build resilience in decentralised, small rural supplies. For example, a change of source (e.g. from spring to borehole) can be a sensible course of action in areas where bedrock aquifers have the potential to sustain borehole water supply, and when vulnerability to drought and contamination co-occur for a given Private Water Supply or supply zone. Also, the report identifies the potential role of household water storage capabilities as back-up support to non-drinking water uses during drought. This may be more suitable for non-drinking water use. Summary of Implications for the Proposed Plan: Flood risk The current Perth and Kinross Local Development Plan (LDP) 2019 identifies appropriate opportunities for development with controls applied within flood risk areas. However, this LDP2 was based on Scottish Planning Policy (SPP) 2014, and the new NPF4 introduces ‘at risk areas’ which refer to the SEPA future flood maps which include climate change projections. The Proposed Plan will accord with NPF4, refer to these future flood maps, and use the SEA site assessment template to assess risk for all proposals being considered for potential LDP3 allocation. During preparation of the Proposed Plan at the Call for Sites and Ideas stage the Council 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. The analysis of existing LDP2 allocations in the SFRA will inform the spatial strategy of LDP3, it could act as a screening tool for identifying sites which will need further analysis of flood risk constraint. 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. Resilience will also be supported by managing the need to bring previously used sites in built up areas into positive use (dependent on the vulnerability assessment) and planning for adaptation measures. The mapping flooding disadvantage in Scotland study was concerned about new properties being built within the floodplain. It indicates key reasons why and this knowledge could potentially inform the preparation of the Proposed Plan as the objective is to limit the future instances.
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Water environment SEPA’s water environment hub and the Blue Green Infrastructure (BGI), and Nature Network (NN) mapping will be used to complete SEA site assessments at the Proposed Plan stage. The analysis of natural flood risk management opportunities within the SFRA will also inform future blue and green infrastructure mapping considered in the Evidence Report section 21 Blue and Green Infrastructure. This mapping tool will be used to identify existing pressures on water bodies and the site assessment will identify whether policies and proposals are likely to exacerbate existing pressures, create new problems and offer opportunities for enhancement. Please refer to the evidence report issue B3 on Blue and Green Infrastructure in Appendix B for more information on this mapping. Climate change and coastal changes The Perth and Kinross area faces a range of development pressures and future threats from sea level rise and flood risk. The future of Perth harbour, sea level rises, and coastal erosion risk is covered in Appendix A8 the Coastal Development and Aquaculture issue. Private Water Supplies In terms of Private Water Supplies, NPF4 presumes against these unless they will be sourced from a sustainable water source that is resilient to periods of water scarcity. A review of currently available studies has been undertaken. There are useful sources of information such as the drought risk indicator. The drought risk indicator is available as a GIS layer for Local Authorities to use, however it is likely to prove advisable to use more up to date, and better resolution climatic water balance mapping from The James Hutton Institute Climate Data Visualisation. However, there is no equivalent to the SEPA flood risk mapping to identify which areas are at most risk, nor an associated national planning policy approach for these areas. Therefore, at Proposed Plan stage there will be a need to consider the potential use of • drought risk indicator/water scarcity mapping • alongside other information the Council holds about places where private water supplies have previously dried up • information about the type of source proposed to establish where Private Water Supplies may not be sourced from a sustainable water source that is resilient. In this situation perhaps a Local Development Plan requirement might be placed on the developer to conduct a Private Water Supplies risk assessment considering climate change related risks and/or adopt measures to make their supply more resilient. Environmental Health colleagues have intimated that they wouldn’t expect a treatment specialist to be able to comment on the risk of climate change and this would require specialists such as geologist, hydrogeologist which is likely to be costly and perhaps difficult to source, so the chosen approach will need to be proportionate to the risk. Gaps, Uncertainties or Key Issues Raised: Flood risk Whilst if a site is within an at-risk area, the NPF4 policy approach is clear, if a site is partially within, the approach is still clear, but what is fairly unclear until you get to the planning application stage is which areas are within the at risk area. Also, whilst SEPA medium likelihood future flood risk 2080 river and coastal flood risk mapping is the best proxy for the at-risk flood
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risk areas mentioned in NPF4, this is currently based on UK 2009 Climate projections but will be updated to reflect the UK 2018 climate change projections. If this updated climate change mapping is available this will be used in site assessment for the Proposed Plan. Should the Proposed Plan promote sites where a potential flood risk is identified on part of the site, then it will be necessary to assess them using the allowances to calculate the area “at risk of flooding or in a flood risk area” and this will clarify the developable area. To address this gap during the preparation of the Call for Sites and Ideas 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 extent, as identified in the SFRA, taking account of both SEPA and flood study mapping. Consideration of the research on mapping flooding disadvantage suggests to properly implement policy and limit the instances of development within at risk/floodplain areas, there could be an enhanced focus on member engagement on flood risk matters. One of the other reasons mentioned (of sites taking time to come forward and being based on an older FRA) is largely outwith the Local Authorities control. However the approach taken at Mu73 Almond Valley whereby on this long term strategic site, the overall masterplan permission requires each phase which comes forward as a planning application to be based on a new FRA could be a way to mitigate this issue. Water environment Findings of the SFRA help identify some potential opportunities to implement improvements to the water environment through natural flood management and blue green infrastructure. However, the Proposed Plan spatial strategy will identify and protect blue and green infrastructure assets and networks (via the Planning (Scotland) Act 2019, and subsequently NPF4); and seek to enhance and expand existing provision including new blue and/or green infrastructure. Blue and Green Infrastructure is considered in more detail in Appendix B3. Private Water Supplies The drought indicator method has not been developed to assess individual Private Water Supplies and is not provided at a finely grained resolution (12 km). However, the drought indicator alongside other water scarcity mapping, and Council call out records for water scarcity, could prove a useful starting point to determine vulnerable locations. It could potentially help identify where a Private Water Supplies risk assessment procedure considering climate change related risks is required and/or where/when a planning response and mitigations may be required. 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 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
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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. Prior to the topic paper consultation, there was early engagement with SEPA and with Council Flood teams to seek information needed for preparation of the draft SFRA. A draft of the SFRA and the topic paper was then circulated to SEPA and our Flood team prior to their formal consultation. The feedback received was largely addressed prior to the formal consultation, however the inclusion of flood study mapping took time to locate, and bring into formats that it could be included within the SFRA. The Council looked to resolve these outstanding matters prior to finalising the Evidence Report for Gatecheck. As per SEPA guidance on producing a SFRA, this finalised SFRA was sent to SEPA, Perth and Kinross Council Flood team and Building standards teams, Scottish Water, and Scottish Canals, for final comment. This finalised SFRA was consulted on in December 2024 and then final amendments were made to reflect the views of SEPA and Scottish Water prior to publication in February 2025. Please note that Perth and Kinross Council is working on producing an online interactive SFRA, to inform the Call for Sites and Ideas which is programmed for April/May 2025. Prior to the topic paper consultation, there was early engagement with Environmental Health colleagues to seek information needed concerning private water supplies. Post topic paper consultation there was further engagement with the James Hutton Institute, and with Environmental Health and SEPA to help inform revisions to this Evidence Report Issue content on private water supplies. The Big Place conversation summary report has a feeling safe indicator, where participants 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 tended to have a significant impact on feeling safe. Suggestions were made to improve drainage and flood protection, and to develop community resilience including rapid response teams. The care and maintenance indicator for the BPC Place Standard consultation asked are there spaces or buildings that need cleaning up or fixing in the area. A summary of the comments on this topic identifies that blocked drains and farmland/hillside run off exacerbate flooding issues, again improving drainage/flood protection were suggested.
