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Appendix C - Homes

Perth and Kinross Council · 5 March 2025
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Perth and Kinross LDP3 2027
Draft Evidence Report Appendix C Homes
March 2025

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Issue: Homes
Acronyms used in this section
BPC  Big Place Conversation
HLA  Housing Land Audit
HMA  Housing Market Area
HMO  Houses in Multiple Occupation
HMP  Housing Market Partnership
HNDA  Housing Needs and Demand Assessment
HST  Housing Supply Target
LDP  Local Development Plan
(i)LHLR  (Indicative) Local Housing Land Requirement
LHS  Local Housing Strategy
MATHLR Minimum All Tenure Housing Land Requirement
NPF  National Planning Framework
NRS  National Records of Scotland
PKC  Perth and Kinross Council
RSL  Registered Social Landlord
SDP  Strategic Development Plan
SHIP  Strategic Housing Investment Programme
SME  Small to Medium sized Enterprise 
Corresponding NPF4 policies:
• NPF Policy 16: Quality Homes
• NPF Policy 17: Rural Homes (part)
• Other key NPF4 policy connections - 1: Tackling the climate and
nature crises; 2: Climate mitigation and adaptation; 4: Natural
Places; 7: Historic assets and places; 8: Green belts; 9: Brownfield,
vacant and derelict land and empty buildings; 10: Coastal
development; 13: Sustainable transport; 14: Design, quality and
place; 15: Local living and 20 minute neighbourhoods; 18:
Infrastructure First; 19: Heating and cooling; 20: Blue and green
infrastructure; 21: Play, recreation and sport; 23: Health and safety;
27: City, town, local and commercial centres; 29: Rural
development; 30: Tourism. 
Corresponding Perth and Kinross LDP3 Topic Paper:
Topic Paper 020: Homes
https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume
nts/TP020_Homes.pdf 
Information required by the Act and NPF4 regarding the topic:
Sections 15(5), 16(2) and 16B of the Town and Country Planning (Scotland)
Act 1997, as amended:
• the housing needs of the population of the area, including in
particular, the needs of persons undertaking further and higher
education, older people and disabled people
• the availability of land in the district for housing, including for older
people and disabled people
• persons seeking to acquire land for self-build housing
• the action taken to support and promote the construction and
adaptation of housing to meet the housing needs of older people
and disabled people in the area, and the extent to which the action
has helped to meet those needs
• the action taken to meet the accommodation needs of Gypsy /
Travellers in the area, and the extent to which the action has helped
to meet those needs 
Under Policies 16 and 17 NPF4 expects Local Development Plans to:
• Identify a Local Housing Land Requirement
• Allocate deliverable land to meet the 10-year Local Housing Land
Requirement
• Identify areas which may be suitable for new homes beyond year
10

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• Allocate land for Gypsy / Travellers and Travelling Showpeople
where need is identified 
Policy intent for Policy 16:
• To encourage, promote and facilitate the delivery of more high
quality, affordable and sustainable homes, in the right locations,
providing choice across tenures that meet the diverse housing
needs of people and communities across Scotland. 
Policy intent for Policy 17:
• To encourage, promote and facilitate the delivery of more high
quality, affordable and sustainable rural homes in the right
locations. 
Policy outcomes for Policy 16:
• Good quality homes are at the heart of great places and contribute
to strengthening the health and wellbeing of communities.
• Provision of land in the right locations to accommodate future need
and demand for new homes, supported by the appropriate
infrastructure. 
• More energy efficient, net zero emissions homes, supporting a
greener, fairer and more inclusive wellbeing economy and
community wealth building, tacking both fuel and child poverty. 
Policy outcomes for Policy 17:
• Improved choice of homes across tenures so that identified local
needs of people and communities in rural and island areas are met.
• Homes are provided that support sustainable rural communities
and are linked with service provision.
• The distinctive character, sense of place and natural and cultural
assets of rural areas are safeguarded and enhanced. 
The Scottish Government’s LDP 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 16, the Guidance advises that planning
authorities should take into account the MATHLR figure for the area, any
identified need for land to ensure the provision of accommodation for
Gypsy / Travellers and Travelling Showpeople, annual HLA, and SHIP. 
With respect to NPF4 Policy 17, the Guidance advises that planning
authorities should take into account the MATHLR figure for the area, any
identified need for land to ensure the provision of accommodation for
Gypsy / Travellers and Travelling Showpeople, annual HLA, an
understanding of population change over time, locally specific needs and
market circumstances in rural and island area, identification of Remote
Rural Areas, SHIP, and local economic strategy. Due to the cross-over with
NPF Policy 29 Rural Development, some of the above is discussed in
Appendix E4: Rural Development. 
Links to Evidence:
• Housing to 2040
• Perth and Kinross HMP HNDA Final Report
• NPF4 Annex E MATHLR
• NPF4 Perth and Kinross MATHLR Assessment Report
• TAYplan2 Strategic Development Plan Examination Report
• Perth and Kinross LHS Framework 2022-27  
• Perth and Kinross LHS 2022-2027 Appendix: HST 2022+
• Perth and Kinross LHS 2022-27 Annual Progress Report 2022/23 and
2023/24
• PKC SHIP 2025/26 – 2029/30
• PKC STLs Evidence Research Report 
• Existing Housing Need in Perth and Kinross – Report commissioned
by Homes for Scotland
• Extract from the PKC Self and Custom Build Register

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• Perth and Kinross HLA – 2022 and 2023
• Edinburgh City Council HLA and Completions Programme 2022
p.11-13
• Briefing Paper: The Barriers to Housing Delivery
• The Scottish Land Commission: The role of land in enabling new
housing supply in rural Scotland
• Planning and the Housing Emergency – Delivery Plan
• Perth and Kinross LDP2
• BPC - Results 
Summary of Evidence:
The key expectation of NPF policies 16 and 17 at Evidence Report stage is
the identification of a LHLR and the LDP Guidance specifically requires the
Evidence Report to include an indicative LHLR when setting out what the
evidence means for the Proposed Plan. To make this section of the Report
easier to navigate and avoid repetition, the summaries of evidence below
also consider the potential impact of individual pieces of evidence on the
setting of the iLHLR. Where the evidence is lengthy or more complex an
‘issues considered’ summary is included. 
Housing to 2040
Housing to 2040 is the Scottish Government’s first national housing
strategy. It was published in 2021 with an ambition to deliver a further
100,000 affordable homes in the period to 2031/32 with at least 70% of
these for social rent. Recognising the unique challenges faced by rural
island communities, the strategy commits to specific action to support
housing development in these areas, helping to stem rural depopulation
and supporting communities to thrive. The Strategy aims that everyone
has access to a home that is affordable, and people have choices about
where they live, no matter what tenure they live in. This includes action to
scale up opportunities for self-provided housing, so people have more
choices about the kinds of home they want to live in. 
New building standards will be introduced from 2025/26 to underpin the
new Scottish Accessible Homes Standard to future-proof new homes for
lifelong accessibility. Action will be taken so that all homes, no matter what
their tenure, are required to meet the same standards and the aim is that
this will cover all homes new or existing. 
Potential impact on the iLHLR
This is a high level strategy document the implications of which will have
influenced the preparation of NPF4. 
Perth and Kinross Housing Market Partnership Housing Needs and
Demand Assessment 
Issues considered:
• Housing market drivers
• Estimating future housing need and demand
• Specialist provision
• Housing stock profile and pressures 
The starting point for the consideration of housing-related issues for the
LDP is the HNDA for the area. HNDAs are designed to give broad, long-run
estimates of what future housing need might be, rather than precision
estimates. They provide an evidence-base to inform housing policy
decisions in the LHS and land allocation decisions in the LDP. The LDP
Guidance confirms that where the Scottish Government is satisfied that an
HNDA is robust and credible, the approach used will not normally need to
be considered further at Gate Check. The Perth and Kinross Housing
Partnership HNDA was confirmed as robust and credible on 9 May 2023.
The Guidance does, however, go on to state that where stakeholders
consider further evidence may be relevant after this date this may be
raised in engagement and reflected in the Evidence Report. 
The HNDA first considers the relevant HMAs for data analysis. The PKC
area is divided into six HMAs as shown in the map below. The Greater

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Dundee HMA refers to the small part of the PKC area falling within the
wider Greater Dundee HMA which includes Dundee City Council area plus
parts of Angus and Fife Council areas. 
Housing Market Areas in Perth and Kinross 
There is no longer a requirement for the LHLR in LDPs to make reference to
housing market areas, but it is considered relevant to assess whether there
are any particularly strong influences on the housing market in Perth and
Kinross coming from outwith the area. The HNDA concluded that 63% of
property purchasers originate from within Perth and Kinross indicating that
the PKC area is a relatively self-contained housing market area. That said, a
strong relationship was observed between the Kinross area and Fife
Council area with 24% of properties being sold to purchasers from Fife.
Also, that migration into parts of Perth and Kinross from the rest of
Scotland / UK was over 20%. 
1 Note that this includes those who live within Perth and Kinross but work outwith the
area. Average incomes for those living and working in Perth and Kinross are below the
national average. 
The HNDA then goes on to consider the core outputs for the analysis of
need and demand. These are based on a combination of primary and
secondary data sources. 
Housing Market Drivers (Core output 1)
Core output 1 considers the key demographic, affordability and economic
factors and how these are driving the Perth and Kinross housing market. 
Demographic issues:
• 12.5% increase in population between 2000 and 2019. Population
projections from 2018 predict a marginal decline in population of
1%. Significantly, however, the 75+ cohort is expected to increase
significantly over this period by 76%.
• 6.1% increase in households between 2008 and 2018 with a further
6-8% increase expected from 2021 to 2043 depending on migration
levels. Single person and 2 adult households are expected to
increase with declines in all other household groups. 
Affordability issues:
• Average income in Perth and Kinross is higher than the Scottish
average1 yet the average house sale value increased by 13% from
2009 to 2019.
• 49% of people cannot afford a lower quartile market value property. 
Economic issues:
• Employment rates increased by 16% between 2009 and 2019. Key
industries include agriculture, forestry and fishing; professional,
scientific and technical sectors; and construction.
• More than twice the number of people travel out of the area for
work than travel in.

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• In 2020, seven of the Scottish Index of Multiple Deprivation data
zones in Perth and Kinross were in the top 15% most deprived data
zones in Scotland. 
Estimating Future Housing Need and Demand (Core Output 2)
Core output 2 estimates the number of new homes, disaggregated by
tenure, that are likely to be required over the next 20 years to meet local
need and demand using the Scottish Government’s HNDA calculation tool.
The calculations in the tool are underpinned by an affordability assessment
which splits overall housing estimates into the requirement for different
housing tenures. 
Calculation of future housing estimates = existing housing need + new
need for housing 
For the estimate of existing housing need, a local estimate (as opposed to
the default estimate in the HNDA tool) was developed informed by
housing system evidence held by PKC of households currently in unsuitable
housing and who need to move to an alternative property. For this local
estimate existing need is that driven by factors including homelessness,
insecurity of tenure, overcrowding, concealed households, poor quality
housing or a lack of basic amenities, and unmet need for specialist housing.
For the purposes of the HNDA calculation it was assumed that the backlog
of existing need would be addressed over the first 5-year period of the 20-
year projection. 
Source: HNDA
Note: MHP above should read HMP ‘Housing Market Partnership’ 
For the estimate of new need for housing, this was assessed in the HNDA
using the NRS 2018-based Household Principal Projections, and the NRS
2018-based Household High Migration Projections. This resulted in an
estimate of 4,060 to 5,131 new households over the 20-year period, or an
average of 203 to 257 households per year.

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Source: HNDA 
The HNDA calculation combines the components of housing need to create
a 20-year range of housing estimates depending on whether the principal
(main) or high migration population projections are used. The high
migration projection is based on the principal projection but with an
alternative assumption on migration. For the inputs relating to income
growth, income distribution, house prices, affordability, rental threshold,
and rental growth, as they relate to the new need for housing, the default
assumptions within the toolkit were used. 
Source: HNDA 
The housing estimates in each of the Perth and Kinross HMAs across the
20-year period range from:
• 714-862 in the Strathearn HMA
• 736-887 in the Strathmore and the Glens HMA
• 167-206 in the Greater Dundee HMA
• 2,956-3,521 in the Greater Perth HMA
• 420-503 in the Highland Perthshire HMA
• 394-480 in the Kinross HMA 
The following table sets out the tenure split associated with the principal
and high migration scenarios. 
Tenure Percentage
(principle
projection)
Percentage
(high migration
projection)
Social rent 36 32
Below market housing 13 14
Market rent (private rented
sector)
26 27
Market housing 25 27
Total 100 100 
Specialist Provision (Core Output 3)
Core Output 3 considers the future property requirements in Perth and
Kinross associated with specialist housing provision including accessible
and adapted housing, wheelchair housing and non-permanent
accommodation for key client groups, the future care and support
requirements to enable independent living including supported housing for
key client groups, and the future site provision to meet the needs of the
gypsy / traveller and travelling showpeople communities. 
The Perth and Kinross Housing Contribution Statement is an integral part
of the Perth and Kinross Housing and Social Care Partnership Strategic
Commissioning Plan and considers the role of supported housing provision
in enabling key client groups to live well in the community they chose. The
Statement sets out that housing plays a vital role in providing services and
support to intervene early to prevent later, longer term issues arising, and

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in enabling people to be empowered to live independent lives at home or
in a homely setting. Specific Housing Contribution Statement actions set
out in the Strategic Commissioning Plan include:
• Increasing the provision of affordable housing, particularly in areas
where shortages have been identified
• Identifying and planning for new housing developments for people
with specialised support needs 
There are 1,344 units of specialist housing provided by social landlords in
Perth and Kinross: 
• 63% provide housing for older people including sheltered housing 
• 29% are accessible houses
• 2.5% are fully wheelchair accessible 
There are 292 temporary accommodation units to meet the needs of
homeless households and 45 care homes for adults accommodating 1,336
residents. 
A research study in 2016 into the accommodation needs of Gypsy /
Travellers and Travelling Showpeople in the TAYplan area showed that
there were 435 Gypsy / Travellers and Travelling Showpeople in Perth and
Kinross in over 185 households. 69% of the population lived in settled
housing. There were two Council sites providing a total of 26 pitches. 
The extent and nature of future provision required across each category of
specialist housing identified in the HNDA over the 20 year period to 2041 is
summarised below. 
Accessible, adapted and wheelchair housing:
• Up to 3,200 households may require a more accessible form of
housing such as accommodation without stairs.
• 640 households may require wheelchair housing.
• 7,000 households may require adaptations to their current home. 
Supported housing:
• Approximately 1,500 households may require housing for older
people.
• 3% of the annual homeless population in Perth and Kinross (700)
have complex support needs and may benefit from Housing First
tenancies.
• There is a need for 144 commissioned tenancies/spaces for key care
groups with learning disability clients accounting for most
anticipated future need. 
Student accommodation:
• A backlog of 50 students have expressed demand for Perth College
accommodation. 
Specialist site:
• At 2016 there was projected to be a -2 shortfall to 4 surplus in site
pitches over the following 5 years.
• The study included a recommendation that the potential for transit
site provision be explored further. Plans for a transit site in Perth
are currently being progressed. 
Housing Stock Profile and Pressures (Core Output 4)
Core output 4 considers the stock profile, and the key stock condition
issues and housing pressures which are influencing the operation of the
Perth and Kinross housing system. Much of the data was derived from a
primary research survey which was carried out to inform the HNDA. 
Stock profile:
• Tenure – 66% of households own their property, 16% privately rent,
and 17% rent social housing
• Dwelling type – 76% are houses / bungalows and 21% flats /
tenements
• Dwelling size – 39% of homes have 1-2 bedrooms and 55% have 3-4
bedrooms
• There were 78 registered HMOs in Perth and Kinross in 2020