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Statements of Agreement/ Dispute 18 responses were received on our Flood Risk and Water management Topic Paper. Over 40% of the respondents either agreed with or neither agreed nor disagreed with the evidence identified through Topic Paper 023, or the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and/or highlighted other potential implications for the Proposed Plan. A summary of these comments, their status, and the Council’s response are provided in the table below. Three respondents wished their comments to be treated as a formal dispute to the Evidence Report (highlighted in red), a further 6 indicated some disagreement with the evidence (highlighted in amber). Respondent Agree or Dispute Summary of Comments PKC’s Response Ristol Consulting Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Ristol Consulting agreed with the list of evidence/datasets for Topic Paper 023, and notes necessity of ensuring SFRA is consistent with SEPAs future Flood Maps to ensure policy interpretation is aligned. Further Comments: Considers that new approaches to climate change may run counter to previous policy approaches, often as a result of locational considerations, and enable positive change in line with NPF4's spatial principles and strategy. Future policy and guidance, particularly for a 10 year plan period, should provide flexibility to enable the delivery of sustainable land use patterns. Formal Dispute: Ristol Consulting does not wish to make a formal dispute. Note comments regarding the need to consider new approaches for climate change, and considering how and when flexibility can be provided, this will be considered when preparing the Proposed Plan. There will be further engagement as PKC prepare the Proposed Plan. 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 for Topic Paper 023, and neither agrees nor disagrees with the implications for the Proposed Plan. Appreciate at this stage that there can be some uncertainty for stakeholders. There will be further engagement as PKC prepare the Proposed Plan.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Further Comments: No further comments Formal Dispute: Errol Community Council does not indicate whether they want to make a formal dispute. 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: This is a fairly long topic paper. It would be useful to have a contents page. It would be worth adding all the policy connections listed under Policy 22 of NPF4 (p. 75). 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. Agree it was an oversight that there was no contents page included, and the topic paper would also have benefited from this. Agree, the topic paper was more focussed on the most important of these policy connections, but the Evidence report now acknowledges all policy connections listed under Policy 22 of NPF4. SEPA Disagreed initially, but this dispute was resolved 06/02/2025 List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): SEPA consider the Water classification hub should be included as the source of evidence for most recent water classification data. They also point to outputs of detailed flood studies (Comrie, Coupar Angus, Dunkeld and Birnam, Perth, Blackford, Kinross and Blairgowrie) being absent from the draft SFRA maps. Further Comments: SEPA note work is ongoing with flood management colleagues to obtain access to the mapped outputs of the detailed flood studies. Regarding paras 2.19 and 2.27 SEPA support the inclusion of the water environment in the site assessment and the RBMP pressures and actions may identify opportunities for improvement. However, Blue Green Infrastructure (BGI), and Nature Network (NN) mapping, to be compiled to inform the List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Unfortunately, it was not initially appreciated that the water classification hub is a different source from the water environment hub and provides the most up to date information on water quality. The Evidence Report has been updated to include the water classification hub as well as the water environment hub which was always mentioned. The reported 2020 data within the Whole Plan area Issue, was taken from an environmental baseline collated for a recent Strategic Environmental Assessment for another Council strategy, but it is recognised that that data has now been superseded. Our LDP3 SEA Scoping Report uses the 2022 data included in the Water Classification Hub and RBMP key pressures and actions available via the Water Environment Hub, and the Flood
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Respondent Agree or Dispute Summary of Comments PKC’s Response proposed plan, are other sources of evidence for the site assessment process which will be instrumental in identifying opportunities to protect and improve the water environment at a site scale. The inclusion of water environment evidence in this mapping process is important in supporting the delivery of multi-functional BGI and NNs and climate resilient places. SEPA note that changes have been made to the Topic Paper in response to SEPA’s comments from 26 June 2024. In particular, the maps and accompanying key in the first version were very blurred and therefore hard to interpret, and we note that this issue has been fixed. We have some minor points to highlight that could be corrected/updated in the finalised version of the SFRA: Section 2.1 - recommend this should say 'avoid the flood risk area as defined in NPF4' rather than ‘avoiding areas of flood hazard’. Section 2.4 - recommend that reference is made to localised Surface Water Management Plans being a useful source of information for this issue, e.g. Blairgowrie, part of Dunkeld Study and the one currently being done for Perth. Section 2.5 and 2.6 - Please note that from July 2024 our updated and published guidance can be found here: development-behind-defences.docx (https://www.sepa.org.uk/media/nlyfx2v3/development- behind-defences.docx); and here land-use-vulnerability- guidance.docx (https://www.sepa.org.uk/media/nvnotwqd/land-use- vulnerability-guidance.docx) Risk and Water Management issue of this Evidence Report also incorporates both sources of evidence. Mapping from the following flood studies was added to the SFRA before it was finalised and published February 2025: Bankfoot 2007 Coupar Angus 2007 Perth Town Lade 2013 Comrie/Dalinross 2013 Pitlochry 2018 Aberfeldy 2019 Blackford 2019 Dunkeld and Birnam 2022 Blairgowrie 2024 Surface Water Management Plan This includes Pitlochry, Aberfeldy and Bankfoot flood study information which was beyond SEPA’s original request. However, Kinross 2021 outputs requested by SEPA, is not available yet to the Council, but should be available soon, and certainly prior to Call for Sites stage. SEPA have indicated when available the flood study modelled extents within Kinross flood study 2021 is an improvement and should be used preferentially once available. The SFRA has been published in the meantime, as SEPA have provided a general statement of agreement with the SFRA in its current form. A table indicating what Flood Study data has been provided, and what will follow, and
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Respondent Agree or Dispute Summary of Comments PKC’s Response Page 155 – Tay at Aberfeldy - Note that the Caravan Park was badly affected on 6/7 October 2023 where vehicles and caravans had to be towed out of flood water, and on the Moness Burn, some properties at the lower end of the burn were also flooded in 2002. Lastly, in response to the question posed on page 11, we advise that if flood risk assessment (FRA) is deemed necessary following consideration of the information included in the SFRA, this should be undertaken prior to the inclusion of a site in the Proposed Plan. Please refer to our previous response to the draft version of the paper for comments on any other relevant issues. Formal Dispute: SEPA has a formal dispute. The water classification hub is the RBMP data source which provides the most recent classification data regarding the water environment should be included as an evidence source. SEPA’s position could be reviewed if written confirmation is provided that the water environment hub will be included as an evidence source for this topic prior to submission to the Gate Check. It is understood that further work is to be done on the SFRA following this consultation. However, SEPA can confirm we dispute the draft SFRA due to the absence of the mapped output from the detailed studies. This position could be reviewed if a finalised SFRA which includes output from the detailed studies is provided prior to submission to the Gate Check. indicating how the Flood study mapping should be used alongside SEPA indicative mapping has been provided within the published SFRA. Unfortunately, it has not been possible to get the SFRA online before finalising it. It is not a requirement, but the intention is to hopefully get this online before Call for Sites and Ideas which is planned for April/May 2025. The online/amended SFRA will be published using the best available flood mapping at that point in time. It is agreed that the Blue Green Infrastructure and Nature Network mapping is important to the site assessment process, and to protecting and improving the water environment. This has been acknowledged and reference to the water classification hub has been added, in addition to the reference to the water environment hub. Also, changes have been made to Evidence Report for this Flood risk and water environment section to better acknowledge role of Blue Green Infrastructure (BGI), and Nature Network (NN) mapping in relation to this data informing the spatial strategy and the Proposed Plan blue green network. Note changes made to SFRA, and improvements to the quality of the mapping for the published draft SFRA. Agree change to SFRA paragraph 2.1 to refer to flood risk area as defined in NPF4.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Note SWMPs will be a useful resource for identifying areas at risk, and appropriate amendment has been made to reference this. Note the updated SEPA guidance documents for development behind defences and for land use vulnerability have now been published, these links to updated guidance have been provided. Note that the flooding event on 6/7 October 2023 affecting the Aberfeldy caravan park is noted in the SFRA on para 4.8, whilst the properties flooded at lower end of burn in 2002 are shown on figure 6. Agree that FRA should be undertaken prior to potential inclusion of a site in the Proposed Plan if it might be within an at risk area, this is acknowledged within this Issue and within the SFRA (para ref 3.5 and 3.13). Please also note further amendments have been made to reflect advice provided at a SEPA HOPs session on LDP evidence for Flood risk and water management held on 3rd of September. Reference has been added to new guidance on recommended riparian corridor layer and geomorphic risk buffer layer. Also referring to previous comments from SEPA provided 26th June 2024, previous amendments have either addressed them, or the comments are now covered in this SEPA representation. However, there was an additional comment about Private Water Supply (PWS) information sources, identifying that PKC Environmental Health (EH)
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Respondent Agree or Dispute Summary of Comments PKC’s Response colleagues hold details of PWS which have dried up and they also hold a GIS layer of all PWS in Council area. PKC note, that the water team had significant staffing changes, and were not able to input prior to publication of the topic paper, but we have subsequently had feedback from them during this engagement period, and further information has been added on PWS to the Evidence Report with call out records added as a core document (Core Doc Ref 24). Based on the information provided to SEPA they provided a general statement of agreement on the SFRA and have also agreed that this dispute has been resolved. Private individual Disagree – but does not register a formal dispute List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Respondent disagrees with the information provided on the Craigie Burn flood studies at Para 5.12. The SWMP, Para5.37 seems to rely on flow rates predicted in the Craigie Burn flood study, which are considered unreliable. Notes that it appears work is yet to start on the SWMP and is concerned that unreliable flow rates may be assumed as accurate and may be carried forward into the next LDP, to the detriment of the local community. In October 2022 local residents received a letter from the Council which mentioned a Perth Integrated Catchment Study scheme between the Council and Scottish Water. This seems more comprehensive but it is unclear what progress has been made on the Integrated Catchment Study. Further Comments: Respondent provides no further comments. The Craigie Burn flood study was carried out for PKC by suitably qualified consulting engineers, in-line with national guidance and industry-standard methodology. The study was updated and finalised and the conclusions and recommendations of the Craigie Burn Flood study were approved at the Climate Change and Sustainability Committee on 27 November 2023. The funding to develop and deliver the recommended flood protection works has also been provided in the current budget approved by Full Committee. Depending on availability of GIS outputs/progress this flood study’s more detailed information on flood risk may be available to inform the Proposed Plan, and could help inform a screening tool, which will identify indicative at risk areas where a Flood Risk Assessment (FRA) would be required to further clarify the at risk areas. However, where the flood study mapping is not available the SEPA
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: Respondent does not have a formal dispute. indicative mapping is sufficient for this screening purpose (it is what will be used for most of Perth and Kinross) and will trigger requirement for a detailed site specific FRA where necessary. The Perth Integrated Catchment Study (ICS) was jointly delivered by Scottish Water and PKC, and concluded in 2019. This study greatly improved the understanding of surface water/sewer flood risk as well as the interaction with watercourses on these sources of flooding. It identified 32 areas of highest risk, and has been used to inform where further investigation work is required to provide the highest level of benefit. This includes the Perth IFOS project carried out by Scottish Water to look at options to reduce sewer flood risk at 5 priority locations. The Council jointly worked on 2 of these areas (Cavendish Ave/Gray St and Feus Rd) to see if wider options to reduce surface water risk were available. Further information regarding this can be found at PowerPoint Presentation (pkc.gov.uk). Scottish Water will provide further information to communities in these areas at the appropriate times. The Perth ICS also informs the ongoing Perth Surface Water Management Plan, which the Council has currently engaged consulting engineers (Amey Consulting) to deliver. This is expected to be concluded later in Spring 2025. This will build on the work from the ICS, identify the main surface water flood risk hotspots and investigate options to reduce the risk.
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Respondent Agree or Dispute Summary of Comments PKC’s Response The Proposed plan will support any implementation of identified measures in the SWMP and will also generally consider identification of areas for flood management. This is considered further in the Blue Green infrastructure section, this mapping will be another source of evidence for the site assessment process which will be instrumental in identifying opportunities to protect and improve the water environment at a site scale. Private individual Disagree – but does not register a formal dispute List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Concerned about the information relied upon to inform the flood risk sections. Para 5.12 mentions flood studies and an SWMP. Appears that works has not started on the SWMP. Para 5.37 details the outcomes from the Craigie Study and the estimated flows that it relied upon. Pages 159 and 160 likewise. Respondent and many other residents made representations about the flood study expressing significant concerns about many issues, but especially the flow rates used for predictions and conclusions reached. Respondent has concerns that these same shortcomings would be carried forward into the next LDP and undermine its policies and proposals. Further Comments: Respondent provides detailed comments on their representation to the flood study consultation. Formal Dispute: Respondent does not indicate whether they want to make a formal dispute. The Craigie Burn flood study was carried out for PKC by suitably qualified consulting engineers, in-line with national guidance and industry-standard methodology. Please consider the response to private individual (row 12) for further detail on how this study, the Perth Integrated catchment study and Perth Surface Water Management Plan will inform the preparation of the Proposed Plan. Private individual Disagree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Respondent disagrees with the sources of information on the flood risk on the Craigie Burn. The Craigie Burn Flood Study, is not fit for purpose with the flow List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The Craigie Burn flood study was carried out for PKC by suitably qualified consulting engineers, in-line with national
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Respondent Agree or Dispute Summary of Comments PKC’s Response rates incorrect. The latest SWMP, which would include data from floods in 2020, 2022 and 2023, has not yet been completed and this, is essential for anything like an accurate Flood Risk section within the LDP3. The risk of flawed data contained in the Craigie Burn Flood Study being used within LDP3 must be addressed. The calculations used and any concerns brought up by residents should be listened to and discussions held between interested parties. There is also concern with SEPAs data, as so much of it was lost in the data breech a few years ago. Further Comments: Respondent considers flooding and avoiding areas at risk within a site, or in the surrounding area, is to many people the most important element of LDP3. The combined sewer system in use in Craigie cannot cope in heavy, but not torrential rain, and even although new developments have to deal with surface water within their boundary, foul water still joins this system, making the problem worse. Flood risk should be considered from the combination of foul water, surface water and from the Craigie Burn overtopping. When SuDS are not built to a specification Scottish Water requires to adopt them, they cause issues. Considers that developers should build and maintain such important elements to a satisfactory standard. Formal Dispute: Respondent has a formal dispute, and considers that the Craigie Burn Flood Study must be redone using flow rate figures agreed with residents who have knowledge in this field. guidance and industry-standard methodology. Please consider the response to private individual (row 12) for further detail on how this study, the Perth Integrated catchment study and Perth Surface Water Management Plan will inform the preparation of the Proposed Plan. Note that flood risk is a key concern for stakeholders, and the Strategic Flood Risk Assessment is prepared to inform the Proposed Plan and to understand these risks. With regard to concerns about the specification and maintenance of SUDs, detailed advice is provided and applied at the planning application stage, in Flood risk and Flood Risk Assessment Supplementary guidance.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Private individual Disagree – but does not register as a formal dispute List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Respondent considers more account should be taken of the foul and combined sewer networks. New development appears to be granted based on whether the local WWTW has capacity. Little or no account is given to the capacity within the network of pipes. The topic paper should identify areas for flood management, for storage of surface water, fluvial water or foul water storage. Too often areas that might be useful for reducing flood risk are being used to expand development. The planning authority needs a more holistic approach otherwise it is only compounding problems. The council should be looking to undeveloped or vacant sites as opportunities to reduce existing flooding issues. Solutions should be found within the urban areas. Further Comments: Disputes the design flood figures in the Craigie Burn Flood Study and considers the study significantly underestimates the design flows and its findings and recommendations should therefore be treated with some caution. Formal Dispute: Respondent stated that they do not have a formal dispute, but they have mentioned a dispute in relation to flood study findings. List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Agree with respondent that there is a need to consider network capacity as well as the asset with regard to foul and combined sewers. Scottish Water agree that water and wastewater capacities is not considered a show stopper to new development. However early engagement and open discussions to realistic timescales and phasing of new sites can prevent any delays at site. This matter is considered further in the Infrastructure Water and Waste Water Issue D6. In addition, it is also worth noting that Scottish Water will require a full Technical Audit submission for water and wastewater connections applying to join the existing public network. Scottish Water may request from applicants the need for further network studies to ascertain impact of new flow/demand on the existing infrastructure and customers. These could be standalone drainage and/or water impact assessments, flow and pressure tests or odour impact assessment for development near large sewage assets. Agree that the Proposed Plan will need to consider identification of areas for flood management. This is considered further in the Blue Green infrastructure section Appendix B3 and this mapping will be another source of evidence for the site assessment process which will be instrumental in identifying opportunities to protect and improve the water environment at a site scale.