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Condition:
• Across all tenures 2% of dwellings are Below the Tolerable
Standard, 27% are in urgent disrepair, and 78% have evidence of
disrepair
• 8% of properties across all tenures have low energy efficiency
ratings which is twice the Scottish average 
Pressures:
• At 2019 3.9% of dwellings were unoccupied (2,849 properties) of
which 1.8% had been empty long term 
• Scottish Government estimates indicate that 2% of households are
overcrowded and 1% are concealed whereas the HNDA survey
indicated that 2% are sharing amenities with another household
and 17% have too few rooms in their current homes
• There are approximately 5 applicants for each empty social rented
property
• Options for future policy around the 1,081 second homes in Perth
and Kinross could be considered 
Potential impact on the iLHLR
The HNDA outputs for future housing need and demand are based on the
2018-based principle and high migration population projections. These are
still the most recent available projections. Since the HNDA was produced,
however, several datasets have been updated. For example, the number of
commissioned tenancies / spaces for key care groups has fallen slightly.
Plans and strategies too are being reviewed. The Perth and Kinross
Housing and Social Care Partnership Strategic Commissioning Plan and
Housing Contribution Statement, for example, are both due to be reviewed
in 2025/26. Whilst is it difficult to compare directly due to the different
timescales, and even though datasets and plans have and will continue to
be reviewed and updated since the HNDA was prepared, even the highest
end of the 20-year range identified in the HNDA (6,459) is considerably
below the 10-year MATHLR set for Perth and Kinross in NPF4 of 8,500
units. 
National Planning Framework 4 Minimum All-Tenure Housing Land
Requirement 
Issues considered:
• Council input to MATHLR calculation
• Council evidence submitted to Scottish Government on newly
forming households
• Council evidence submitted to Scottish Government on the existing
housing need
• NPF4 Perth and Kinross MATHLR Assessment Report 
NPF4 sets out the MATHLR for each authority area. The MATHLR is the
minimum amount of land, by reference to the number of housing units,
that is to be provided by each planning authority for a 10-year period. The
MATHLR was calculated by adding the projected increase in households
(newly forming households) to existing housing need in each local
authority area and then applying a flexibility percentage to allow for
changes in sites coming forward. 
Council input to MATHLR calculation
Interim draft MATHLR figures were produced by Scottish Government in
February 2021 and planning authorities were given the opportunity to
submit comments on these. The draft 10 year figure proposed for Perth
and Kinross was 2,650. At the time work was well advanced on the HNDA
which meant the Council were able to propose a well-informed locally
adjusted estimate MATHLR for Perth and Kinross. The evidence for this
adjusted estimate, which was submitted to Scottish Government by the
Council, is summarised below. 
In addition to the two scenarios considered in the HNDA based on the
principal and high migration population projections, a further scenario was
developed as the HNDA was being prepared which tested the impact of
moving beyond the high migration scenario to reflect an ambition for
housing-led growth in the area. This assumed 0.5% growth over the NRS

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2018-based principal projection. The table below sets out the three
different projections in 5-year bandings. 
Cumulative housing need: 
All tenures
2021-
2025
2026-
2030
2031-
2035
2036-
2040
Scenario 1 Principal 2,946 3,786 4,522 5,388
Scenario 2 High Migration 3,125 4,237 5,271 6,459
Scenario 3 Growth 4,743 7,451 9,729 10,595
Source: HNDA table 6.2 – 2021 PKC HNDA calculation scenarios 
This additional ‘growth scenario’ was not included within the final HNDA
given that it was policy-based (assuming an additional 0.5% growth) rather
than evidence-based (using published projections). It was, however,
discussed with the HMP as set out in the Stakeholder Engagement section
below. There was unanimous support from partners for using a growth
scenario to inform future housing supply targets and so this informed the
Council’s response on the interim draft MATHLR for Perth and Kinross. 
Council evidence submitted to Scottish Government on newly forming
households
NRS population and household projections for Perth and Kinross have been
projecting a fall in the growth rate. Yet over the same period house
completions have been steadily increasing. The birth rate has continued to
fall, and we are still to fully understand the impact that Brexit and the
pandemic will have on future inward migration, yet there is an inherent
difficulty in relying purely on a projection of past trends as these take no
account of policy ambition in the area or make any allowance for potential
post pandemic changes within society. 
House completions exceeded 900 several times in the 1990s / 2000s. The
financial crisis in the late-2000s obviously impacted significantly on
completions post 2008 but they had very nearly reached 900 again in 2020.
Despite the restrictions of the Covid pandemic completions were back
above 600 by 2021. Based on the house building activity seen during the
2021 survey, future completions are likely to reach approximately 800 per
year in the medium term. A housing land requirement figure which is
significantly below what has been previously delivered runs the risk of a
serious under supply of housing land for the next LDP. With an
undersupply comes higher house prices and an increased difficulty for
some households to be able to access the type of housing they need.
Reduced build rates will also impact on the construction industry and
ultimately the ability of the economy to grow in the future. 
Pre-covid, about 70% of PKC migration came from either Scotland or the
rest of the UK with 30% from overseas. The effects of the pandemic are
still unclear at PKC area level but there may be potential for an increase on
the UK side as the area may become a more realistic option for families,
attracted by the quality of life on offer and the flexibility offered by
homeworking meaning more people can choose to live in less populated
areas. 
The area is well placed to generate additional growth and jobs. The
Council’s Corporate Plan places emphasis on supporting businesses to
grow and attract investment and higher value jobs, deliver new investment
to the Tay Cities Region, and develop the workforce and retain and attract
young people to the area. 45% of the total registered enterprises in 2020
were in Growth sectors and the Tay Cities Deal will invest more than
£150m over 15 years in Perth & Kinross. These elements will contribute to
at least a modest real growth scenario, possibly even strong growth, and a
greater equality of income distribution with more people accessing job
opportunities in sectors with higher paid jobs. In-house projections, based
on gradual increase to 0.5% growth by 2029 and then onwards to 2037, to
derive a locally adjusted estimate is ambitious yet achievable and reflects
the growth agenda promoted by the Council. 
Council evidence submitted to Scottish Government on the existing
housing need
A revised existing need estimate has been calculated through the HNDA
process incorporating results from a telephone and online survey.
Homeless households and those in temporary accommodation information

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was taken from HL1 data (the statutory statistical return to the Scottish
Government on homeless applications) and data from the survey on
households in insecure tenure who were under threat of eviction /
repossession. Concealed households and overcrowding information was
taken from the survey for households who share rooms with another
household or who identified overcrowding as the main reason as wanting
or need to move. Specialist housing and housing related services
information was taken from waiting list information on households
needing to move due to their house being unsuitable to meet specialist
needs and newly forming households requiring specialist housing. Poor
quality housing information was taken from an in-house all-tenure stock
condition survey. Combining these requirements results in a local existing
need estimate of 1,369. 
Housing to 2040 includes a target of 100,000 over the next 10 years. This
appears at odds with the initial default estimate proposed for NPF4. For
example, assuming 3% of the 100,000 affordable homes target would be
allocated to Perth and Kinross based on the share of the national
population, the target would be 2,763. This is already higher than the
initial default estimate and excludes private tenure development.
Furthermore the 2021-26 SHIP projects 1,270 affordable housing
completions which is half the initial default estimate but covers only five
years. 
NPF4 Perth and Kinross MATHLR Assessment Report
The Scottish Government confirmed that: 
A) The locally adjusted estimate for Perth and Kinross was primarily
driven by the use of alternative in-house household projections.
These in-house projections were based on a gradual increase in
households to 5% by 2029 and on to 2037.
B) A revised existing need estimate had been calculated through the
HNDA process. This incorporated results from a telephone and
online survey which was confirmed as statistically robust. The HNDA
was confirmed as robust and credible by the Centre for Housing
Market Analysis on 9 May 2023. 
As a result of the Council’s input, informed by the HNDA and discussion
with the HMP, the final MATHLR in NPF4 was more than three times higher
than the initial default estimate – from 2,650 to 8,500. A breakdown of
how the 10-year MATHLR calculation for Perth and Kinross evolved is set
out in the following table. 
Component Initial default
estimate
Locally adjusted
estimate
MATHLR
Existing need 100 1,350 1,350
Households 1,950 5,200 5,200
Flexibility (30%) 600 1,965 1,965
TOTAL 2,650 8,500 8,500 
Potential impact on the iLHLR
It is expected that the iLHLR will exceed the MATHLR. It must, however, be
evidence based. The revised existing need estimate for Perth and Kinross
was calculated using a combination of data from the HNDA survey, Scottish
Government HL return statistics, waiting list and specialist housing report
data, and local estimates of poor-quality housing. As will be discussed
below, more recent survey data is presented by Homes for Scotland. This is
not, however, considered an appropriate basis for altering the existing
need estimate and the reasons for this are also discussed below. 
Much of the HNDA inputs came from the survey work carried out
specifically for the HNDA. Some updates are available, for example, the HL
statistics for 2023/24 show that there were 65 households in temporary
accommodation which is an increase from the 38 households included in
the HNDA. There is not, however, considered to be justification at present
for altering the existing need estimate. This will, however, be reassessed in
setting the final LHLR in the Proposed Plan. By that time some relevant
detailed information may also be available from the 2022 Census.

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Strategic Development Plan TAYplan 2 Examination Report
In considering the options for the iLHLR, it is relevant to consider the
previous housing land requirement upon which the current LDP2 was
based. This was set by the SDP, TAYplan2, which identified an average
annual housing land requirement for Perth and Kinross of 1,000 units per
year. 
TAYplan2 is no longer in force yet it is useful to consider the Examination
Report in relation to the Reporter’s views on setting a realistic housing
land requirement for Perth and Kinross. 
The requirement of SDPs was to set both a HST and a HLR for each local
authority area. The HLR was to reflect the HST plus a flexibility allowance
of 10-20%. For Perth and Kinross, however, the proposed SDP set both the
HST and the HLR at 1,000. This was because the SDP Authority considered
there was no evidence that increasing the HLR above the HST would result
in any more houses being delivered. The Reporter concluded that the: 
‘…target to build an average of 1,000 homes a year would require
more homes to be built annually than has ever been achieved in
any year over the period since 2002, and 24% more homes than the
average annual figure even for the pre-recession years of 2022 to
2009….It is clear that the authority believes fewer than 1,000
homes will be delivered on average in Perth and Kinross in the Plan
period, and the consensus among the housebuilding industry is also
that this level of target is challenging. I therefore conclude that the
proposed housing supply target [of 1,000 per year] for Perth and
Kinross is too high.’ (TAYplan2 Examination Report p.222) 
The end result of the examination was to instead identify a lower HST with
a HLR of 1,000 to allow for flexibility which the Reporter considered ‘…the
most pragmatic way to ensure that the plan contains a more realistic
housing supply target and housing land requirement for this area….’
(Examination Report p.226). 
Potential impact on the iLHLR
It is acknowledged that the Examination Report for TAYplan 2 dates from
2017 and since then there have been significant changes and challenges
faced by the house building industry, not least of which the impacts of the
covid-19 pandemic and Brexit. The TAYplan Examination does, however,
highlight the importance of setting a realistic HLR. 
The Homes Topic Paper included as a possible option for the iLHLR using
the same 1,000 units per annum requirement as had been set for Perth
and Kinross in TAYplan2. There was some support for this option from
consultants responding on behalf of a landowner or developer. Homes for
Scotland did not comment on this as an option but stressed that they
would dispute any attempt by the Council to set an LHLR that does not
exceed the MATHLR. 
Analysis of historic house completion rates before and since TAYplan 2 was
approved demonstrates that identifying a land requirement of 1,000 per
annum, which at the time was higher than completions that had ever been
achieved in any one year, does not automatically result in those higher
build rates being achieved. 
0
200
400
600
800
1000
1200
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
Annual completions over 25-year period
Completions MATHLR TAYplan HLR

Page 13

Source: Perth and Kinross Housing Land Audits
Note: completions from 2010 have not been included as this year only
covered a 9-month period due a change in audit date 
The iLHLR must be evidence based. After carrying out further analysis of
the evidence following engagement with stakeholders it is concluded that
there is no evidence to support setting an iLHLR in the Evidence Report at
1,000 units per annum to reflect the higher land requirement which was
set in the previous SDP for Perth and Kinross. This option has therefore
been discounted. 
Local Housing Strategy 2022-27, Appendix: Housing Supply Target, and
Annual Progress Report 2022-23 and 2023-24 
Issues considered:
• Key issues
• Actions
• Setting the Housing Supply Target
• Progress 
The LHS sets out the vision of the Council and local partners for the supply
of housing across all tenures and types of housing provision. The LHS was
approved by Committee on 15 March 2023. The strategy aligns to national
housing priorities, maximising investment opportunities, and building on
the ambitious economic growth objectives set out in the Tay Cities Deal.
The purpose of the LHS includes setting out a shared understanding of
need and demand for all types of housing, and for housing services now
and in the future, and providing clear strategic direction for housing
investment including the development of new homes as well as
investment in existing. The LHS is required to identify a HST. 
LHS priorities are defined as:
Priority 1 – Providing more affordable homes to support liveable and
sustainable communities
Priority 2 – Providing a range of housing options that people can easily
access, afford and keep
Priority 3 – Delivering housing for people with varying needs
Priority 4 – Delivering quality homes with affordable warmth, zero
emission, and SMART technology 
Key Issues
Key issues identified through engagement in relation to these priorities
include:
• Overcome development barriers such as land availability and
development constraints which is key to increasing the scale and
pace of delivery
• Make better use of existing buildings to meet housing need
including bringing redundant buildings or low demand housing back
into effective use
• Provide a wide range of housing options that deliver tenure
diversity, including development and growth of the private rented
sector through Build to Rent and mid-market rent
• Affordability in the private rented sector is problematic and
opportunities to deliver quality market and mid-market rent
options should be explored
• Access to affordable housing options is severely limited in many
rural areas of Perth and Kinross
• Improve design guides for all housing tenures and all types of
housing for varying needs
• Ensure sufficient supply of housing options for older people as
demographics change and the elderly population grows 
Actions
Actions to address the key issues include:
• Maximising the development of social housing through the SHIP
delivering a diverse mix of property sizes and more accessible,
adaptable homes
• Seek opportunities to deliver a wider range of affordable housing
options

Page 14

• Developing an empty homes strategy which targets areas where
housing pressure is evidenced
• Maximise the potential to generate more homes through
brownfield regeneration
• Developing policy through LDP3 where appropriate for STL control
areas
• Ensure planning policy, placemaking and housing investment
programmes contribute to improved and sustainable homes,
outdoor space, health and wellbeing for all including people with
varying needs
• All affordable homes are built to revised Housing for Varying Needs
standard and New Build Design Guide, with a minimum of 10% of
all affordable homes delivered being built to wheelchair and
adaptable standard
• Work with Gypsy / Traveller community members to have a better
understanding of their accommodation needs and preferences 
There are 11,557 affordable homes across Perth and Kinross with two
thirds provided by the Council and a third provided by RSLs. Around 7%
become available for letting each year with roughly five applicants for
every tenancy that becomes available. Demand for tenancies is focused on
smaller properties (82%) but there are also significant pressures for larger
homes with seven applicants for every property with four or more
bedrooms. 33% of Council tenants are under-occupying a property by two
or more bedrooms so there is a need to address the mismatch in
household composition and property size within social housing stock. 
Setting the Housing Supply Target
The HST in the LHS sets out the estimated level of additional housing that
can be delivered on the ground. The LHS HST is different to the LDP2 HST,
but it will inform the definition of the LHLR within the LDP. In preparing the
LHS there has been close partnership working between Council housing
and planning officers to ensure that housing delivery and land use
principles are informed and well aligned. The detailed calculation of the
HST is set out in the Perth and Kinross LHS 2022-2027 Appendix: Housing
Supply Targets 2022+. 
During the life of the LHS a need for 4,743 new homes is estimated across
Perth and Kinross with the following approximate tenure split:
• 29% market housing
• 30% market rent
• 25% social rent
• 15% below market rent such as shared ownership / equity and mid-
market rent 
Through discussion between PKC’s Housing and Planning Services, and
Homes for Scotland it was agreed that in setting the HST for the LHS the
most realistic and preferred scenario for Perth and Kinross is one which
assumes an element of additional growth over and above that in the high
migration projection in the NRS 2018-based Household Projections. The
following table summarises the estimated total housing needs over a 20-
year period based on this growth scenario. 
Growth Scenario 2021-25 2026-30 2031-35 2036-40
Social rent 1,881 393 256 107
Below market rent 639 489 309 133
Private rented 1,129 920 673 314
Owner occupation 1,092 906 651 313
Total 4,741 2,708 1,889 867
Average per annum 948 542 378 173
Cumulative 4,741 7,449 9,338 10,205
Source: Perth and Kinross LHS 2022-2027 Appendix: HSTs 
In setting a HST in their LHS, local authorities must take account of
economic and market factors. Influences and challenges include previous
levels of affordable housing delivery (see table below) and the availability
of resources (see SHIP section below).