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Respondent Agree or Dispute Summary of Comments PKC’s Response The Council has a number of finalised, ongoing or planned SWMPs within the current published Local Flood Risk Management Plans (Cycle 2 2022-2028) which will improve evidence on surface water flood risk. This SFRA and Appendix B3 is a point in time source of information, and as and when SWMPS are completed they will inform the preparation of the Proposed Plan for LDP3 and subsequent review of planning applications as and when they come forward. PKC are content with the Craigie Burn Flood Protection Study methodology and conclusions. Please consider the response to private individual (row 12) for further detail on how this study, the Perth Integrated catchment study and Perth Surface Water Management Plan will inform the preparation of the Proposed Plan. Also beyond the LDP stages, if/when proposals come forward as planning applications, detailed advice on SUDs is provided in Flood risk and Flood Risk Assessment Supplementary guidance to inform the planning application process. Homes for Scotland Disagree – but does not register as a formal dispute List of Evidence/Datasets: Homes for Scotland (HFS) disagrees with the list and welcomes the opportunity to comment on the Flood Risk and Water Environment Topic Paper. Within Section 2 of the Topic Paper the Council rightly recognise that some of the SEPA guidance is being updated. HFS highlights updated and new guidance that were published in July. It is suggested that the following additional evidence is considered by the Council: The SEPA guidance notes July 2024, and the consultation draft of the Scottish Government Flood resilience strategy have been added to the list of evidence. The balance that needs to be struck on flood risk is provided by NPF4 Policy 22 Flood risk and Water management. PKC will seek to avoid development in areas at risk of flooding as first principle. Resilience measures
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Respondent Agree or Dispute Summary of Comments PKC’s Response SEPA Position Statement on Development Protected by Formal Flood Protection Schemes (July 2024) SEPA Flood Risk and Land Use Vulnerability Guidance (July 2024) Updated version of the guidance the council refers to. SEPA Flood Risk Standing Advice for Planning Authorities (July 2024). Scottish Government Flood resilience strategy: This consultation closes on 13 August and sets out views on what is needed to make places more flood resilient in the longer term. https://www.gov.scot/publications/flood-resilience- strategy-consultation/ Homes for Scotland Site Assessment Methodology: provides a template for assessing sites based on the policies within NPF4 Copy attached to our response to the “Homes” Topic Paper. Homes for Scotland Deliverability Checklist Sets out criteria to allow a council to understand if a site is deliverable. Copy attached to our response to the “Homes” Topic Paper. Summary of Implications for Proposed Plan (PP): HFS considers that a flood resilient solution may not always be the most appropriate solution if the principles of the Scottish Government’s Just Transition are applied. Each settlement has different flooding issues, and it is their view that a balance needs to be struck between investing in fixing flooding problems and the potential loss of investment, businesses and homes within areas that may be at risk of flooding by the year 2100. The latter may include areas currently protected by existing defence or flood protection will be appropriate where managing the need to bring previously used sites in built up areas into positive use. The SEPA Position Statement on Development Protected by Formal Flood Protection Schemes details the approach that will be used to consider proposals behind formal flood defences. The Council will encourage collaboration on flood resilience matters, and support new development, where in line with NPF4 policy and SEPA guidance. With regard to the Homes for Scotland Deliverability checklist, and wider matters beyond flood risk, this has been considered in the Homes Issue Appendix C1. The Council welcomes Homes for Scotland’s comments and agrees with the checklist criteria for flood risk, which requires that an FRA should be undertaken prior to potential inclusion of a site in the Proposed Plan if it might be within an at risk area, an amendment has been made to the Evidence Report Issue and to the SFRA (para ref 3.5 and 3.13) to acknowledge this. It is our intention that all Call for Sites, including existing LDP allocations will be subject to the SEA site assessment, and an FRA if applicable.
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Respondent Agree or Dispute Summary of Comments PKC’s Response schemes. The financial cost of providing or upgrading these requires to be understood and where appropriate the “fixing flooding problems” approach maintained. HFS suggests that the Council should consider opportunities to encourage partnership between local landowners/managers, farmers, crofters and housebuilders/developers where there may be an opportunity to improve a settlement’s long-term flood resilience. Collaboration is key to delivering value engineered solutions that continue to deliver much needed new homes. In response to the Council’s question regarding the requirement for a FRA if a promoted site lies within a flood risk area it is suggested that, as a minimum, this is accompanied by a stage 1 FRA at the site promotion stage. It is suggested that this requirement should also apply to existing allocations. The LDP and future Deliverable Housing Land Pipeline should then set out if a further FRA is required at the planning application stage. HFS states that allocated sites must be clearly deliverable and viable. The Council engages with the home building sector when considering the deliverability of sites submitted under a future Call for Sites exercise. HFS and its members have experience of overcoming flooding constraints and, if required, can provide more certainty regarding site deliverability should the Council have concerns. The socio-economic benefits of home building cannot be understated. In 2019 the home building sector supported 79,200 jobs, equivalent to 3.5 jobs for every home built. This was made up of 45,000 direct jobs, 24,750 indirect jobs and 9,450 induced jobs (link:https://homesforscotland.com/download/the-social-
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Respondent Agree or Dispute Summary of Comments PKC’s Response and-economic-benefits-of-home-building-in-scotland/). Private sector home building is also a key contributor to the delivery of affordable housing. Further Comments: Homes for Scotland (HFS) has no further comments Formal Dispute: Homes for Scotland (HFS) does not wish to make a formal dispute. Montague Evans (on behalf of Loch Developments Ltd) Disagree – but does not register as a formal dispute List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Loch Developments Ltd consider that further understanding should be given to the implications of the committed Flood Defence works, such as those in Kinross, which will influence the flood risk data. Loch Developments Ltd have been in dialogue with the Council’s flood team for a number of years, on the delivery of the flood protection scheme, in line with the redevelopment of the former BCA site at Kinross. As a result of this, some sites including the former BCA Site in Kinross are not expected to be at risk of flooding following the implementation of the flood defence works. Further Comments: The Flooding team and Perth and Kinross Council will be better placed to advise. Formal Dispute: Loch Developments Ltd does not wish to make a formal dispute. Agree that Kinross Flood study data should be used. It has not been included at this stage in the SFRA as no GIS data has been provided by the consultants yet. However, this flood risk GIS data will be available prior to Call for Sites and Ideas programmed for April 2025, and will inform where an FRA will be required. Scottish Water Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Scottish Water does not disagree with the evidence sources provided within the Topic Paper for this Flood Risk and Water Management. However, we would direct Perth and Kinross Council towards Scottish Water's Climate Adaptation Plan 2024 which sets out Scottish Water's Scottish Water's Climate Adaptation Plan 2024 has been added to the list of evidence sources, it notably covers flood risk to assets, and water scarcity. The Council also notes the complexity of the situation surrounding water supplies within rural areas, the joint
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Respondent Agree or Dispute Summary of Comments PKC’s Response long term priorities in dealing with and adapting to climate change which is putting pressure on our infrastructure serving Scotland. This includes, flood risk increase, water scarcity and drought management planning as well as consumer water use. This plan can be located on our website at https://www.scottishwater.co.uk/- /media/ScottishWater/Document-Hub/Key- Publications/Climate- Change/290224ScottishWaterAdaptationPlan.pdf. Scottish Water agrees with the implications for the Proposed Plan. Further Comments: Private Water Supplies: Scottish Water notes the reference to a presumption against Private Water Supplies under NPF4, and where public water supplies are available this should be first consideration for new development. Scottish Water is supportive of this principle; however, it must be highlighted there are large areas rurally where there are no available public water infrastructure and the feasibility of an applicant providing an extension to the nearest public network would be logistically and financially prohibitive. These developments and their long-term water supply needs must be considered carefully from the earliest stages of planning. Flood Risk Management: Climate change modelling predicts an increased risk of surface water flooding. Surface water management planning and integrated drainage should maximise opportunities to manage surface water close to source and above ground – in SUDS pond & 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 work on surface water drainage, and the need to explore green blue opportunities. These matters will be considered through the preparation of the Proposed Plan. The Council notes Scottish Water acknowledge and support the inclusion of datasets relating to increasing pressures on water resources and future water scarcity challenge and appreciate that whilst connection to public water supply is a preference, in some instances rurally it will not prove feasible. The Council welcomes the comments with regard to surface water drainage and will continue to work closely with Scottish Water, and SEPA with regard to integrated drainage, and managing sewer flood risk. The Council also welcomes the “Team Scotland” approach being adopted by Scottish Government as the desired approach to address the climate crisis and notes that Scottish Water considers that the topic paper reflected this.
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Respondent Agree or Dispute Summary of Comments PKC’s Response continue to work closely with Perth and Kinross Council and SEPA in this space. Where Scottish Water have projects to manage risk of flooding to our customers from our sewer network, they are exploring opportunities to apply the principles of surface water management with blue green infrastructure to reduce the flows entering the sewer, and where possible disconnect surface water from the combined system. Scottish Water are trialling this approach and monitoring how this can help to manage the risk of sewer flooding, provide capacity for new development and realise multiple benefits in partnership with local authorities. Water Scarcity and Water Resources: Scottish Water acknowledge and support the inclusion of datasets relating to increasing pressures on water resources and future water scarcity challenges. Scottish Water supports a joined up, planned and proactive approach to water resources management. This approach must focus on the increasing stresses of water resources being understood by all. The key message being water must be used wisely, efficiently and respected. Scottish Water’s Strategic Plan recognises the critical contribution we play in ensuring there is sufficient availability of source water that can be treated for supply to our customers, even during extreme droughts. Scottish Water will continue to work with SEPA to identify opportunities to collaborate with other sectors, for example using SEPA’s One Planet Choice framework. A “Team Scotland” approach is already being adopted by Scottish Government as the desired approach to address the climate crisis and is in line with the high-level summary of this
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Respondent Agree or Dispute Summary of Comments PKC’s Response topic paper. Scottish Water will continue to work across agencies to ensure water resources in Perth and Kinross remain strong and resilient. Formal Dispute: Scottish Water does not wish to make a formal dispute. Gray Planning & Development Ltd (On behalf of GS Brown Construction Ltd) Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): GS Brown Construction Ltd neither agree or disagree with the evidence base and the implications for the Proposed Plan. Further Comments: The usefulness of the SEPA Future Flood Mapping is accepted, however it is not 100% accurate and its pixellated form can be difficult to follow detail. It is recognised that some future allocation sites in the new LDP may not be supported owing to future flood mapping constraints. Landowners and developers have a key role to play in presenting future development sites for consideration which either do not have any risk according to the Future Flood Map and those which offer a managed or mitigation to the risk where cross-cutting policy objectives and outcomes (such as creation of new blue and green infrastructure, or provision of woodlands, allotments and other land uses as part of a mixed community). It is encouraging to note a Strategic Flood Risk Assessment for PKC forms the evidence base - and that settlements at risk and not at risk (PVAs) have been identified. Locations such as Crieff, west Kinross, Crook of Devon and Blairgowrie appear to be less at risk and potentially offer locations for safe longer term growth of settlements where adaptation to climate change can be achieved. Appreciate at this stage that there can be some uncertainty for stakeholders. There will be further engagement as PKC prepare the Proposed Plan. It is acknowledged that SEPA Future Flood Mapping is indicative. Agree that FRA should be undertaken prior to potential inclusion of a site in the Proposed Plan if it might be within an at risk area, and an amendment made to this Evidence Report Issue acknowledge this. Noted that the respondent welcomes that the SFRA will inform the Proposed Plan. This will be alongside other considerations, principally a settlement audit and a site assessment process. Whilst flood risk will be an important factor, other considerations will be considered together to inform the strategy, and site allocations of the new LDP.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: GS Brown Construction Ltd does not wish to make a formal dispute. Private individual Disagree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Considers that the paper fails to address the impact of proposed and existing development on subterranean aqua flows especially in the Scone area. There is historical evidence of this impacting on the flooding in Scone. The SUD at the junction of CTRL and A94 can overflow into the burn that floods lower Scone. The paper fails to address possible outcomes on developing SUDs in development or mention the Barrel Drain in Scone and the effect it has on lower Scone, and does not cover 'deforestation' for development which impacts on surface water and subterranean water flow. Evidence previously been provided by Scone CC and should be recognised as part of the evidence base. Further Comments: Makes no further comments. Formal Dispute: Has a formal dispute because the topic paper does not mention 'deforestation' for development impacting both surface water and subterranean water flows, nor address the impact of proposed and existing development on subterranean aqua flows especially in the Scone area. List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The SFRA acknowledges the site requirements for H29 Scone North and planning application progress as follows, ‘H29 Flood Risk Assessment required, and the results may reduce the amount of land available for development. Groundwater flooding will need to be considered as spring and dry valley are within the site boundary. The development of the site must not increase the risk of flooding down gradient and may require improvements to current drainage arrangements off-site.’ Planning Permission in Principle has been secured across the entire North Scone site (16/02127/IPM). The approved Masterplan splits the proposal into four large phases. An application approval of matters specified in conditions for erection of 42 dwellinghouses was approved August 2019. LDP2 and the SFRA acknowledge the groundwater flood risk. LDP2 has a site specific requirement to ensure the development of the site must not increase the risk of flooding down gradient. It is appropriate that this matter is considered further through the application approval of matters specified in conditions applications (AMSC), and it is considered that sufficient evidence has been included in the SFRA to support the preparation of the Proposed Plan. It is considered that sufficient evidence has been included in the SFRA to support the preparation of the Proposed Plan, whilst LDP2/masterplan requirements ensure in the
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Respondent Agree or Dispute Summary of Comments PKC’s Response interim that if/when AMSCs come forward, they will include appropriate consideration and provisions for flood risk and water storage. Private Individual Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Respondent agrees with the evidence and the summary of implications for the Proposed Plan. Further Comments: With recent incidents of more frequent & intensive rainfall causing an increase in localised flooding, use of flood risk assessments (FRAs) will become more important as part of planning application process. Also, good contact with local farmers in rural areas in helping to allow drainage after heavy rain would be of benefit. Formal Dispute: Respondent does not have a formal dispute. Agree regarding importance of FRAs at the planning application stage. Earn Community Council Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Earn Community Council agrees with the evidence and the summary of implications for the Proposed Plan. Further Comments: Earn Community Council recognises this is a huge piece of work, that Bridge of Earn is mentioned often and flooding incidents well recorded. Detailed maps of possible future areas of concern are also included. Finds it difficult to gauge as to what depth of reporting was needed. Earn Community Council suggest that FRA should be implemented prior to allocation in the Proposed Plan, and a requirement for the planning application stage, noting that Oudenarde, is a plan that is now 20 + years old. Notes comments on the Strategic Flood Risk assessment scope. It is noted that the depth of reporting needed is prescribed in the SEPA guidance sfra-guidance-for- planning-authorities.pdf (sepa.org.uk). Notes feedback on when FRA should be required. Agree that FRA should be undertaken prior to potential inclusion of a site in the Proposed Plan if it might be within an at risk area, amendment made to the Evidence Report to acknowledge this and SFRA (para ref 3.5 and 3.13).