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Affordable housing completions 1 April 2016 – 31 March 2022
Financial year Perth and 
Kinross Council
RSL partners Affordable homes 
completed
2016/17 45 41 86
2017/18 66 168 234
2018/19 93 106 199
2019/20 69 251 320
2020/21 40 84 124
2021/22 179 129 308
Total 492 779 1,271
Source: Perth and Kinross LHS 2022-2027 Appendix: HSTs 
The market housing element of the HST was taken from the HNDA
estimate with a growth scenario applied for years 1-5. The HST therefore
includes meeting the demand for market housing in full over the life of the
LHS. 
For affordable housing, adopting a growth scenario results in a need for a
total of 2,520 affordable houses over the 5-year period. The supply of land
available over that period, however, would only facilitate around 1,000
affordable houses from the application of the Council’s 25% affordable
housing policy alone. Even taking into account the potential for buy-backs
of ex-local authority houses and bringing empty homes back into use, it
was not considered achievable for the Council and it’s RSL partners to
deliver the affordable housing element of the growth scenario within the
life of the LHS. It was therefore proposed instead to aim to deliver the
affordable housing component over the 20-year period of the HNDA. This
would mean addressing the backlog of existing need over the full 20 years
period rather than in the first 5 years as was assumed in the HNDA. 
The resulting HST in the LHS is therefore 654 houses per year comprising
210 affordable houses (social and below market rent) and 444 market
houses (owner occupied and private rent). 
Progress
Local authorities must review LHS actions annually to evidence progress on
how the LHS is implementing its priorities and plans within the five-year
period. The report covers the periods 2022-23 and 2023-24 and
achievements include:
• Delivery of 394 affordable homes including 269 for social rent, 25
for low-cost home ownership, and 100 for mid-market rent
• Delivery of 50 Council new build homes, including three wheelchair
accessible properties and 11 adapted properties, and 84 buy-backs
• Support for minor and major adaptations for local authority and
private tenants and homeowners
• Delivery of a refurbishment project and two core and cluster
supported accommodation projects for individuals with a range of
housing and support needs
• Securing funding of almost £4m to transform the Council Gypsy /
Traveller site with new energy-efficient accommodation and
upgrades to create a sustainable environment
• Continuing work with the Gypsy / Traveller community to better
understand their accommodation needs 
Potential impact on the iLHLR
The LHS assumes the demand for market housing identified in the HNDA
will be met in full over the lifetime of the strategy. The availability of
funding for affordable housing, however, dictates that this will need to be
met over a longer timeframe than that assumed in the HNDA. The resulting
HST of 654 per annum is considerably lower than the annualised MATHLR
(850). There are several actions set out in the LHS designed to maximise
the use of existing housing stock and land resources. It is considered
therefore that, rather than indicating a need for a higher iLHLR, currently
the LHS highlights a need for a targeted approach to the delivery of
affordable housing. The work being undertaken to establish the unmet
needs of transient Gypsy / Travellers may, however, affect the setting of
the final LHLR in the Proposed Plan.

Page 16

Perth and Kinross Strategic Housing Investment Programme 
Issues considered:
• Housing need and demand
• Available resources
• Affordable housing delivery
• Connection with other LHS priorities
• Prioritisation framework
• Development constraints 
The latest SHIP covers the five-year period 2025/26 – 2029/30. It has been
approved by committee and was submitted to Scottish Government in
October 2024. 
The SHIP is designed as a working tool which, among other things,
improves longer term strategic planning, details how investment in
affordable housing will be directed, sets out key investment priorities and
demonstrates how these will be delivered, and informs the allocation of
resources from a national to local authority level. As well as supporting the
LHS priorities, the SHIP also aligns with the aims of the Perth and Kinross
Strategic Commissioning Plan and Housing Contribution Statement. 
Housing need and demand
The LHS has set a target of 210 new supply affordable homes per year. This
is across a range of delivery types including new build, buybacks,
conversions, and empty homes, by both Council and RSL partners with a
mix of social rent and other tenures such as shared equity and mid-market
rent. 
Available resources
Funding resources to support the delivery of SHIP priorities include:
• Affordable Housing Supply Programme
• Housing Revenue account and Prudential borrowing 
• Developer contributions – currently £1.5m available 
• Council tax reserve income from the reduction of discount for
empty and second homes including the 100% council tax surcharge
on second homes from 1 April 2024
• Housing Infrastructure Fund which funds stalled housing
development due to excessive cost or nature of the infrastructure
works required
• Vacant and Derelict Land Investment Programme – whilst there are
currently no housing sites in the SHIP with this funding attached,
the Council have agreed that priority for affordable housing would
be given when disposing of surplus land or buildings
• Rural Housing Fund – the Council is exploring sites and partnerships
with bodies who are eligible to apply
• Affordable Rural Homes for Key Workers Fund which enables local
authorities to purchase existing suitable properties in rural areas
which can be rented directly or leased to employers 
Affordable housing delivery
The programme is based on operating at 139% of the current Resource
Planning Assumption in order to effectively manage slippage and respond
to funding increases. 
Financial Year Starts (including
buybacks)
Completions (including
buybacks)
24/25 177 223
SHIP period 25/26 – 29/30
25/26 341 159
26/27 224 265
27/28 212 259
28/29 174 269
29/30 209 200
Total 1,160 1,152
Yearly average 232 230
Source: SHIP

Page 17

Connection with other LHS priorities
The following are of particular relevance to this topic: 
Empty homes – the Council’s aim is to bring 135 privately owned
properties back into use each year. The Private Sector Housing Team works
in tandem with the Housing Options Team to ensure empty homes are
targeted in appropriate areas and to those in housing need. 
Gypsy Travellers – there are two permanent sites operated by the Council
at Double Dykes and Bobbin Mill providing 26 units of chalet-style
accommodation. There are no temporary or short stay pitches on these
sites and occupancy rates are typically at 100%. There are a further 24
pitches across three private sites. A major capital project at the Double
Dykes site is underway to replace the 20 chalets with high quality energy
efficient accommodation. Feasibility studies are planned for the Bobbin
Mill site to establish what improvements can be made and significant
progress is being made to develop at transient site in Perth city. 
Accessible homes / supported housing – the LHS includes a target that 10%
of new build affordable homes will be wheelchair accessible or adaptable
but there is no mechanism to enforce a similar requirement in private
sector housing. Over the 5 year course of the SHIP 104 fully wheelchair
adapted properties will be funded. 
Rural and community led housing – the LHS sets out the aim that the urban
/ rural population split (53/47%) should be reflected in new affordable
housing delivery. This SHIP will fund 398 new affordable homes in rural
areas (61%) and 625 in urban areas (39%), but these projections do not
include buybacks or new delivery supported via the Rural Housing Fund. In
addition to the SHIP, the Council’s Housing Strategy Team work with
communities to enable Community Led Housing. The Council are also
working to deliver a ‘key worker policy’ which will include an updated
definition of key worker priority groups as part of ongoing work to seek to
address the shortfall of suitable housing in some rural areas for key
workers. 
City / Town centre living – Perth and Kinross has a substantial urban
population and a focus of town centre living can boost the local economy
and community vibrancy. In this SHIP 104 of the new affordable homes are
projected to be in or very near city and town centre boundaries. 
Prioritisation Framework
This assesses proposals based on the Council’s strategic aims, priorities,
and project deliverability. Investment decisions are balanced through a mix
of Council, RSL and developer delivery, considering various affordable
housing tenures to meet housing need across all the HMAs. A renewed
focus on deliverability has resulted in some less deliverable sites in the
previous SHIP moved to the ‘pipeline’ list, with more deliverable projects
introduced. 
SHIP 2024/25 – 2028-29
Year Expected total
site starts
Expected total
completions
24/25 713 516
25/26 369 471
26/27 246 285
27/28 163 239
28/29 197 150
5-year period 1,688 1,661 
Development Constraints
There are several challenges that can affect development including market
volatility in the construction sector impacting on private sector delivery
timescales, increased energy prices, high material prices and shortages,
shortages of labour, economic uncertainty and inflation. Whilst these
issues need careful management, they also present opportunities for
affordable housing providers. Off-the-shelf opportunities with private
developers are explored to increase affordable housing supply.

Page 18

Potential impact on the iLHLR
The SHIP sets out how investment in affordable housing will be directed
and how the LHS target for new supply affordable homes per year will be
met. It focuses on implementation rather than the setting of the iLHLR. 
Perth and Kinross Council Short Term Lets Evidence Research Report
Detailed research was commissioned by the Council on housing
affordability and an analysis of housing system pressures specifically to
inform policy considerations in relation to STLs but some of the findings
are also relevant to the wider homes issue. 
The outcomes of housing affordability modelling across Perth and Kinross
show that: 
Source: PKC STLs Evidence Research Report – note that £274,907 is the
average PKC house price 
Pressures
Housing tenure and dwelling pressures – the tenure profile in Perth and
Kinross is dominated by home ownership accounting for 62% of dwellings.
17% are social tenancies and 14% are in the private rented sector. 
Ineffective housing stock pressures – across Perth and Kinross 8% of the
housing stock is ineffective (2% second homes, 2% STLs and 4% empty
homes). This varies significantly, however, in different parts of the Council
area with as much as 24% of stock ineffective in the Highland Perthshire
HMA.

Page 19

New supply pressures – just over half the housing land supply is
concentrated in the Greater Perth HMA with only 5% of the supply in the
Highland Perthshire HMA. The majority of affordable housing projects
(59%) are also located in Greater Perth. 
Household income pressures – average annual incomes across Perth and
Kinross are higher than the national average but this overall figure hides
the considerable variations which exist across different HMAs. 
Housing market pressures – across Perth and Kinross there has been an
average turnover of 7% with 59% of sales made to local households and
41% to households from outwith PKC. This varies significantly, however, in
different HMAs with the highest levels of in migration in the Kinross and
Highland HMAs. Average house prices also vary considerably. 
Housing affordability pressures – average house price to income ratio
varies significantly across the area from 5.84 in the Strathmore HMA to
10.49 in the Kinross HMA. 
Private rented sector pressures – the private rented sector can frequently
be the default tenure for households who can’t afford home ownership
but can’t access social housing. The majority of private rents are in the
Greater Perth HMA at 60% with only 4% in the Kinross HMA. 
Social housing pressures – the availability of social housing varies
considerably across the Council area with 64% in the Greater Perth HMA to
only 4% in the Kinross HMA. Demand is, however, also highest in Greater
Perth and lowest in the Kinross HMAs. 
Potential impact on the iLHLR 
A key element of this research is to highlight the variations that exist
between the different HMAs across Perth and Kinross in relation to the
access to and affordability of housing. The research highlights a number of
issues including: 
• the existing stock is dominated by home ownership,
• there is a concentration of land supply, affordable housing projects,
and private and social rents in the Greater Perth HMA with
significantly lower levels in some other HMAs, and
• there are considerable variations in household income, average
house prices, house price to income ratio, and levels of migration
across the area. 
Some of these issues, such as the distribution of the housing land supply,
can be considered in identifying the spatial strategy for LDP3. Overall,
however, as highlighted above in relation to the LHS, these housing system
pressures are more appropriately tackled by targeting the delivery of
affordable housing rather than simply increasing total land supply in the
iLHLR. 
In relation to ineffective stock, the latest Scottish Government statistics on
empty homes (Dec 2023) indicates that since 2021 the number of second
homes in Perth and Kinross has remained relatively static at around 1,200.
Until recently there were no specific means available to the Council for
controlling the number of second homes in the area. The introduction
from 1 April 2024 of an increase in Council tax charge to 200% levied on
second homes in Perth and Kinross, however, may result in the number of
second homes reducing and either being sold or moving to short-term
letting. Conversely, the new STL licencing requirements may result in a
move from STLs to second homes.  So, whilst there is not currently
considered evidence in relation to ineffective stock which would justify
making an allowance for this within the iLHLR, more data on the impact of
the increase in the Council tax charge and the STL licencing requirements
will be available to inform the setting of the final LHLR in the Proposed
Plan.

Page 20

Existing Housing Need in Perth and Kinross – Report commissioned by
Homes for Scotland
Homes for Scotland commissioned a primary research-led approach to
understanding housing need across the whole of Scotland. A report has
also been published for the Perth and Kinross area specifically. The
research only considered existing need and not future need. 
Homes for Scotland is concerned that the Scottish Government estimates
of existing housing need included within the MATHLR calculations are
based on counts of homeless people in temporary accommodation and of
households that are both overcrowded and concealed. This is considered
too strict a definition of need as it only takes account of those households
with a particularly pressing need. Homes for Scotland argue that this tight
definition overlooks those households whose need may not be pressing,
but which should still be considered in the planning and housing processes.
The inclusion of primary data from a survey allows for wider definitions of
need and demand to be incorporated. 
Homes for Scotland is also concerned that the extensive and costly
traditional means of collecting primary data for HNDAs means that the
fuller approach to data collection is now quite rare. Through the research
Homes for Scotland sought to undertake shorter surveys of housing need
and demand and to assess the calculations in a straightforward, robust and
efficient way, allowing for the production of more accurate and meaningful
local assessments (report p.7) 
The research surveyed households using an online panel (Scotpulse). The
panel has a membership of over 47,000 adults in Scotland meaning it can
produce reliable and robust estimates at national and, in most cases, at
local / regional levels. For the Perth and Kinross report 482 households
were surveyed and extrapolating these results to c.71,000 households in
Perth and Kinross the following conclusions were drawn:
• 12,000 households have at least one concealed household
• 6,000 households are living in properties that they were struggling
to afford
• 3,000 households in the area are overcrowded
• 2,000 households were living in properties with very poor
conditions
• 1,000 households are living in properties where they do not have
the specialised adaptations or support they require 
The research acknowledges that meeting these needs will not all require
the provision of additional houses. Some needs can be met by in-situ
solutions e.g. the provision of adaptations, or by the freeing up for another
household a property of an unsuitable size e.g. an overcrowded household
moving to a larger house would free up that property for a smaller
household. 
Potential impact on the iLHLR 
A key concern identified in this research is that some HNDAs are being
carried out based only on secondary data. That is not the case in in Perth
and Kinross. The primary research included in the HNDA helped inform the
Council’s input to the identification of the MATHLR for the area in NPF4.
The Homes for Scotland research is, however, more up to date (August
2023 whereas the HNDA survey was carried out in March / April 2021) and
so it is relevant to review the data inputs to this research. 
Whilst the HNDA was based on both a telephone survey and an online
survey (415 responses in total), the Homes for Scotland survey was online
only. The latter did, however, have a larger number of responses (482).
Both surveys are confirmed as statistically robust. A significant difference
was in the length of the survey – 33 questions for the online HNDA survey
and 44 questions for the telephone survey, compared to 16 questions for
the Homes for Scotland online survey. 
Direct comparison of the results of the HNDA with the Homes for Scotland
research is not possible due to the differences in the way in which survey
questions were framed. A very general comparison of the results as they
relate to the different categories of need, however, reveals the following.

Page 21

Issue HNDA Homes for Scotland research
Concealed and overcrowded
households
403 concealed and overcrowded households which is
derived from those identifying themselves in the
survey as overcrowded or sharing amenities with
another household with double counting eliminated
Survey identified 12,000 households with at least one
concealed household, and 3,000 households that are
overcrowded
Poor quality housing  350 households in housing identified as Below
Tolerable Standard using local house condition survey
outcomes
Survey identified 2,000 households living in properties with
very poor conditions
Specialist housing  154 households who need to move due to medical
needs or who require specialist housing applications
as a measure of housing waiting lists
Survey identifies 1,000 households living in properties where
they do not have the specialised adaptations or support they
require
Affordability  No comparable measure in the survey although the
research carried out to inform policy considerations
on STLs found that 51% of households can’t afford
market entry level prices, and 10% are unable to
afford even the lowest social housing rents
Survey identifies 6,000 households living in properties they
are struggling to afford
Homeless households  421 homeless households and those with insecure
tenure using HL1 statistics and the HNDA survey
100 households that are homeless or in temporary
accommodation sourced from the Scottish Government,
Homelessness in Scotland, 2022-23
Total existing need 1,328 21,100 gross but when in-situ solutions and the ability of
households to afford to buy out of need are taken into
account the gross figure reduces to c.12,200 households in
net housing need who require an affordable housing
solution plus a further 6,600 households in need and who
could afford a market solution
Homes for Scotland acknowledge that their research does not constitute a
full HNDA but considers that it provides ‘a robust assessment of actual
need based on primary research of households in Perth and Kinross that is
up to date’. It is suggested that the figures provided in the research can be
used in conjunction with other data sources as part of the HNDA process.
The research identifies considerably higher levels of housing need than
that in the HNDA or that could be accommodated within the MATHLR. 
The HNDA was carried out using the Scottish Government’s HNDA tool and
incorporated both primary research and secondary data sources. The
HNDA was confirmed as robust and credible. The research prepared for

Page 22

Homes for Scotland was not considered in partnership with the Council or
with other housing partners. It is noted, however, from Homes for
Scotland’s response to the Homes Topic Paper, that this research is to be
discussed at Scottish Government level. If the conclusion of those
discussions is that the methodology used in this research, or elements of it,
are to be preferred nationally over those derived through the HNDA
process, then they can be used to inform the setting of the final LHLR in
the Proposed Plan. Until then it is considered that the results of the HNDA,
together with the evidence the Council provided in relation to establishing
the MATHLR, are preferred in informing the iLHLR. 
Perth and Kinross Self and Custom Build Housing
A specific requirement of the Act is consideration of persons seeking to
acquire land for self-build housing. A self and custom build register has
been set up for Perth and Kinross on the Council’s website and is gathering
interest even although there has been little done so far in the way of
promotion. To date 26 people have registered their interest and of these,
12 have indicated that they would intend to start to build within one year.
A total of 22 respondents confirmed that they have the finance in place to
build. 
It was suggested through the Topic Paper engagement that the company
‘Buildstore’ also maintain a register of people who have expressed an
interest in acquiring land for self or custom build. Buildstore is a private
company established in 1998 which provides support and services for
individual homebuilders. Buildstore have provided the Council with the
overall number of expressions of interest for land for self or custom build
for those postcode areas which are either wholly or partly within Perth and
Kinross. At the end Sept 2024 there were nearly 550 expressions of
interest in postcode areas which are wholly within Perth and Kinross –
PH1, PH3, PH5, PH7, PH8 and PH9. Around a further 380 people had
expressed interest in postcodes areas which are partially within Perth and
Kinross. More detailed analysis is required to accurately quantify this
demand, but if it is assumed that 50% of these were for areas within Perth
and Kinross this would result in a total of around 740 people who have so
far expressed an interest in acquiring land for self or custom building in
Perth and Kinross. 
Postcode Total demand Wholly within PKC Partly within PKC
PH2 227  227
PH1 324 324 
KY6 23  23
PH7 79 79 
PH6 26  26
PH3 116 116 
KY4 21  21
DD8 20  20
PH9 4 4 
KY5 20  20
DD2 28  28
PH4 13  13
PH5 12 12 
PH8 10 10 
Total 1190 545 378
Source: Buildstore Land Database 
As part of the housing land audit, completions on small sites (of less than 5
units) are recorded. It is considered reasonable to assume that a significant
proportion of these small sites are likely to be some form of self or custom
build e.g. houses in the countryside. The first Perth and Kinross LDP was
adopted in February 2014 so looking at the data from the 2015 onwards
there were 942 houses built on small sites, an average of 105 per year.

Page 23

Potential impact on the iLHLR 
In preparing the LDP, section 16(2) of the Act requires the planning
authority to have regard to the list published under section 16E of persons
seeking to acquire land in the authority’s area for self-build housing. This
could mean having a local level policy in LDP3 to support self-build
proposals and this is considered further in the Summary of Implications for
the Proposed Plan section below. 
Alternatively, or additionally, this could mean allocating sites within the
LDP specifically for self-build or to include a proportion of self-build as a
developer requirement on specific sites. In the past the LDP has tended
not to allocate sites of less than 10 houses. Instead, small sites have been
facilitated though the Housing in the Countryside policy and by allowing
scope within settlement boundaries where appropriate. No decision has
been made as yet, however, as to the scale of sites which will be allocated
in LDP3. 
The other option would be to make some provision for self-build within
the iLHLR. The HNDA toolkit takes into account a considerable number of
variables in determining the HNDA outputs. No specific reference is made,
however, to the demand / need for land for self-build. This could be
because the requirement on local authorities to maintain a register is
relatively new in Scotland, or because self-build has by default been
included within a small sites contribution which some authorities have
incorporated into their housing land requirement. It could therefore be
appropriate to make an allowance for self and custom build houses in
setting the iLHLR and this is considered further in the Summary of
Implications for the Proposed Plan section below. 
Perth and Kinross Housing Land Audits 
Issues considered:
• Past performance
• Future housing land supply
o Longer-term strategic sites
o Non-constrained sites which remain undeveloped
o Constrained sites
• Deliverability of the land supply 
Local authorities are no longer required to refer to HMAs. That is not to
say that the authority cannot still choose to use HMAs as the basis for
considering housing land supply. Given that the existing HLAs give data at
Perth and Kinross and HMA level, this has been continued in the analysis of
audit data below. 
Past performance
The main source of information on housing completions comes from the
annual HLA. The most recent published housing land audit for Perth and
Kinross reflects the position on 31 March 2023. The chart below shows
past completion rates on all sites over the two periods for LDP1 and LDP2.
The overall trend line shows a steady increase in completions over the two
Plan periods.

Page 24

Source: Perth and Kinross HLAs 
The annual HLA records those completions which have occurred on sites of
less than 5 units. As shown in the table below, small sites have historically
contributed varying proportions to total completions but have been
particularly significant in the Highland and Greater Dundee HMAs. 
HMA 2015-2023
Total small sites
Average Small sites as % of all 
completions 2015-2023
Perth 313 35 10
Greater Dundee 34 8 63
Highland 179 20 53
Kinross 144 16 18
Strathearn 153 17 15
Strathmore 119 13 19
Perth and Kinross 942 105 15
Source: Perth and Kinross HLAs 
As well as completions on small sites, the annual housing land audit
records those completions which have occurred on ‘windfall’ sites. These
are defined in the LDP as sites which become available for development
unexpectedly and are therefore not included as allocated land in the LDP.
The calculation of the housing land requirement for LDP2 assumed that
10% would be met on windfall sites. 
An assessment of historic completions on windfall sites has been
undertaken, again covering the two LDP periods. This is important as it is
generally the case that the level of windfall opportunities increase the
further it gets from the Plan adoption date. The assessment showed that
on average completions on windfall sites constituted 30% of all
completions on sites of 5 or more. 
As assessment of the tenure split between local authority, RSL, and private
sector completions on sites of five or more houses during the two Plan
periods shows that the tenure split between affordable and market
housing across Perth and Kinross is 30% / 70% although this varies in the
different HMAs. For this calculation local authority and RSL completions
have been classed as affordable and private sector completions as market
sector although there may be an element of affordable provision within
the private sector, for example, discounted for sale. 
HMA 2015-2023 split
Affordable / Market
Perth 35% / 65%
Greater Dundee 0% / 100%
Highland 28% / 72%
Kinross 18% / 82%
Strathearn 24% / 76%
Strathmore 32% / 68%
Perth and Kinross 30% / 70%
Source: Perth and Kinross HLAs
0
100
200
300
400
500
600
700
800
900
1000
2015 2016 2017 2018 2019 2020 2021 2022 2023
Annual completions over LDP1 and LDP2

Page 25

Future housing land supply
The Act requires planning authorities to set out their views on the
availability of land for housing, including for older people and disabled
people. At March 2023 there was a total non-constrained (previously
referred to as ‘effective’) land supply of 17,411 units. Homes for Scotland
disputed the effectiveness of 489 units leaving an agreed land supply of
16,922 units. There are no sites allocated specifically for housing for older
people or disabled people in LDP2. 
The map below shows the distribution of the remaining housing land
supply where 50+ houses are still to be built (2023 Housing Land Audit).

Page 26

As shown in the map above, by far the largest proportion of the land
supply is in and around Perth (71%).  Smaller proportions are in the
Strathmore area primarily at Blairgowrie (13%) and the Strathearn area
split between Crieff and Auchterarder (9%). The least supply is in the
Highland Perthshire area at Aberfeldy and Pitlochry (4%) and in Kinross-
shire (3%). Less than 1% of the supply is within the Greater Dundee area
but, as abovementioned, this is only a small part of a much larger cross-
boundary HMA. 
Longer-term strategic sites – 65% of the remaining land supply at March
2023 was on eight strategic scale sites. Three in Perth City, three in the
Greater Perth HMA (at Bridge of Earn, Luncarty and Scone), one at
Blairgowrie, and one at Crieff. All of these sites are currently programmed
to extend beyond the year 3035. Of the eight sites, three are currently
under construction. Of the five sites yet to start, three are programmed to
begin construction in the short term, one in the medium term, and one in
the long term. 
Site Timescale
Perth City (Perth West) Medium term
Perth City (Berthapark) Under construction
Perth City (Almond Valley) Short term
Bridge of Earn Short term
Luncarty Short term
Scone Under construction
Blairgowrie Long term
Crieff Under construction
Source: 2023 HLA 
Non-constrained sites which remain undeveloped – There are 153 sites in
the 2023 HLA. 33 of these sites (totalling nearly 6,800 units) are allocated
in the LDP but do not yet have planning permission. LDP2 was adopted in
2019. This is a considerable proportion of allocated sites which, at March
2023, had not yet progressed to planning application stage. Furthermore, a
number of these sites were carried forward from LDP1. 
In some cases, there may be legitimate reasons for the delay in bringing a
site forward but there is concern that in some instances sites are simply
being land-banked for a future date. This is a particular problem in areas
where the land supply is under the control of a small number of
housebuilders who may also have development interests elsewhere in the
Council area. The willingness of individual house builders to deliver on
their existing supply of allocated sites is an important factor. 
Constrained sites – Of the 153 sites in the 2023 HLA 16 of these (totalling
around 350 units) have some form of constraint which is currently
preventing development from taking place. The number of units by type of
constraint is shown in the chart below. Although land use constraint
accounts for more than half of constrained units this is due to the inclusion
of two larger sites within this category both of which are in the Perth HMA. 
Source: Perth and Kinross Housing Land Audits 
12%
11%
3%
5%2%
55%
12%
FACTORS CONSTRAINING LAND
SUPPLY
Marketability Ownership Infrastructure Physical
Programming Land use Multiple

Page 27

As abovementioned, a further four sites (totalling nearly 490 units) are
considered constrained and are disputed in the 2023 Audit by Homes for
Scotland. Two are disputed on marketability grounds, one on land use, and
one on programming. 
Deliverability of the land supply
There is a greatly enhanced emphasis in NPF4 on deliverability. As such
LDPs are to consider de-allocation where sites are no longer deliverable.
Previous HLAs have included an assessment of the land supply against the
housing land requirement set by TAYplan by providing an update to LDP
Table 1: Housing Land Requirements and supply by Housing Market Area.
The most recent update was included in the 2022 HLA. 
Housing
Market
Area
Greater
Dundee
Strathmore
and Glens
Highland
Perthshire
Kinross
Strathearn
Greater
Perth
PKC total
HLR 2016-
2029 
78 1,859 995 983 1,846 7,239 13,000
Completions
to 2022
40 438 245 576 645 2,163 4,107
Effective
supply
2022-2029
60 886 405 486 802 3,332 5,971
Windfall
assumption
0 100 60 59 99 378 696
Small site
allowance
(Highland)  
89    89
Surplus /
shortfall
22 -435 -196 138 -300 -1,366 -2,137
Source: 2022 HLA 
The commentary in the 2022 HLA identified shortfalls in housing land
supply in four of the six HMAs across Perth and Kinross but notes that
‘ultimately the issue is not one of land allocation but in the delivery of the
land in the short-medium term’. At 2022 the agreed non-constrained
effective land supply stood at 18,292 units. 
By the 2023 HLA TAYplan2 was no longer in force. For the 2023 audit,
factors which are currently affecting site delivery were apportioned to
those sites under discussion with Homes for Scotland (approximately 25%
of all sites). This was based on the approach which has been used by
Edinburgh City Council for a number of years. Factors relate to the
ownership or control of a site, the planning system, or to the development
industry. For nearly half the sites considered the key factor affecting
delivery was identified as the need to align ownership with the intention to
develop i.e. the site is allocated for housing but it has not been progressed
by the owner. These sites are not in the hands of a house builder and in
some cases the owner has indicated that they do not intend to market the
site at present. For most of the other sites the delivery factors identified
were associated with the development industry either: 
• the site is under construction and the rate of delivery is determined
by market demand,
• the site is in the control of a developer with all consents in place,
but development has yet to start, or
• planning consent is in place, but the consent was obtained by the
landowner or development company rather than a housing
developer. 
The intention is to extend this assessment of factors affecting site delivery
to all sites for subsequent HLAs and to discuss these with Homes for
Scotland as part of the annual HLA engagement process. It is recognised,
however, that whilst market factors will play a significant role in assessing