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: Earn Community Council does not have a formal dispute. Savill’s on behalf of Scone Estate Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Scone Estate neither agree nor disagree with the list of evidence/datasets for Topic Paper 023, and neither agrees nor disagrees with the implications for the Proposed Plan. Further Comments: Notes that the SFRA will identify potential opportunities to implement improvements to the water environment through natural flood management and blue green infrastructure. We would flag that landowners in Perth and Kinross would have potential to assist with such matters and could do so at the strategic scale. Scone Estate are aware that discussions on flood risk policy are on-going between the development community, Scottish Government and SEPA. They consider that PKC should allow scope for any national policy change/guidance etc. which could emerge as the LDP3 progresses. Formal Dispute: Scone Estate 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. Note and welcome comments regarding blue and green infrastructure and role of landowners. Also noted and agreed that any changes to national policy will need to be considered through LDP3 preparation. Savill’s on behalf of Duplin Estate Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Duplin Estate neither agree nor disagree with the list of evidence/datasets for Topic Paper 023, and neither agrees nor disagrees with the implications for the Proposed Plan. Further Comments: The Perth Sustainability Park has at its core flood risk and water management. A key part of the development is to design catchment management for the Appreciate at this stage that there can be some uncertainty for stakeholders. There will be further engagement as PKC prepare the Proposed Plan. Noted comments regarding Perth Sustainability Park and this will be considered further at the Proposed plan stage. These comments are site specific and will be addressed beyond the Evidence Report stage.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Craigie Burn to alleviate flood impact on Cherrybank and Queens Avenue residents. The management of land in the hinterland of Perth can have a hugely positive impact on downstream concerns. This points again to the need for close working partnership approaches between the Council, and landowners. Formal Dispute: Duplin Estate does not have a formal dispute. Stuart Buchanan on behalf of Cardross Asset Management Ltd Disagree – but does not wish to register as a formal dispute List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Cardross Asset Management Ltd does not indicate whether they agree or disagree with the list of evidence/datasets, or with the implications for the Proposed Plan. Further Comments: There needs to be recognition that pivotal Gate Check Reports for LDP3 require an integrated approach from stakeholders. For example, Strategic Flood Risk Assessments are required for the PKC area. These will involve PKC, SEPA, Scottish Water and affected landowners so there must be a prescriptive and inclusive approach. This is of critical importance for Inveralmond Industrial Estate (including LDP development site E38), where PKC is required to advance flood protection measures. Formal Dispute: Cardross Asset Management Ltd does not indicate whether they want to make a formal dispute. The Strategic Flood Risk Assessments (SFRA) purpose is to inform the development planning process, and gather evidence, primarily to avoid increasing overall flood risk, and avoid development within NPF4 ‘at risk’ areas. The draft SFRA was consulted on as part of the topic paper Flood Risk and water environment which ran 8 Jul till 18 Aug 2024.This draft was prepared by the planning authority in consultation with Scottish Environment Protection Agency (SEPA). The SFRA guidance prepared by SEPA suggests, ’input from colleagues with expertise in flooding, planning, mapping, building standards and from other organisations such as Scottish Water and Scottish Canals may be needed prior to finalising it.’ There is limited reason to involve landowners when preparing the SFRA, although there has been wider consultation, which has provided some feedback. However, it will be important to engage with landowners and developers, at Call for Sites and Ideas stage, envisaged for April/May 2025. Surface water flood risk, and drainage matters will be addressed at E38, as for the planning approval 19/02033/IPM, Employment use development (class 4, 5 and 6) (on allocated site E38) (in principle) the Council’s Structures and Flooding team advised of the drainage
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Respondent Agree or Dispute Summary of Comments PKC’s Response requirements that will need to be met at the detailed application stage, and the permission is conditioned accordingly. The applicants IPM Flood Risk Assessment considered drainage, and the site layout indicatively designs the Sustainable Urban Drainage system (SUDs). PKC is not required to advance flood protection measures for Inveralmond Industrial Estate. A Surface Water Management Plan (SWMP) is being prepared for Perth, and although there is some uncertainty surrounding the programme, it aims to complete initial study phase March 2025. Inveralmond is an identified hotspot for surface water risk, but that does not necessarily mean that (viable) measures will be identified and taken forward. In the current economic climate, it will be a major challenge to bring forward significant scale surface water flood schemes if and where these may be identified. The consultants are going through the options appraisal stage just now and are conscious of this so will also look into more localised/affordable options (which is more geared at areas where residential properties are at risk).
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Issue: Health and Safety Corresponding NPF4 Policy/Policies: National Planning Framework 4, Policy 23: Health and Safety Other key NPF4 policy connections – 1: Tackling the climate and nature crises; 2: Climate mitigation and adaptation; 6: Forestry, woodland and trees; 11: Energy; 12: Zero waste; 13: Sustainable transport; 14: Design, quality and place; 15: Local living and 20 minute neighbourhoods; 16: Quality Homes; 18:Infrastructure first; 19: Heat and cooling; 20: Blue and green infrastructure; 21: Play, recreation and sport; 22: Flood risk and water management; 24: Digital infrastructure; 26: Business and industry; 27: City, town, local, and commercial centres; 28: Retail; 31: Culture and creativity; and 33: Minerals Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 024: Health and Safety https://consult.pkc.gov.uk/communities/copy-of- topicpapers2/supporting_documents/TP024%20Health%20and%20safety. pdf Information required by the Act and NPF4 regarding the topic: The size, composition health and distribution of the population of the district, the health needs of the population of the district, the infrastructure of the district (including health care facilities) and how that infrastructure is used. For information, the principal infrastructure characteristics of the area are dealt with under Infrastructure. NPF4 Policy 23 expects LDPs to ‘…create healthier places for people.’ The policy intent for Policy 23 is noted as: • To protect people and places from environmental harm, mitigate risks arising from safety hazards and encourage, promote and facilitate development that improves health and wellbeing. The policy outcomes for Policy 23 are: • Health is improved and health inequalities are reduced. • Safe places protect human health and the environment. • A planned approach supports health infrastructure delivery. 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 23, the Guidance advises that planning authorities are expected to seek to tackle health inequalities particularly in places which are experiencing the most disadvantage. They should identify the health and social care services, and infrastructure needed in the area, including potential for co-location of complementary services, in partnership with Health Boards and Health and Social Care Partnerships. LDPs should create healthier places, for example: through opportunities for exercise, healthier lifestyles, land for community food growing and allotments, and awareness of locations of concern for suicides. Spatial Strategies should maintain appropriate distances between sites with hazardous substances and areas where the public are likely to be present and areas of particular natural sensitivity or interest.
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Evidence relating to the health needs of the population of the district, how that infrastructure is used and a summary of the implications for the Proposed Plan is set out in Appendix D, issue D4 Healthcare Infrastructure. Links to Evidence: Major Hazard sites Perth and Kinross Local Development Plan (2019): maps shown in Appendix 3 pages 338-346 Health and Safety Executive (HSE)'s Planning Advice Web App Pipeline safeguarding United Kingdom Onshore Pipeline Operators’ Association Good Practice Guides Locations of concern for suicide Suicide Prevention Action Plan National Guidance on Action to Address Suicides at Locations of Concern Air Quality Perth Air Quality Action Plan (2009) Crieff Air Quality Management Area revocation order Air Quality Annual Progress Report (2024) Airfield Safeguarding Perth and Kinross Local Development Plan Airfield Safeguarding Supplementary Guidance (2020) Scottish Government Planning Circular 2/2003 (revised) safeguarded aerodromes, technical sites and military explosives areas Coal mining Mining Remediation Authority Planning maps Summary of Evidence: Major Hazard sites There are nine major hazard sites designated in the Local Development Plan area. They are in Perth city with several around the harbour area and the remainder in the city’s employment areas. These sites are designated because they are used for the storage or processing of hazardous substances. To mitigate any risks that present from the use of these sites, a health and safety consultation zone is designated around each site. The purpose of designating consultation zones around major hazard sites is to ensure that the advice of the Health and Safety Executive and the facility’s operators and owners is sought on the suitability of any proposals for development in the consultation zone of a notifiable installation, or for any new notifiable installation in the Plan area. The consultation zones around major hazard sites safeguarded in the LDP area are illustrated in Appendix 3 of the Local Development Plan. They are designated as follows: • Flogas Britain Ltd (site ref H0605) • Transco Perth Holder Station (site ref H1649) • Marley Building Materials, Errol Brickworks (site ref H2000)
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• BFL Calport of Perth (site ref H2085) • Daltrade Ltd, Perth Harbour (site ref H3372 Rev1) • Calport of Perth (site ref H3375 Rev1) • Morris Young (Perth) Ltd (site ref H3461) • Central Storage Perth Ltd (site ref H4107) • Tan International Limited (site ref H4596 Rev1) There have been no recent changes to the consultation zones around major hazards and no new designations since the adoption of the Local Development Plan. The Health and Safety Executive has requested that Perth and Kinross Council review three sites of those sites above where Hazardous Substances Consents remain extant but are unused and are unlikely to used in the future. These are at Morris Young (Perth); Daltrade Ltd; and Calport of Perth – all located at the Perth Harbour area. For the Proposed Plan, it is proposed to engage each of the facility owners and operators to check whether existing safeguarding arrangements are appropriate, and whether any expansion plans are in place for new or existing sites. For the three identified sites, we will engage in dialogue with the current Consent holders. Should it be found that there is no substantive risk to the public because Hazardous Substances are not present or likely to be present in future then the Council will explore if there is willingness for the Consent to be revoked, potentially allowing deletion of these consultation zones. It is also proposed to check with the Health and Safety Executive that the safeguarding maps for the remaining sites currently held are sufficient. Pipeline safeguarding The purpose of designating pipeline safeguarding zones under LDP Policy 54 is to ensure that advice is sought from the pipeline facility’s operators and owners as to the suitability of any proposals for development that might affect the safe operation of the pipeline. The LDP area contains pipeline consultation zones for: • INEOS pipeline • Shell pipeline • National Grid pipeline • Scotland Gas Networks pipeline There have been no recent changes to the pipeline consultation zones and no new designations since the adoption of the Local Development Plan. For the Proposed Plan, it is proposed to engage each of the pipeline owners and operators to check whether existing safeguarding consultation zone arrangements are appropriate. Locations of concern for suicide This is a relatively new requirement for Local Development Plans to be prepared with an awareness of location of concern for suicide. Public Health Scotland has published national guidance on action to address suicides at locations of concern that includes practical guidance for planning considerations, which will be used when preparing the Proposed Plan. The views of the Council’s suicide prevention officer and the Health and Social Care partnership have been sought as to what information is held in respect of locations of concern and how this may inform the preparation of the Proposed Plan.
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It has been identified that there are locations of concern in the Proposed Plan area, and at the time of preparing the Proposed Plan information about these locations of concern will need to be sensitively taken into consideration. The evidence report has not published information about locations of concern. If necessary for the Proposed Plan, we expect to seek views from land owners and infrastructure operators, with the co-operation of Council officers and the Health and Social Care partnership. We will also use information from Scotland’s suicide prevention action plan, and the national guidance on action to address suicides at locations of concern from Public Health Scotland when preparing the Proposed Plan. Air quality The Council’s duty to improve air quality in the LDP area is set out in LDP Policy 57. The policy aims to prevent the creation of new pollution hotspots, and to prevent introduction of new human exposure where there could be existing poor air quality. The policy aims to support low emission technologies. It also seeks to address the gradual worsening in air quality that might take place caused by the cumulative impact of many small developments. Mitigation measures include both on and off-site design measures and promote the use of a hierarchy of transport measures that favour active travel. The Local Development Plan policy applies throughout the LDP area and is supported by statutory Supplementary Guidance setting out how air quality will be considered when determining planning applications. The Council has designated an Air Quality Management Areas in Perth city. The Air Quality Management Area has an Air Quality Action Plan with specific measures to assess, monitor and improve air quality over the long term. Annual monitoring reports are used to report progress on improvements to air quality, and the Air Quality Action Plan is periodically reviewed. Crieff has previously been the subject of an Air Quality Management Area with an associated Action Plan. However, having conducted a review and assessment of air quality in Crieff, the Council is satisfied that the air quality objectives in respect of the Nitrogen Dioxide annual mean and Fine Particles annual mean objectives as specified in The Air Quality (Scotland) Regulations 2000 (as amended) will be met. This has resulted in the revocation of Crieff’s Air Quality Management Area. Airfield safeguarding The purpose of safeguarding an airfield is to protect both the airspace over and around it. Development in the vicinity of the airfield may adversely affect its safe operation. It is therefore appropriate that steps are taken to protect those locations by establishing an agreed consultation procedure between the airfield operators and the planning authority. The existing arrangements for this are set out in the LDP2 Policy 61 Airfield Safeguarding, supported by the Airfield Safeguarding Supplementary Guidance (March 2020). There are two types of airfields that could be affected by development in the LDP area, licensed and unlicensed airfields.