Page 28

the continued deliverability of housing sites, other elements of the NPF4
strategy must also be taken into account. NPF4 policies on tackling the
climate and nature crises, climate mitigation and adaptation, sustainable
transport, local living, and infrastructure first are just a few of the factors
which could also affect the deliverability of land for new housing. 
Potential impact on the iLHLR
Analysis of past completion rates as an indicator of future delivery must be
treated with a degree of caution as house completions are so heavily
dependent on peaks and troughs in the market. The key point to note from
historic completions data is that over the period since the adoption of
LDP1, only twice have the total completions exceeded the annualised
MATHLR of 850. Average completions over the period were just under 680.
There is not therefore considered to be evidence for making an allowance
based on historic completion rates within the iLHLR. 
The existing land supply is concentrated in the Greater Perth HMA in line
with the previous strategic development plan spatial strategy. There are
several issues which will need to be considered in the identifying of the
spatial strategy for LDP3. These are considered in the Summary of
Implications for the Proposed Plan section below but could potentially
include some redistribution of the housing land supply. There is no longer
a requirement for the LHLR within LDPs to refer to HMAs so even if some
redistributions were required this would not result in a need to make an
allowance for it within the iLHLR. 
Any change to the scale of sites allocated in LDP3 to meet the LHLR, for
example, a move away from large scale strategic sites to a larger number
of smaller sites, could potentially result in a higher number of allocations
given that a large proportion of the existing land supply is concentrated on
a small number of strategic sites. It is not possible to determine the impact
of such a change to the spatial strategy on the LHLR, however, until the
spatial strategy for LDP3 has been identified in the Proposed Plan. Any
impact of a change to the spatial strategy in terms of site size will
therefore be considered in setting the final LHLR at Proposed Plan stage. 
In relation to the deliverability of the existing land supply on setting the
iLHLR, much of the current land supply is longer term and there have been
shortfalls in short-term land supply identified in previous housing land
audits. The new planning system requires a full review of all allocated sites
for the next LDP, and it is possible that this could highlight some sites
which should be de-allocated if they have little or no prospect of delivery
within the plan period. If this is the case, then alternative deliverable sites
will be identified in LDP3. There is not therefore considered a need to
include within the iLHLR an allowance for current allocated sites failing to
come forward. Furthermore, the MATHLR already includes a 30% flexibility
allowance designed to help compensate for this eventuality. 
Homes for Scotland Briefing Paper: The Barriers to Housing Delivery
Homes for Scotland identify the barriers to housing delivery as including: 
• Net-zero transition including supply chain and grid capacity.
• Infrastructure funding and delivery causing significant impact on
development viability.
• Access to labour and skills impacting build programmes, costs and
introduction of new technologies and practices.
• Planning and consents including low minimum housing targets, and
a lack of deliverable available land.
• Market conditions including consumer confidence, mortgage
constraints, cost inflation, and the attractiveness of Scotland as a
place to invest.
• Regulatory impact making it easier to build elsewhere.
• Unintended consequences of unevidenced policy making increases
risk and uncertainty and impacts decision making.

Page 29

• SMEs are struggling including difficulties accessing development
finance – such enterprises are vital to the rural housing supply but
the existence of many are under threat. 
Potential impact on the iLHLR
This research for Homes for Scotland highlights barriers to the delivery of
housing in Scotland. It is clear from the variety, scale and significance of
the barriers set out in the research that these will not be solved by simply
increasing the supply of land. Issues such as supply chain constraints to
achieving a transition to net zero, infrastructure funding and delivery,
access to labour and skills, mortgage constraints, and cost inflation all
impact on the ability of the house building sector to deliver. The existence
of these barriers do not therefore in themselves justify making an
additional allowance within the iLHLR. 
The Role of Land in Enabling New Housing Supply in Rural Scotland
This report by Savills for the Scottish Land Commission in 2019/20 to
consider the extent to which land, specifically the cost of land and access
to land, is a barrier to new housing delivery in rural and remote rural
Scotland finds: 
• Landowners and land price – lack of land transaction data makes it
harder for landowners to establish whether the price they have
been offered is best value and can lead to unrealistic expectations.
• Market failure in rural areas – the model of speculative
housebuilding that delivers the vast majority of new homes does
not work across the majority of rural Scotland as there is often not
sufficient depth of demand or value to generate adequate levels of
profit to sustain their business models. This does, however, perhaps
create an opportunity for smaller custom build contractors in
partnership with landowners and the not-for-profit sectors to
manage risk.
• Cost of development in rural Scotland – the more remote the
market the more expensive it is to build and house and the less
affordable it is for many people living and working in rural
communities.
• The role of not-for-profit organisations – generally target housing
need rather than market demand. The price of land is often heavily
influenced by the grant funding available.
• Site effectiveness / deliverability – can be very difficult to get the
economics of a project to stack up where land is expensive to
service or unlock. Many sites in LDPs are zoned without first
understanding if that land is deliverable.
• The role of the community sector – many community groups and
development companies lack the time, resources, and skill set to
progress what are often challenging projects to unlock.
• The role of grant regimes – the lack of long-term clarity and stability
in the grant funding regimes is debilitating for the housing sector in
rural Scotland.
• The role of the planning system – early forms of rural planning was
driven by a need to protect the countryside from urbanisation, and
this has perhaps created an overly protective and relatively static
approach to planning for rural areas across much of Scotland. A
general lack of land being made available restricts supply and can
increase house prices and thus land prices. 
Potential impact on the iLHLR
As with the Homes for Scotland research above, this report highlights
barriers to the delivery of housing but concentrates on those which relate
specifically to rural and remote rural Scotland. As above, whilst these
impact on the ability of the house building sector to deliver, they will not
be solved by simply increasing the supply of land. The existence of these
barriers do not therefore in themselves justify making an additional
allowance within the iLHLR.

Page 30

Planning and the Housing Emergency – Delivery Plan
Published in November 2024, the Delivery Plan sets out the Scottish
Government’s approach to addressing the national housing emergency.
Key objectives and actions are identified including: 
• Identify mechanisms to stimulate the build-out of housing sites
with planning permission at a faster pace – for several years build-
out rates have been significantly lower than permissions.
• Work with SME householders to better understand the challenges
they face.
• Help planning authorities to bring forward new style development
plans including a pipeline of deliverable housing land and delivery
programmes – new guidance to be published on HLAs to enable
consistency in approach. 
Potential impact on the iLHLR
High level document focusing on delivery rather than the setting of the
iLHLR. 
Big Place Conversation
The housing and community indicator for the BPC Place Standard
consultation asked participants whether the homes in their area supported
the needs of their community. In some parts of Perth and Kinross housing
needs were being met with a strong sense of community, good housing
mix and, evidence of community development work supporting housing
needs. In other areas, however, the following issues were highlighted: 
• Limited or no affordable housing in some more rural areas
• A significant lack of housing in some rural communities
• Housing shortages impacting on other parts of the community, for
example in attracting and retaining workers
• Short term lets and holiday / second homes reducing housing
availability and affecting house prices
• Few opportunities for smaller and lower income households
• People move outwith the area because of housing shortages
• Impact of new housing developments on infrastructure and the
character of local areas
• A lack of temporary supporting / independent housing
• Older housing stock across the area requires significant
maintenance / energy retrofit
• Fuel poverty 
• Historic land allocations need to be reviewed 
To address some of these issues the following suggestions were made: 
• More affordable / social housing needed (including rentals) to meet
different needs e.g. families, young people, key workers
• Integrate affordable / social housing into new developments
• Provide smaller housing units for downsizing / independent living
• Protect housing for local people / workers 
• Improve infrastructure as part of new housing developments
• Restrict short term lets and second / holiday homes
• Find a balance between providing new housing and protecting the
character of existing areas
• Prioritise brownfield development
• Re-use and repurpose existing buildings to create housing
• Provide more support / funding for those living in older properties
• Communities should determine housing priorities, not developers
• Micro-homes could help deal with homelessness
• Promote self-build housing 
Potential impact on the iLHLR
Discussion on the place standard housing and community indicator
highlighted several issues of concern and suggestions as to how these

Page 31

could potentially be addressed. The need for more housing to meet a wide
range of needs is already taken into account above in relation to the
HNDA, LHS, SHIP and STL research. Issues are also considered in other
sections of the Evidence Report such as Rural Development, Tourism and,
Brownfield, vacant and derelict land. The issues raised through the BPC are
not therefore considered in themselves to justify making an additional
allowance within the iLHLR. 
Summary of Implications for the Proposed Plan: 
Issues considered:
• An indicative Local Housing Land Requirement for Perth and Kinross
• Meeting the Local Housing Land Requirement
o Windfall and brownfield sites
o Small sites
o Reallocation of requirements between HMAs
o Review of existing LDP allocations
o Allocation of new sites
• Proposed Plan spatial strategy
• Proposed Plan policy framework
• LDP Delivery Programme
• Gaps or uncertainties in data 
The key expectation of NPF policies 16 and 17 at Evidence Report stage is
the identification of a LHLR. The LDP Guidance specifically requires the
Evidence Report to include an indicative LHLR when setting out what the
evidence means for the Proposed Plan and to provide a transparent and
understandable explanation of how the iLHLR has been arrived at.
Thereafter the Proposed Plan will need to consider how to meet the LHLR, 
2 Note that windfall is seen as a potential contributor to meeting the LHLR rather than
influencing the setting of the iLHLR.
set out a spatial strategy and policy framework to support the delivery of
the LHLR, and monitor progress in the delivery of the LHLR through the
LDP Delivery Programme. 
An Indicative Local Housing Land Requirement for Perth and Kinross
In identifying the iLHLR the planning authority are expected to take into
account the housing needs of the population in particular the needs of
older people, disabled people, and people in higher and further education,
and the availability of land for housing, including for older people and
disabled people as required by Section 5(5) of the Act. Consideration
should also be given to the MATHLR, the HNDA, HLAs, the demand for self-
build, the contribution from windfall development2, the LHS and SHIP, and
the impact of ineffective housing stock. 
The table below brings together the potential impact of the evidence
considered in the preceding section on the setting of an iLHLR for Perth
and Kinross.

Page 32

Source Considers How evidence has informed the iLHLR
Housing to 2040 The national housing strategy for Scotland High level strategy document the implications of which will have
influenced the preparation of NPF4 – no change
Perth and Kinross HMP HNDA The housing needs of the population including
the needs of older people, disabled people, and
people in higher and further education
Even the highest end of the 20-year range identified in the HNDA is
considerably below the 10-year MATHLR in the NPF4 – no change
NPF MATHLR A locally adjusted estimate of newly forming
households using in-house household
projections, and a locally adjusted estimate of
existing need
PKC evidence informed the MATHLR and, whilst some updates are
available, there is not considered to be justification at present for
altering the existing or new housing need estimates – no change
SDP TAYplan2 Examination
Report
The previous HLR set for Perth and Kinross No evidence to support setting an iLHLR to reflect the land requirement
which was set in the previous SDP – no change 
LHS and associated
documents
Information relating to different tenures of
affordable and market housing including
housing for older people and disabled people,
and ineffective stock
Rather than indicating a need for a higher iLHLR the LHS highlights a
need for a targeted approach to the delivery of affordable housing – no
change
SHIP The availability of land for affordable housing
and information on local authority housing
investment priorities
The SHIP focuses on implementation rather than the setting of the
iLHLR – no change
Perth and Kinross STLs
Evidence Research Report
Affordability and housing system pressures
including ineffective stock
As with the LHS, the housing system pressures considered are more
appropriately tackled by targeting the delivery of affordable housing
rather than simply increasing total land supply in the iLHLR – no change
Existing Housing Need in
Perth and Kinross – Report
commissioned by Homes for
Scotland
Alternative existing need estimates The results of the HNDA, together with the evidence the Council
provided in relation to establishing the MATHLR, are preferred in
informing the iLHLR – no change
Perth and Kinross Self and
Custom Build Housing
Demand for self and custom build There does appear to be demand for self and custom build in Perth and
Kinross which was not taken into account in the calculation of the
HNDA. It would therefore be appropriate to make an allowance within
the iLHLR to help accommodation the demand for self and custom
build.

Page 33

Source Considers How evidence has informed the iLHLR
Perth and Kinross HLAs The availability of land for housing Much of the considerations arising from the HLAs, such as the
distribution of the land supply, site scale, and deliverability relate to the
spatial strategy and review of existing allocations for the Proposed Plan
rather than Evidence Report stage – no change
Research on the Barriers to
Housing Delivery
The barriers to housing delivery The variety, scale and significance of the barriers identified will not be
solved by simply increasing the supply of land, and the existence of
these barriers do not in themselves justify making an allowance within
the iLHLR – no change
Research on the Role of Land
in Enabling New Housing
Supply in Rural Scotland
The barriers to housing delivery in rural Scotland
Planning and the Housing
Emergency – Delivery Plan
The Scottish Government’s approach to
addressing the national housing emergency
Focuses on delivery rather than the setting of the iLHLR – no change
Big Place Conversation Consultee views on whether homes support
community needs 
The need for more housing to meet a wide range of needs is already
taken into account in the HNDA, LHS, SHIP and STL research and some
of the other issues identified are considered in other sections of the
Evidence Report – no change
Whilst the HNDA and MATHLR are the starting points, consideration needs
to be given to any local factors and / or new evidence which has arisen
since their publication in setting the iLHLR in the Evidence Report. The
iLHLR must be evidence-based. 
There is an agreed land supply for housing of nearly 17,000 units. The chart
below shows that in very simplistic terms there is more than enough non-
constrained housing land identified in the most recent published HLA to
accommodate even the highest PKC or Scottish Government need
estimate. There is even sufficient supply to meet the vast majority of the
significantly higher Homes for Scotland identified need. At a build rate of
850 units per year (the annualised MATHLR) there is sufficient land to last
nearly 20 years, almost double the 10-year LDP period. It is acknowledged,
however, that this is not a straightforward calculation and that ultimately
it is the bringing forward for development of that non-constrained land
supply which results in the end delivery of houses on the ground.

Page 34

In proposing a locally adjusted MATHLR the Council wished to reflect its
ambitions for the sustainable growth of Perth and Kinross, and this was
reflected in the challenging figure put to Scottish Government. Whilst the
Council was acutely aware of the risks of failing to allocate a generous
supply of land for housing in the new LDP when proposing a revised
MATHLR, it must also be recognised that an oversupply of land could also
pose significant risks. Key questions to consider are firstly, what capacity is
there within the industry to deliver houses at a higher rate and secondly,
what would be the impact of increasing the supply of land for housing on
the overall delivery of housing in Perth and Kinross. One concern is that a
significant increase in the allocation of sites could dilute the market and /
or lead to developers ‘cherry-picking’ the easiest sites in the most
profitable areas to the detriment of achieving regeneration goals and
sustainable development in other parts of Perth and Kinross. 
The MATHLR set out in NPF4 for Perth and Kinross already includes a
generous flexibility allowance of 30% to compensate for sites stalling or
not delivering as expected. 
As identified earlier in this section, it is expected that some new or
updated information will be available by the time the LHLR in the Proposed
Plan is prepared and this may result in a final LHLR which is different to the
indicative figure set out in the Evidence Report. This includes: 
• Updates to HNDA inputs, for example from the 2022 Census
• LHS Annual Reports
• Information on the unmet needs of transient gypsy / travellers
• New evidence relating to ineffective stock:
o Impact of 200% Council tax levy on second homes
o Impact of STL licencing requirements
• Changes to HNDA methodology at national level
• Self and custom build register
• Enhanced deliverability assessment of all HLA sites
• Impact of the Proposed Plan spatial strategy 
The suggestion of setting the iLHLR at 10,000 units over 10 years to reflect
the SDP has been discounted as there is no evidence to support it. The
other option considered in the Topic Paper of no increase on the MATHLR
is also discounted as LDP Guidance expects that the LHLR will exceed the
MATHLR. Furthermore, Homes for Scotland have made clear that, as the
representative body of private sector housing providers, they would not
support this approach. 
Taking all of the currently available information into account, however,
there is considered little evidence at this stage for setting an iLHLR which is
significantly higher than the MATHLR. This is because the HNDA for the
area is up to date and because the factors which could justify an increase
0
2000
4000
6000
8000
10000
12000
14000
16000
18000
20000
LHS HST (5 years) MATHLR (10 years) HNDA (upper
estimate over 20
years)
Homes for Scotland
Research total
existing need
Comparison of need estimates against supply
Need Non-constrained land supply
Total supply (incl. constrained sites)

Page 35

to the iLHLR (such as housing market drivers, estimated future need and
demand including for elderly people and disabled people and those in
higher or further education, and housing stock pressures) have already
been considered in the setting of the MATHLR. The exception to this is
taking account of the demand for self-build. 
The data from Buildstore suggests that the demand for self build may be
considerable. As abovementioned, however, only data on the overall
number of expressions of interest within Perth and Kinross postcode areas
has so far been obtained and this may include individuals registering an
interest in more than one postcode area. It cannot therefore be
considered an absolute indicator of demand at this stage. It is, however,
considered appropriate to make an initial allowance within the iLHLR to
accommodate the apparent demand for self and custom build in Perth and
Kinross. Of the 26 people who have indicated an interest on the Council’s
register, 12 have said that they would intend to start building within a
year, and a further 8 (with unknown timescales) have indicated that they
have got the finances to pay for the build. It is therefore considered
appropriate to make an initial conservative allowance of 20 units per year,
200 in total over the 10 year period of the Plan, to help accommodate the
demand for self and custom build. This will be considered further at
proposed plan stage once more detailed information on demand is known. 
The iLHLR for Perth and Kinross is therefore set at 8,700 over the 10-year
period on the grounds that: 
• The MATHLR already takes account of the Council’s commitment
to sustainable growth by seeking a challenging land requirement
which balances the need to ensure a generous supply of housing
land against the potential risks associated with oversupply. This
commitment led directly to a more than 3-fold increase in the
MATHLR from the interim draft figure of 2,650 to the final figure
in NPF4 of 8,500.
• It is considered appropriate to include an initial conservative
allowance of 200 units to help accommodate the demand for self-
build as this was not included in the HNDA.
• Taking account of stakeholder views that the iLHLR is expected to
exceed the MATHLR although, with the exception of Homes for
Scotland, respondents did not appear to be seeking a significant
increase over the MATHLR. 
Meeting the Local Housing Land Requirement
In meeting the identified HLR, the calculations for LDP2 assumed that 10%
of the requirement would be met on windfall sites, 15% would be met on
small sites in the Highland HMA only, 10% of the requirement would be
reallocated from the Kinross HMA to the Greater Perth HMA for
environmental reasons, and 10% would be reallocated from the Highland
HMA to the Greater Perth HMA due to environmental constraints. The
paragraphs below identify issues which will need to be considered in
meeting the LHLR in the Proposed Plan. 
Windfall and brownfield sites
The LDP Guidance allows authorities to take account of the contribution of
windfall sites to meeting their LHLR. Any assessment of the expected
contribution of windfall sites must be realistic and based on clear evidence
of past completions and sound assumptions about likely future trends. 
The Brownfield, Vacant and Derelict Land and Empty Buildings section of
the Evidence Report highlights the work currently being carried out to
develop a register of potential brownfield regeneration sites which arose
from an action in the LHS to maximise the potential to create more homes
through brownfield regeneration. This study is still at an early stage and
will take some time to complete but it may well identify sites which can be
considered for allocation in the Proposed Plan. This in turn should mean
that going forward completions on windfall sites as a percentage of overall
completions is most likely to reduce. At this stage is it not therefore

Page 36

considered that sound assumptions can be made about the likely future
contribution from windfall sites and as such it is not currently proposed to
include a contribution from windfall sites in meeting the iLHLR, rather
these will provide a further element of flexibility in the land supply. 
Small sites
Small sites have historically made a significant contribution to overall
completions in Perth and Kinross, particularly in the Highland HMA, and as
such the previous housing land requirement included an assumption that
15% of the housing land requirement in the Highland HMA would be met
on small sites. There is, however, no specific mention of small sites within
the LDP Guidance. As above mentioned, in the past the LDP has tended not
to allocate sites of less than 10 houses and no decision has been made as
yet as to the scale of sites which will be allocated in LDP3. It may therefore
be that some smaller sites will be included in meeting the LHLR as site
allocations. It is not proposed at present, however, to include an
assumption that an overall percentage of the LHLR will be met on small
sites. Instead, these will also add flexibility in the supply. 
Reallocation of requirements between HMAs
As above mentioned, there is no longer a need to consider housing land
supply or requirement at the HMA level so reallocation between HMA is no
longer relevant. 
Review of existing LDP allocations
Currently some settlements rely on a very small number of sites for their
supply of housing land which leaves a shortfall if these fail to deliver. The
new planning system requires a full review of all allocated sites for the
next LDP. No site should just roll forward from one plan to the next as has
sometimes been the case with past LDPs. This means that any sites which
are uncertain in terms of their deliverability should be considered for
removal from the next plan. This will require suitable deliverable
alternative sites to be identified. 
Allocation of new sites
As identified in the calculation of the iLHLR above, there is currently
sufficient housing land supply overall to comfortably accommodate the
MATHLR. Should a review of the deliverability of existing allocated sites
identify a need for new sites, however, these will be assessed using the site
assessment methodology. As discussed in the Design Quality and Place
section of the Evidence Report, Homes for Scotland have invited the
Council to utilise the Site Assessment Methodology and Deliverability
Checklist they have prepared when considering ‘call for sites’ submissions.
This is still in draft form, and it is noted that it may require revision once
the Scottish Government’s new HLA guidance is published. The site
appraisal template that the Council proposes to use is included as an annex
to the Evidence Report. It is largely based on the agreed LDP: Site
Assessment and SEA Checklist template developed by the Consultation
Authorities, but with consideration given to the deliverability criteria
suggested by Homes for Scotland. 
It should be noted that there are other pieces of work which will need to
be carried out before selecting new sites, for example, review of the green
belt and work on 20-minute neighbourhoods, as these will inform the site
selection process. In identifying new sites, as well as assessing the
suitability and deliverability of the site itself, it also may be appropriate to
take in account wider considerations such as: 
• the range and / or size of existing allocations within a settlement or
distribution within the wider HMA
• the potential for a site to deliver on wider corporate objectives or
provide multiple benefits
• the need for a particular tenure or type of housing, or housing for
specific groups

Page 37

Proposed Plan Spatial Strategy 
The spatial strategy for the current LDP2 was established by the then SDP
which directed LDPs to focus the majority of development in the area’s
principal settlements. Below these the LDP2 strategy allocated limited
growth to those settlements with a range of facilities capable of serving
local needs. Growth within the smallest and least accessible settlements
with few or no local facilities was restricted. 
Section 4: Perth and Kinross LDP2 Monitoring reviews the implementation
of the Plan’s spatial strategy themes and land allocations. Specifically in
relation to the above hierarchical approach adopted from the SDP, the
restriction on growth within the smallest and least accessible settlements
has made the delivery of affordable housing in these communities
particularly challenging and this will be considered in the preparation of
the Proposed Plan. 
The NPF places new and / or enhanced emphases on some of the issues to
be considered in defining the spatial strategy for an area. The Proposed
Plan spatial strategy as it relates to land for housing will need to take
particular account of: 
NPF Policy 8 Brownfield, vacant and derelict land and empty buildings
This issue is considered in Section 5 and Appendix A: Sustainable Places of
the Evidence Report under Brownfield, vacant and derelict land and empty
buildings. This policy seeks to ensure that ‘development is directed to the
right locations, maximising the use of existing assets and minimising
additional land take’. The spatial strategy for LDP3 will need to consider
the options to achieve this, for example, increasing densities on
established sites, and the actions that the Council can take to accelerate
the delivery of houses on sites which are currently constrained. 
Policy 15 Local living and 20-minute neighbourhoods
This issue is considered in Section 5 and Appendix B: Liveable Places of the
Evidence Report under Local Living and 20-minute neighbourhoods. This
approach seeks to create connected and compact neighbourhoods where
people can meet the majority of their daily needs within a reasonable
distance of their home. This will clearly have a significant impact on where
new sites for housing should be identified. 
NPF Policy 16 Quality Homes
One specific requirement of Policy 16 not considered so far under the
Homes issue is the identification of areas that may be suitable for new
homes beyond the 10-year lifespan of the LDP. This does not impact on the
iLHLR which is to consider the 10-year Plan period but will be relevant to
take into account in the identification of the spatial strategy for the
Proposed Plan. 
NPF Policy 17 Rural Homes
There is a specific requirement under Policy 17 to identify in the spatial
strategy any previously inhabited areas that are suitable for resettlement.
This issue is considered in Section 5 and Appendix E: Rural Development of
the Evidence Report. 
NPF Policy 18 Infrastructure first 
This issue is considered in Section 5 and Appendix D: Infrastructure and
Transportation of the Evidence Report which look at cemetery provision,
communications and digital, education facilities, healthcare, transport, and
water and wastewater. The Infrastructure First approach will inform the
Proposed Plan spatial strategy by helping identify those areas with existing
infrastructure capacity, areas where development could help support
existing infrastructure, or areas which are currently constrained but where
development could help secure new infrastructure. It will not be
appropriate to identify sites for housing in isolation without considering
the potential impacts on infrastructure and infrastructure needs.

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NPF Policy 29 Rural development
This issue is considered in section 5 and Appendix E: Productive Places of
the Evidence Report under Rural Development. This policy places a much
greater emphasis on encouraging economic activity in rural areas in order
to create vibrant and sustainable rural places and a balanced and
sustainable rural population. The spatial strategy in the Proposed Plan will
therefore need to balance this increased support for development in rural
areas and the delivery of homes in sustainable locations. The spatial
strategy will also need to set out an appropriate approach to development
in rural areas which reflects the identified characteristics of those areas. 
LDP2 Policy 6 Settlement boundaries
The existing spatial strategy in LDP2 presumes against development
adjacent to defined settlement boundaries except in a small number of
circumstances. There is no similar emphasis in NPF4 and as such
consideration will need to be given in the Proposed Plan to the future role
of settlement boundaries as a means of either restricting or encouraging
additional development. This may be particularly relevant in relation to
facilitating development in rural areas, especially for affordable housing. 
Proposed Plan Policy Framework 
The intention of NPF housing policy is to encourage, promote and facilitate
the delivery of more high quality, affordable and sustainable homes, in the
right places and providing choice across tenures that meet diverse housing
needs. The existing suite of housing-related policies in LDP2 includes: 
• Policy 19: Housing in the Countryside
• Policy 20: Affordable Housing
• Policy 21: Gypsy / Travellers Sites
• Policy 22: Particular Needs Housing Accommodation
• Policy 23: Delivery of Development Sites
• Policy 25: Housing Mix 
In addition to these the policy framework for the Proposed Plan will need
to consider how best to plan for the following housing solutions and
options. 
Increasing the provision of affordable homes
The HNDA and Affordable Housing System Pressure Analysis discussed
above identifies the percentage of the Perth and Kinross households who
will rely on affordable housing options to meet their housing needs. The
tenure split between affordable and market housing identified in the
HNDA is nearly 50/50. The tenure split of past completions for Perth and
Kinross over the last decade, however, is approximately 30% affordable to
70% market. The figure below superimposes the percentage split of need /
demand by tenure over the past 10 years completions. This highlights that
market completions have historically been consistently above the market
demand identified in the HNDA, whilst affordable completions (RSL and
Council) have been consistently below the identified affordable need. The
SHIP identifies the challenges involved in the development of affordable
housing projects and the extent to which the affordable housing
programme is dependent on private sector build-out rates.