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Licensed airfields, such as Perth Airport at Scone, and Dundee Airport, are already safeguarded in line with CAA document CAP168 ‘Licensing of Aerodromes’ and the LDP need not duplicate this. Unlicensed airfields, of which there are five in the LDP area, are safeguarded in line with CAA document CAP 793 ‘Safe Operating Practices at Unlicensed Aerodromes’ and will require continued designation of a safeguarding zone around each. The Supplementary Guidance identifies these as: • Balado Airfield • Errol Airfield * • Methven Airfield • Portmoak Airfield • Strathallan Airfield * Note: for Errol airfield, planning permission has been granted for residential development within the boundaries of the airfield, and on implementation of this permission the airfield safeguarding for Errol would need reviewed and may be no longer necessary. For the Proposed Plan, it is proposed to engage with each of the airfield operators to check whether the existing safeguarding arrangements remain sufficient and appropriate. It is also proposed that the Licensed airfield operators be asked to confirm whether existing safeguarding maps held by the planning authority continue to reflect their requirements. It will also be necessary to consider whether some or all the content of the adopted LDP Policy and Supplementary Guidance will need to be incorporated into a new LDP policy or planning guidance moving forward. Coal Mining The Mining Remediation Authority (formerly called the Coal Authority) holds coal mining data in a national database, and this provides information on legacy constraints as to whether land or property is affected by coal mining, whether it is located in a high risk area, and whether it contains coal and mine entries on or near the surface. This information is important when assessing development risk. The Mining Remediation Authority has produced a detailed interactive map showing the coal related risks in the area. There are two areas in Perth and Kinross where proposed development is identified as being at risk of being affected by coal mining. These are identified on the Mining Remediation Authority maps. The first is an area east and south of Blairingone; and the second is around land south and west of Loch Leven. Areas are divided into land where development is at high risk of being affected, and where the risk is low. The Local Development Plan takes into account the risk that legacy coal mining presents to development. LDP2 Policy 58B Unstable Land specifically requires applicants to demonstrate that land can be made safe and stable where development is proposed on land defined as at risk of being affected by coal mining. NPF4 Policy 9 Brownfield, vacant and derelict land and empty buildings also contains a similar requirement in part (c) of the policy where land is known or suspected to be unstable.
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The Mining Remediation Authority is a regular consultee for planning applications in the areas where development is likely to be affected by legacy constraints resulting from coal mining. Summary of Implications for the Proposed Plan: Air Quality For the Proposed Plan, it will be necessary to consider whether the content of the Supplementary Guidance will need to be incorporated into a locally tailored policy on Air Quality to complement the National Planning Framework policies. The Council has a responsibility to monitor and improve air quality and while it is recognised that air quality now forms part of NPF4 Policy 23 Health and safety, there may be an ongoing role for a locally-tailored policy or planning guidance to address local air quality issues, including in the Perth Air Quality Management Plan, and relating to our monitoring requirements. The Perth Air Quality Management Plan has recently been reviewed and is expected to be published later in 2025. The Proposed Plan will need to address the actions set out in the revised plan. This may include • gathering evidence on whether there is a need to address pollution from stoves and boilers in the air quality management area • examining whether emissions from vehicles can be reduced through encouraging low car developments • although the Air Quality Management Plan is not expected to introduce a need for a Low Emissions Zone in Perth, this issue was last considered in 2020 and may have been raised again in consultation so may require examination again in the future. The Crieff Air Quality Management Area was revoked in 2024 following a review, and the Proposed Plan will need to reflect those changes. Airfield safeguarding Licensed airfields are already safeguarded as described earlier so the Proposed Plan need not duplicate this. However, the five unlicensed airfields are safeguarded by the Local Development Plan policy and associated Supplementary Guidance. This means that the Proposed Plan will require to continue the designation of a safeguarding zone around each unlicensed airfield. The Proposed Plan will also need to consider whether the contents of the Airfield Safeguarding Supplementary Guidance will need to be incorporated into Local Development Plan policy or remain as planning guidance. Coal Mining The Local Development Plan will need to maintain an awareness of the areas of the Plan that are at risk of being affected by coal mining. It will need to consider whether it should contain a Local Development Plan policy specifically addressing unstable land (including areas where development is at risk of being affected by coal mining). Gaps, Uncertainties or Key Issues Raised: Safeguarding Zones around major hazard sites, major accident pipelines, and airfields will need to be checked to ensure they remain appropriate.
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Locations of concern for suicide risk will need to be sensitively taken into consideration when preparing the Proposed Plan. Once published, the measures contained in the Perth Air Quality Management Plan will need to be incorporated into the Proposed Plan. 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 evidence the Council has gathered to help produce our Evidence Report and which we hope to use to prepare our Proposed Plan, were published on the Council’s Consultation Hub and open for comments for a period of six weeks during July and August 2024. As part of our consultation process for LDP3 Topic Papers we welcomed the views of our key stakeholders 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 Proposed Plan. Statements of Agreement/ Dispute Three responses were received on our Health and safety topic paper. One response was from The Coal Authority (now the Mining Remediation Authority); one submitted on behalf of Shell UK, one of the major hazard pipeline operators; and one on behalf of a Community Council. A summary of these comments, their status and, and the Council’s response is provided in the following table. There were no responses that the respondents wished to be treated as a formal dispute to the Evidence Report.
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Respondent Agree or Dispute Summary of Comments PKC’s Response The Coal Authority Neither List of Evidence/Datasets and Summary of Implications for PP: Has no specific comments to make, save to highlight the coal mining legacy in the LDP area. Summary of Implications for the Proposed Plan: It is hoped that any new LDP includes appropriate policies in respect of land instability and the risks arising from past coal mining activity to ensure that new development is safe and stable. Further Comments: The Coal Authority has records that indicate there are recorded coal mining features present at surface and shallow depth including: mine entries, coal workings and reported surface hazards. These features may pose a potential risk to surface stability and public safety Formal Dispute: No. The Council welcomes the Coal Authority’s comments, and the need for an appropriate Development Plan policy in respect of land instability and the risks arising from past coal mining activity One of the outcomes of NPF4 Policy 9 on brownfield, vacant and derelict land and empty buildings is that development is directed to the right locations. Part c) of the policy states that ‘…where land is known or suspected to be unstable or contaminated, development proposals will demonstrate that the land is, or can be made, safe and suitable for the proposed new use…’ The NPF4 policy addresses the Coal Authority’s suggestion for a Development Plan policy covering land instability, and it is considered unnecessary to provide a duplicate policy in the Proposed LDP.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Shell UK Limited Agree List of Evidence/Datasets: Agree, but also suggest PKC refer to the UKOPA Good Practice Guides, and in particular the guide covering requirements for the siting and installation of wind turbine installations in the vicinity of buried pipelines (UKOPA/GP/013 Edition 1 June 2017) Summary of Implications for the Proposed Plan: Agree Further Comments: Welcome further engagement with pipeline operators at the Evidence Report stage Formal Dispute: No The Good Practice Guides will be used in the preparation of the Proposed Plan. The Council will carry out further engagement with pipeline operators and the UKOPA in the preparation of the Proposed Plan. Earn Community Council Neither List of Evidence/Datasets: Agree Summary of Implications for the Proposed Plan: N/A Further Comments: No Formal Dispute: No No response necessary