Page 39

Source: HNDA and HLAs 
NPF Policy 16e) requires an affordable housing contribution of at least 25%
on market housing sites unless the LDP sets out locations or circumstances
where a higher contribution is justified by evidence of need, or
alternatively a lower contribution is justified. The latter could be by
evidence of impact on viability, where proposals are small scale, or where
there is a desire to incentive particular types of homes such as self-build or
wheelchair accessible homes. Consideration will need to be given in
developing the Proposed Plan policy as to whether an alternative
affordable housing contribution is justifiable in some parts of Perth and
Kinross and under what circumstances, or whether there are other suitable
options such as the allocation of sites for 100% affordable housing, the
opportunities for development of Council-owned land, or the scope for
cross-subsidy with market housing. 
Self-provided homes
Many houses built under the existing LDP2 housing in the countryside
policy are already a form of self-build. There was also an attempt to make
provision for self-build opportunities on larger sites through the
preparation of LDP2 by introducing a requirement in policy 23: Delivery of
Development Sites for developers to demonstrate how delivery on the site
will be maximised including provision for self-build. The LDP examination
Reporter amended the policy wording, however, to the ‘consideration of
provision for self-build’ due to concerns raised by developers with regard
to potential lending, complexity and health and safety-related problems
especially on larger sites. Any local policy designed to encourage self-build
opportunities will therefore need to take account of these concerns as well
as evidencing demand for self-build. 
Rural homes
There is a much enhanced emphasis on the delivery of new housing in
rural areas in the NPF in order to improve choice of tenure to meet the
needs of local people and provide homes that support sustainable rural
communities. The existing LDP2 housing in the countryside policy supports
proposals for single houses and small groups of houses in the countryside.
The Proposed Plan, however, will need to consider whether there is a need
for local level policy specifically to encourage and facilitate the accelerated
delivery of affordable, sustainable homes in rural areas consistent with
balanced consideration of the intent and outcomes of the suite NPF
policies. This could be considered in tandem with a review of the existing
LDP2 settlement boundary policy. 
Homes to meet particular needs
The LHS and SHIP are the primary vehicles for the delivery of housing for
specific groups which require affordable housing. It would be incorrect,
however, to assume that every household containing an older or disabled
person needs an affordable house. Some will have the financial means to
meet their needs on the open market but only if market housing which is
suitable to meet their needs is available. The Proposed Plan will need to
consider whether there is a continued need for a local level policy in order
to secure a greater proportion of homes within market developments to
0
20
40
60
80
100
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023
Comparison of need against
past completions
% Market completions % Affordable completions
% HNDA market demand % HNDA affordable need

Page 40

meet particular needs and / or to look at alternative means of provision,
for example, allocating sites wholly or partly for market housing options
particularly to meet the needs of older or disabled people. 
Given the high level of need for more accessible housing, wheelchair
accessible housing in particular, the Proposed Plan will also need to
consider the most appropriate way to address this need. The Council is
already working with RSL partners to deliver wheelchair accessible housing
in the affordable sector and the forthcoming changes to building standards
to underpin the Scottish Accessible Homes Standard should have an
impact on the numbers of more accessible market housing. NPF Policy 16c)
already supports development proposals for new homes that improve
affordability and choice by being adaptable to changing and diverse needs,
and which address identified gaps in provision and consideration will need
to be given as to whether local level policy is required to supplement this. 
LDP Delivery Programme 
There is a much enhanced emphasis in the NPF on the actual delivery of
the LDP with an expectation that the LDP delivery programme will
establish a deliverable housing land pipeline considering the short,
medium and long term delivery of housing land. This will require the
allocation of sites which are secure in their delivery and the regular and
accurate on-going monitoring of these through the housing land audit
process. PKC is committed to undertaking this review process and in
bringing forward a pipeline of deliverable housing land and delivery
programme as per the NPF and the Planning and Housing Emergency
Delivery Plan.   
Gaps or Uncertainties in Data
Short Term Lets
More analysis is needed on the impact of residential properties as holiday
accommodation. Data will become available on the potential for impact
from the higher Council tax levy on second homes and the STL Licencing
requirements on properties moving from STLs to second homes to inform
the preparation of the final LHLR in the Proposed Plan. 
Gypsy / travellers and travelling showpeople
A specific instruction in the NPF is for LDPs to allocate land for Gypsy /
Travellers and Travelling Showpeople where need is identified. The HNDA
concluded that over a 5-year period there would be a -2 shortfall to +4
surplus in permanent Gypsy/Traveller site pitches This was, however,
based on 2016 data and is qualified by uncertainties in estimating demand.
In relation to Travelling Showpeople, the HNDA referred to the then draft
2022-27 LHS which had no evidence on the needs of Travelling
Showpeople to support estimating future requirements. It is acknowledged
that the data relating to the accommodation needs of Gypsy / Travellers
and Travelling Showpeople is in need of updating. An updated needs
assessment is programmed to be carried out 2025/26 and PKC is exploring
the possibility of working with neighbouring authorities on this. The
updated need assessment will inform the final LHLR in the Proposed Plan. 
Deliverability of land supply
Every year the audit is discussed with Homes for Scotland with a view to
achieving consensus on individual site programming. With the changes
brought about by the new planning system it was a more complicated
process when discussing the 2023 HLA, especially given that the 10-year
housing land pipeline is not yet in place. As a result, it was not possible to
reach agreement on the programming of four sites within the 2023 audit,
all of which Homes for Scotland consider constrained and should not be
programmed within the 10-year period. Whilst this is far from ideal there
will be further opportunities for discussion with Homes for Scotland and
their members through the preparation of subsequent audits which will
inform the preparation of the final LHLR in the Proposed Plan.

Page 41

The consideration of factors affecting delivery as used by Edinburgh City
Council is still at an early stage and only some sites in the HLA have been
discussed in draft form with Homes for Scotland as a pilot exercise in 2023.
This highlighted that it may be appropriate to adapt the Edinburgh
approach to more closely reflect some of the factors applicable in Perth
and Kinross before rolling this out as a formal part of the HLA process. It is
proposed that this will be carried out for future HLAs and will therefore be
in place to inform the final LHLR in the Proposed Plan. 
Summary of Stakeholder Engagement:
The LDP Guidance indicates that the stakeholders expected to be engaged
in the preparation of housing related evidence for the Evidence Report
includes – local authority housing colleagues, social housing providers,
private housing providers, landowners, representative bodies of housing
providers and landowners, and housing and specific interest groups. There
is a particular requirement for the Evidence Report to be informed by the
views of the Gypsy Traveller and Travelling Showpeople communities. 
Engagement on HNDA outputs
A crucial element in producing the HNDA was in securing the scrutiny,
feedback and support of external partners and stakeholders in building the
HNDA evidence base and in validating the core outputs and housing
estimates. To facilitate this, two engagement events were held in May and
December 2021. The focus of the May event in particular was to help
inform the Council’s response to Scottish Government on the interim draft
MATHLR. Over 80 partners and stakeholders with interests across the
whole Tayside HNDA area (Angus, Dundee, Fife and Perth and Kinross
Council areas) attended the event. This included representatives from
partner local authorities, RSLs, private developers, economic development
agencies, health and social care partnerships and third sector
organisations. 
As discussed in the summary of evidence section above, in addition to the
two scenarios considered in the HNDA a further ‘growth scenario’ was
developed as the HNDA was being prepared and although this was not
included within the final HNDA it was one of the scenarios which was
discussed with partners and stakeholders. There was unanimous support
for using a growth scenario to inform future housing supply targets. This
feedback informed the Council’s response on the interim draft MATHLR for
Perth and Kinross which in turn led to a final MATHLR in the NPF more
than three times higher than the draft figure. 
The second engagement event was an opportunity for external partners
and stakeholders to scrutinise the HNDA evidence and validate the final
HNDA housing estimates by sub-area and by tenure. A total of 54 partners
and stakeholders with interests across the Tayside HNDA area attended
and provided feedback on the contextual factors which should be
considered when using housing estimates as the basis for future policy
development. 
Big Place Conversation 
The Council carried out its ‘Big Place Conversation’ exercise to kick start
the LDP3 process across Perth and Kinross communities during most of
2023. This was a substantial exercise involving over 100 events throughout
the Council area. The events ranged from drop-in information sessions,
meetings, and online surveys to workshops and online sessions using the
Place Standard Tool to capture the views of local communities about
different aspects of their places. The results of the BPC are summarised as
part of a separate report on the outcomes and findings across the different
locality areas. 
Engagement with Gypsy / Traveller communities
In addition to the open public consultation there were also targeted
sessions held with minority groups. This included discussions with

Page 42

members of the Gypsy / Travelling community on private and council sites
and in bricks and mortar housing. The Participation and Engagement
section of the Evidence Report sets out details of the engagement with the
Gypsy / Traveller community and comments received are incorporated
into the PKC Wide summary report and Cleish and Blairadam, and Tulloch
Community Council reports. This includes an indication that waiting lists
may be a poor indicator of demand, and also that there are people in
social housing who would prefer accommodation more suited to their
needs. 
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. 
In addition to the key agencies prescribed under the Planning Act, the
following stakeholders were contacted directly about the Topic Papers:
local authority housing colleagues, members of the Perth and Kinross
Housebuilders Forum (including social and private housing providers),
larger estates / landowners in the area, the Scottish Federation of Housing
Associations, Homes for Scotland, Scottish Land and Estates, Rural Housing
Scotland, National Farmers Union Scotland, MECOPP, and Scottish
Enterprise.

Page 43

Statements of Agreement/ Dispute: 
11 responses were received on the Homes Topic Paper. Just over half of respondents either agreed with or had no comment to make on the evidence
identified through Topic Paper 020, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered
examples of additional sources of information which they felt should be considered and / or highlighted other potential implications for the Proposed Plan. A
summary of these comments, their status, and the Council’s response are provided in the table below. There were three responses on the Homes 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
Tactran Not stated List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Further Comments: 
Tactran notes that it is difficult to understand the scale of the
problem and the potential impact new development can
have on quality homes without knowing the baseline data in
ln relation to (traffic related) noise levels (see Scotland’s
Noise Mapping), air quality – especially in the declared
AQMAs in Crieff and Perth – and accident statistics. 
Formal Dispute: No 
The SEA for the Proposed Plan will
consider the relevant
environmental baseline to identify
best sustainable locations for
development considering any
existing and likely future
environmental impacts and
appropriate mitigation measures
to address these.   
Scottish Water Neither List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Formal Dispute: No 
No action required
Errol Community
Council
Neither List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Formal Dispute: No
No action required

Page 44

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Aberfeldy
Community
Council
Agree List of Evidence/Datasets and Summary of Implications for
Proposed Plan (PP): 
Generally agree 
Further Comments: 
Highlighted key points around the need for more (affordable)
housing in the area. Relevant to this topic:
• Range of additional housing sites to be identified and
not relying on current allocated site in Aberfeldy
• Surrounding smaller settlements to support delivery
of new affordable housing development to lessen
impact on Aberfeldy
• Loss of residential housing to holiday accommodation
therefore suggestion for higher affordable housing %
as part of new developments 
Formal Dispute: No 
Comments have helped inform the
Summary of Implications for the
Proposed Plan section of the
Evidence Report.
Earn Community
Council
Agree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Further Comments: 
Appears there is sufficient land to meet housing needs – but
also the opportunity to demote sites and potential/optional
to allow for planning authorities to 'Call for Ideas'.  There is
also a need to make sure that homes are being built in the
right places and meet the needs of age, education and
health.   
The existing spatial strategy in LDP2 also presumes against
development adjacent to settlement boundaries (LDP2 Policy
Comments have helped inform the
Summary of Implications for the
Proposed Plan section of the
Evidence Report.

Page 45

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
6).  There is no similar emphasis in NPF4 and as such
consideration will also need to be given through the plan
preparation process to the future role of settlement
boundaries as a means of either restricting or encouraging
additional development.  Strongly Agree with this statement. 
Noted that the options proposed for the iLHLR are 8500
homes over 10 years or 10,000 over 10 years and what
calculation to use in order to determine this. 
Formal Dispute: No 
Private Individual  Disagree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): 
The data based upon Homes for Scotland is biased and
should not be included. The premise that housing leads to
growth should be removed. 
Further Comments: None 
Formal Dispute: The respondent wishes their comments to
be recorded as a formal dispute on the grounds that using
data from a self-interested source – Homes for Scotland –
distorts the report. The premise that houses lead to growth
should be substantiated. An estimate of available
employment opportunities should be indicated. The Report is
the foundation of other reports in the submission so should
be accurate and unbiased. 
The LDP Guidance states that it is
‘vital that stakeholders get
involved by providing data,
information, and their views at an
early stage’ (para 117).
Stakeholders expected to be
engaged in the preparation of
housing related evidence for the
Evidence Report includes private
housing providers, and
representative bodies of housing
providers. It is therefore
considered appropriate to take
Homes for Scotland’s views and
data into account in preparing the
Evidence Report. 
Conclusion on dispute:

Page 46

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
It is not considered appropriate for
the Council to disregard the
evidence submitted by Homes for
Scotland. The dispute therefore
remains unresolved. 
Homes for
Scotland
Disagree List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): 
1. Further data on housing system pressures in Perth and
Kinross must be available for review prior to the
submission of the Evidence Report to the Gate Check
process. 
2. It is imperative that future LDPs reflect and respond to
the national Housing Emergency and that this must act as
a central pillar in determining housing targets at the local
level. An accurate, dependable, and up to date evidence
base is therefore essential. It is positive that the ‘Existing
Housing Need in Perth and Kinross report’, commissioned
by Homes for Scotland is referenced in the Topic Paper
but more consideration must be given to it in setting the
indicative LHLR. Where stakeholders consider further
evidence may be relevant after the HNDA, this may be
raised in engagement and reflected in the Evidence
Report. Stakeholders expected to be engaged in the
preparation of housing related evidence for the Evidence
Report include representative bodies of housing providers
and landowners. Where more recent information is
available this should be used (LDP Guidance). The Homes
for Scotland report is based on a household survey that
includes families in over-crowded homes, young people
1. Further data was published and
forwarded to Homes for
Scotland on 21 August. This
data has been incorporated
into the Evidence Report. 
2. The HNDA was carried out
using the Scottish
Government’s HNDA tool and
incorporated both primary
research and secondary data
sources. The HNDA was
confirmed as robust and
credible. The Diffley Report
prepared for Homes for
Scotland was not considered in
partnership with the Council or
with other stakeholders. It is
noted, however, that this
research is to be discussed at
Scottish Government level. If
the conclusion of those
discussions is that this research
is to be preferred nationally
over those derived through the

Page 47

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
still living with parents, and older people in homes that
are unfit for their changing needs. Furthermore, the
recent Chief Planner’s letter includes convening a
discussion on the Homes for Scotland report and it is
clear, therefore, that this research is an important
cornerstone in seeking to deliver more homes. 
3. The c.12,200 households figure referred to in table 19 of
the Topic Paper does not reflect the results of the Existing
Housing Need in Perth and Kinross report regarding
estimated total existing need. The report identifies that
there are around 19,000 households in existing need once
those who can make in-situ repairs are deducted. 
4. There must be continued engagement with the industry
given the socio-economic benefits of home building. 
5. The MATHLR is to be exceeded in setting the Local
Housing Land Requirement. There is therefore no basis
for Option 1. Homes for Scotland would robustly dispute
any attempt to set an LHLR that does not exceed the
MATHLR. 
6. It is too early to say what the LHLR should be as this
depends on a thorough analysis of all available evidence
of existing and newly arising housing need and demand,
and the extent to which those needs and demand can be
addressed by existing housing stock. 
7. Agree with the Council’s proposed approach to not
include in the indicative LHLR a contribution from windfall
sites or small sites.
HNDA process, then it can be
used to inform the setting of
the final LHLR at Proposed Plan
stage. 
3. The Evidence Report has been
amended to more accurately
reflect conclusion 4 of the
Diffley Report. 
4. Agreed 
5. There is an expectation rather
than a requirement for the
LHLR to exceed the MATHLR.
The Topic Paper concluded that
the MATHLR already seeks a
challenging land requirement
for Perth and Kinross and
therefore option 1 was
considered reasonable. That
said, the Council wished to also
seek views on setting a higher
iLHLR for the Evidence Report
hence option 2 which is nearly
18% higher than the MATHLR.
Homes for Scotland’s views on
the iLHLR exceeding the
MATHLR have been
incorporated into the Evidence
Report.

Page 48

Respondent Agree or
Dispute
Summary of Comments PKC’s Response 
8. The 2023 HLA non-constrained land supply figure of
16,922 is incorrect. 
9. It is unclear why the 2022 HLA is referred to in the Topic
Paper when the 2023 Audit is published. 
10. There is a greatly enhanced emphasis in NPF4 on
deliverability and LDPs are to consider the de-allocation
of undeliverable sites (draft Site Assessment Methodology
proposed). This process may affect many of the sites
currently referred to as being non-constrained. 
11. Projected completions post Plan adoption (Oct-Dec 2027)
must be removed as they will be delivered outwith the
emerging plan period. Across this period, the HLA actually
demonstrates a non-constrained land supply of just 6,402
units (including sites which may be removed in the next
LDP but excluding programming for 2035/36 onwards as
no annualised completions projections are available for
this period). Removing those sites which are currently
disputed by Homes for Scotland reduces this further to
5,912 units. 
Formal Dispute: Homes for Scotland wish to formally dispute
this issue on the grounds that the MATHLR is to be exceeded. 
6. The Council is required to
identify an indicative LHLR in
the Evidence Report, based on
currently available evidence,
which will be replaced by a
final LHLR at Proposed Plan
stage. 
7. Noted. 
8. 16,922 is the agreed supply.
This figure removes from the
non-constrained / effective
supply identified in the 2023
HLA the 489 units which were
disputed that year by Homes
for Scotland. 
9. The 2022 Audit is only referred
to in relation to the previous
housing supply target set out in
TAYplan2. This comparison was
not carried out in the 2023
Audit as by then the TAYplan2
target had been superseded by
the MATHLR in NPF. 
10. It is acknowledged that any
sites which are de-allocated
through LDP3 will need to be
replaced. Homes for Scotland’s
proposed deliverability

Page 49

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
checklist has been taken into
consideration in compiling the
site assessment methodology
template. 
11. Those units which are
programmed in the HLA
beyond the Plan adoption date
are so because of the capacity
of the industry to deliver. If the
delivery rate is increased, then
the programming can be
brought forward in the housing
land pipeline as the sites are
not considered constrained. 
Conclusion on dispute:
The iLHLR set out in the Evidence
Report exceeds the MATHLR so on
strict interpretation, the dispute is
resolved. It is acknowledged,
however, that taking a broader
view of Homes for Scotland’s
concerns it is likely that they will
be of the view that the iLHLR
should be higher still than that
proposed in the Evidence Report. 
Gray Planning and
Development Ltd
on behalf of GS
Neither  List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments 
Further Comments: 
The differences between the HNDA
and the Diffley Research is
considered in the Evidence Report.

Page 50

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
Brown
Construction Ltd
Noted that in the HNDA analysis there is a housing need of
around 1,328 compared to a Homes for Scotland analysis of
21,000. This suggests considerably higher levels of housing
need than that in the HNDA or that could be accommodated
within the MATHLR. 
Agree with the principle of de-allocating sites which are
constrained and in the current LDP – however this must be
with a suitable deliverable replacement in terms of scale and
form of proposals. We also agree with the method to look at
sites which have consent to a landowner but have not
progressed into control of a housing developer, to enable
actual realisation of housing delivery. 
Preference would be Option 2 as this reflects Strategic
Development Plan previously set out. 
Broadly supportive of a potential shift in spatial strategy of
the new LDP to bring more focus on rural areas encouraging
economic activity (NPF4 Policy 29 Rural Development). 
Formal Dispute: No 
Support noted in relation to other
comments and preference for an
iLHLR which exceeds the MATHLR.
Savills on behalf of
Scone Estate
Disagree  List of Evidence/Datasets: 
The Scottish Land Commission Research on rural housing
should be taken cognisance of. 
Summary of Implications for Proposed Plan (PP): No
comments 
Further Comments: 
The Scottish Land Commission
Research has been included in the
summary of evidence. 
1. Noted that the respondent
supports an iLHLR which
exceeds the MATHLR. Disagree,
however, that the number

Page 51

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
1. PKC is predominantly rural, and work should be done to
increase the resilience of settlements via innovative
means to deliver critical Local Living focused services
instead of a slavish adherence to 20-minute
neighbourhoods and blanket restrictions on development
based on current services and not growth potential. The
facilitatory role that housing delivery can provide in
assisting PKC achieve other Spatial Strategy aims should
be recognised, not just in helping deliver affordable
housing but also in other areas such as biodiversity
enhancement, green infrastructure and active travel
provision. Acknowledge that the Council has a generous
MATHLR, but support Option 2 because the greater the
choice and variety in housing sites the better. The Council
should be confident in exceeding the MATHLR set and
push for housing sites to help the Council achieve
multiple benefits, ultimately the number is arbitrary. It is
securing quality in delivery that is key and that can be
controlled via a collaborative approach with all
stakeholders in relation to housing and associated
multiple-benefit delivery. 
2. The evidence outlined towards self-build and custom-
built need is flawed as it appears to rely on historic
consents but makes no mention of pre-application
enquiries or refusals of small sites. Buildstore data has
shown large numbers of parties who desire self-build
plots in the PH1 postcode. 
3. If some allocated sites are found to be undeliverable then
the scale of the supply goes down. There should therefore
should be considered arbitrary.
NPF policy 17 requires LDPs to
set out tailored approaches to
rural housing and where
relevant include proposals for
future population growth
including provision for small
scale housing. Plans are to
reflect locally appropriate
delivery approaches. Whilst it is
relevant to take account of
other benefits that new
housing development can
bring, it is considered that this
is most appropriately done
through the site assessment
and allocation process. As
discussed in the Summary of
Evidence section, no decision
has been taken as yet as to the
size of site which will be
allocated in LDP3. Furthermore,
NPF policy 16f) is very clear on
the circumstances under which
unallocated sites should be
supported. 
2. The limitations of relying on
past completions as an
indicator of demand is
acknowledged. More informed

Page 52

Respondent Agree or
Dispute
Summary of Comments PKC’s Response
be acknowledgement that there might be additional need
to that previously accounted for and this should have
greater security of delivery in the relevant LDP pipeline
because greater information is now required to ensure
deliverability than in previous LDPs (for example the
infrastructure first approach). 
4. Need for flexibility on rural housing because there is no
one-size fits all approach. The Council should not rely on
the NPF4 rural homes policy alone as this has some
significant omissions in routes to rural homes delivery. A
balanced approach to use of NPF4 policies is essential to
ensure appropriate and increased delivery of rural
housing. One key area would be allowing limited market
housing to encourage affordable housing delivery
alongside in the Council's Housing in the Countryside
policy and on the edge of settlements. 
Formal Dispute: Savills on behalf of Scone Estate wish to
formally dispute this issue on the following grounds: 
a) Data to be used to reflect Self and custom build
demand/need
b) A lack of acknowledgement of the facilitatory role of
housing in meeting other spatial strategy aims
c) The need for a balanced approach to use of NPF4
policies to ensure appropriate and increased delivery
of rural housing. 
evidence on demand for self
and custom build has been
sourced and included in the
Evidence Report. 
3. Comments have helped inform
the Summary of Implications
for the Proposed Plan section
of the Evidence Report. 
4. Comments have helped inform
the Summary of Implications
for the Proposed Plan section
of the Evidence Report. 
Conclusion on dispute:
The grounds of dispute a) and c)
have been addressed and / or
incorporated into the Evidence
Report. These disputes are
therefore considered resolved.
Regarding dispute b), the Council
considers the NPF housing policies
are clear on the circumstances
under which unallocated housing
sites should be supported. This
dispute therefore remains
unresolved. 
Savills on behalf of
Dupplin Estate
Neither List of Evidence/Datasets and summary of Implications for
Proposed Plan (PP): No comments
Response is as point 1 of the Savills
on behalf of Scone Estate response

Page 53

Respondent Agree or
Dispute
Summary of Comments PKC’s Response 
Further Comments: 
Through the Perth Sustainability Park, there is an opportunity
for a development of high quality homes following the
principles of Building with Nature. 
The Evidence Report and future LDP must recognise the
facilitatory role that housing delivery plays in assisting PKC
achieve other Spatial Strategy aims. It is a common theme
that market value housing helps deliver affordable housing
for example, but this model can be applied to other areas
such as biodiversity enhancement, green infrastructure and
active travel provision etc. PKC should work with landowners
and housebuilders to maximise housing delivery and the
multiple benefits housing can bring. If the Council are clear
on this approach, then they should be confident in exceeding
the MATHLR set and pursuing these multiple benefits across
the region via a variety of approaches that delivery a variety
of housing. 
Acknowledge that the Council have a generous MATHLR, but
still support Option 2 because the greater the choice and
variety in housing sites the better for Perth and Kinross and
achieving the sustainable growth of the region which will sit
along the aims of the next Spatial Strategy. In short, Perth
and Kinross should push for housing sites to help the Council
achieve multiple benefits. Securing quality in delivery is key
and that can be controlled via a collaborative approach with
all stakeholders in relation to housing and associated
multiple benefits (active travel, services etc.) to ensure
successful places are created in the currency of LDP3.
above. This respondent has not
raised a formal dispute, but the
issue is highlighted for
consideration by the Reporter by
the preceding respondent in any
event.

Page 54

Respondent Agree or
Dispute
Summary of Comments PKC’s Response 
Formal Dispute: No 
Ristol Consulting Disagree, but
does not wish to
register as
formal dispute
List of Evidence/Datasets: No comments 
Summary of Implications for Proposed Plan (PP): 
If green belt policy is continued into the review LDP, please
explore the application of housing in the countryside policy
particularly for the criteria of building groups and infill. The
contribution these criteria make to local, rural housing is
invaluable whilst the adverse impact on the intent and
outcome is negligible and can be assessed through wider non
green belt policies on amenity and environment. 
Would welcome exploring a policy framework to accelerate
the delivery of affordable, sustainable homes in rural areas
consistent with the intent and outcome of NPF policies 16, 17
and 18. Of note are the well documented housing challenges
facing Dunkeld & Birnam and the necessity for new
allocation(s) to meet local need. 
Formal Dispute: No 
Comments in relation to the green
belt and housing in the countryside
are considered under the Green
Belt section. 
Remaining comments have helped
inform the Summary of
Implications for the Proposed Plan
section of the Evidence Report.

Page 55

Meeting the requirements of the Act:
The Act sets out a number of requirements relating to housing which local
authorities have to set out in the preparation of their Evidence Report. 
The Housing Needs of the Population of the Area
Part 2, Section 16B(3) and Section 15(5)(ca) of the Planning Act 2019
requires planning authorities, in the preparation of their Evidence Report,
to set out their views on the housing needs of the population of the area
(including, in particular, the needs of persons undertaking further and
higher education, older people, and disabled people).   
With respect to the Perth and Kinross Area, the HNDA calculation
combines the components of housing need to create a 20-year range of
housing estimates for Perth and Kinross as follows: 
• There is an estimated need for around 5,400 – 6,500 houses over
the 20-year period of the HNDA
• Approximately 1,500 households may require housing for older
people
• Up to 3,200 households may require a more accessible form of
housing, 640 households may require wheelchair accessible
housing
• There is a backlog demand of 50 students in education requiring
accommodation 
The Availability of Land for Housing
Part 2, Section 16B(3) and Section 15(5)(cb) of the Planning Act 2019
requires planning authorities, in the preparation of their Evidence Report,
to set out their views on the availability of land in the district for housing,
including for older people, and disabled people.   
With respect to the Perth and Kinross Area there is an agreed land supply
for housing of nearly 17,000 units. This means that, in very simplistic
terms, there is enough non-constrained housing land to last nearly 20
years at a build rate of 850 units per year (the annualised MATHLR). This is
almost double the 10-year LDP period. It is acknowledged, however, that
this is not a straightforward calculation and that ultimately it is the
bringing forward for development of that non-constrained land supply
which results in the end delivery of houses on the ground. 
Construction and Adaptation of Housing
Part 2, Section 16B(3)(b)(i) and (ii) of the Planning Act 2019 requires
planning authorities, in the preparation of their Evidence Report, to
provide a summary of the action taken by them to support and promote
the construction and adaptation of housing to meet the housing needs of
older people and disabled people in their area, and an analysis of the
extent to which the action has helped to meet those needs.   
With respect to the Perth and Kinross Area the LHS and SHIP are the
primary vehicles for the delivery of housing for specific groups which
require affordable housing. The LHS Annual Progress Report discussed in
the summary of evidence section sets out the achievements so far in
relation to meeting the needs for affordable housing generally, and of
older people and disabled people in Perth and Kinross specifically. As
identified in the SHIP, the Council is committed to increasing the supply of
wheelchair accessible housing and is aiming for 10% of homes built to be
suitable for people with particular needs where this can be met within
affordable housing development sites. 
Existing LDP2 Policy 22: Particular Needs Housing Accommodation
supports proposals for residential developments supporting housing for
particular needs such as housing for frail or elderly people, people with
additional support needs, and housing for varying needs. Houses in

Page 56

multiple occupation are also supported where a need for such
accommodation can be demonstrated. 
In relation to the backlog demand of 50 students in education requiring
accommodation, the Draft Perth City Centre Development and Design
Framework identifies the ‘University Quarter’ as one of the proposed
investment areas for the city. It refers to a new vision for the University
Campus ‘Quarter’ which is to provide a new framework which will deliver a
new educational facility for primary / secondary / further and higher
education in one campus location. This will be developed alongside other
ancillary uses, but no reference is made to providing more student
accommodation on site. Planning permission was granted in 2019 to
convert and extend an existing retail unit in the city centre to student
accommodation comprising 47 bedrooms, 30 studios and associated
communal facilities but the permission has not been implemented. Further
discussion will therefore be needed with the College to understand any
outstanding accommodation requirements. 
Policy 25: Housing Mix requires that the market element of all sites with a
total capacity of 20 or more provide an appropriate mix of house types and
sizes and meet the needs of smaller households including older people and
lower income households by providing at least 10% of their units as one or
two bedroom homes. This is in addition to any affordable housing
requirements on the site. Furthermore, ‘where there are identified clusters
of households with specific housing needs within the settlement, such as
housing for wheelchair users, there may be a requirement for up to 10% of
the development to be designed to meet these specific identified needs or
for the developer to demonstrate that the house is capable of adaptation’.
There were no specific site allocations for housing for older people or
disabled people in LDP2. 
These policies have been used in assessing planning applications since the
adoption of LDP2. Policy 22 in particular has helped facilitate the
development of a residential assisted living scheme for over 55s, a change
in house type to allow for a specialist need bungalow to be provided on a
larger scheme, assisted living units, and a 10 unit HMO aimed at providing
student accommodation. 
Accommodation Needs for Gypsies and Travellers
Part 2, Section 16B(3)(b)(i) and (ii) of the Planning Act 2019 requires
planning authorities, in the preparation of their Evidence Report, to
provide a summary of the action taken by them to meet the
accommodation needs of Gypsies and Travellers in their area, and an
analysis of the extent to which the action has helped to meet those needs.   
With respect to the Perth and Kinross Area LDP Policy 21: Gypsy /
Travellers’ Sites protects existing authorised sites with a presumption
against their conversion to another use. The policy also supports proposals
for new permanent sites and temporary short stay sites and sets out the
criteria against which such proposals will be assessed. There were no
specific site allocations for new Gypsy / Travellers’ sites in LDP2, although
the settlement boundary of Greenacres private site was drawn to allow for
expansion. Only a small number of planning applications have been
submitted relating to Policy 21 during the lifetime of the Plan. Most
notably permission was granted for replacement chalets on an existing
Gypsy / Travellers site, and permission refused for an extension to another
small existing Gypsy / Traveller site on health and safety grounds. 
The LHS Annual Progress Report discussed in the summary of evidence
section sets out the achievements so far in relation to meeting the
accommodation needs of Gypsies and Travellers in Perth and Kinross. Also,
as abovementioned the HNDA data relating to Gypsy / Traveller needs
dates from 2016. The 2016 report indicated a need to explore provision of
transit sites. As a result, the Council has committed funding to and is
currently progressing a 10 pitch transit site in Perth. Although there are no
plans in the current SHIP for affordable homes for Gypsy / Travellers, work

Page 57

is progressing to establish the unmet needs of transient Gypsy / Travellers,
and working with community members to have a better understanding of
their accommodation needs and preferences is identified as an action in
LHS. Further detail on this is set out in the Gaps or Uncertainties in Data
section.