Appendix E - Productive Places
Perth and Kinross Council · 5 March 2025
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Perth and Kinross LDP3 2027 Draft Evidence Report Appendix E Productive Places March 2025
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Issue: Community wealth building Corresponding NPF4 Policy/Policies: • National Planning Framework 4, Policy 25: Community wealth building • Other key NPF4 policy connections - 9: Brownfield, vacant and derelict land and empty buildings; 15: Local living and 20 minute neighbourhoods; and 26: Business and industry. Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 030: Community wealth building https://consult.pkc.gov.uk/communities/copy-of- topicpapers2/supporting_documents/TP025%20Community%20wealth%2 0building.pdf Information required by the Act and NPF4 regarding the topic: Section 15(5) of The Town and Country Planning (Scotland) Act 1997, as amended: • The principal cultural, social, and built heritage characteristics of the district NPF4 Policy 25 expects Local Development Plans to ‘…align with any strategy for community wealth building in the area. Spatial strategies should address community wealth building priorities; identify community assets; set out opportunities to tackle economic disadvantage and inequality; and seek to provide benefit for local communities.’ The policy intent for Policy 25 is noted as: • To encourage, promote and facilitate a new strategic approach to economic development that also provides a practical model for building a wellbeing economy at local, regional and national levels The policy outcomes for Policy 25 are: • Local economic development that focuses on community and place benefits as a central and primary consideration – to support local employment and supply chains • Support community ownership and management of buildings and land The Scottish Government’s Local Development Plan Guidance (May 2023) under it’s ‘Step by step guide’ provides advice on relevant evidence for the NPF4 policy topics to help planning authorities in considering the national planning policies when preparing their Evidence Report. With respect to NPF4 Policy 25, the Guidance advises that alignment of Local Development Plans with strategies for community wealth building for the area can support a place-based approach to economic development. It suggests that this will be achieved through working in partnership with communities and businesses to build a strong resilient local economy. The approach to the spatial strategy may include prioritising use of brownfield, vacant and derelict land and empty buildings and directing development to existing centres to support sustainable communities. Links to Evidence: Register of community asset transfers
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Perth and Kinross Community Plan: Local Outcomes Improvement Plan 2022 to 2032 Eastern Perthshire Local Action Plan Highland and Strathtay Local Action Plan Kinross-shire, Almond and Earn Local Action Plan Strathearn and Strathallan Local Action Plan Perth City Local Action Plan Summary of Evidence: Perth and Kinross Community Plan The Perth and Kinross Community Plan (local outcomes improvement plan) 2022-32 was approved by the Community Planning Partnership in 2022 and sets out a strategy for dealing with socio-economic inequality in Perth and Kinross. The plan’s strategic priorities are: • reducing poverty • physical and mental wellbeing • digital participation • learning and development • employability Employability, skills, learning and development are the fundamental priorities for sustainable growth in Perth and Kinross. These priorities will be relevant to consider in the preparation of the Proposed Plan. The Perth and Kinross Community plan sets out what the Community Planning Partnership will do to build on the skills and commitment that already exists in the communities in Perth and Kinross. The Plan contains a number of area-wide actions based on its strategic priorities, and it also identifies two localities in Coupar Angus and Crieff South where an accelerated approach would be required. In delivering its outcomes, the Community Planning Partnership aims to improve community participation and co-production of services; continue the movement to locality partnership working; improve data sharing; and review strategic risk to ensure delivery stays on track. The Perth and Kinross Community plan is currently under review to include delivery structures that the Community Planning Partnership can use to take forward the plan’s actions. Local Action Partnerships The Perth and Kinross area is divided into seven Community Planning Partnership localities, each of which is supported by a Locality Action Plan (some are jointly with another locality area). There are five Locality Action Plans: • Eastern Perthshire • Highland and Strathtay • Kinross-shire, Almond and Earn • Strathearn and Strathallan • Perth City
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The Locality Action Plans play a role in distributing the Council’s Community Investment Fund. Community Asset Transfer Community Asset Transfer allows community groups to request ownership, leasing or access rights for Council-owned property as well as property owned by other public bodies. An annual report sets out the number of community asset transfer requests and participation requests received by the Council, together with our response to such requests. Between April 2022 and March 2023 there were 26 community organisations that showed interest in the community asset transfer process. Not all of these progressed further but the information in the Council’s annual reports on community asset transfer will be used in support of NPF4 policy outcomes in relation to community wealth building. For groups interested in exploring asset transfer, the Council has a Community Empowerment Officer available to offer support and help navigate the process, including provision of feedback on expressions of interest, and support preparing an application. There is an online toolkit to help community groups prepare a request, and a list of assets currently owned by the Council. The criteria for assessment of community asset transfer requests are published on our website and this includes documentation for all previous transfer requests that have reached the assessment stage. Summary of Implications for the Proposed Plan: The Proposed Plan will need to look at ways in which it can facilitate a community wealth building approach in the area. The extent to which the Proposed Plan should support or compel local community wealth building initiatives is something that will need to be considered, taking into account deliverability issues. For example, highlighting the points raised in Homes for Scotland’s response to the Topic Paper around whether local housebuilders are sufficiently resourced to follow procurement processes that align with local employment and training opportunities or whether existing arrangements are sufficient. The Proposed Plan will also need to have regard to the Council’s asset register and particularly whether there have been any community asset transfer requests. The call for ideas and sites stage of the Proposed Plan will need to assess the potential for community wealth building as one of a number of factors taken into account as part of the process for identifying, assessing and selecting sites for development proposals. Gaps, Uncertainties or Key Issues Raised: The Proposed Plan will need to take account of any updates that may be made to the Perth and Kinross Community Plan (Local Outcomes Improvement Plan) and the Locality Action Plans. These will need to be embedded into the Proposed Plan. It will also need to consider the contents of any registered Local Place Plans, and whether they have implications for community wealth building in the area because there is a link between community asset transfer opportunities and Local Place Plans.
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Summary of Stakeholder Engagement: Big Place Conversation The Council carried out its ‘Big Place Conversation’ exercise to kick start the LDP3 process across Perth and Kinross communities during most of 2023. This was a substantial exercise involving over 100 events throughout the Council area. The events ranged from drop-in information sessions, meetings, and online surveys to workshops and online sessions using the Place Standard Tool to capture the views of local communities about different aspects of their places. The results of the BPC are summarised as part of a separate report on the outcomes and findings across the different locality areas. LDP3 Evidence Report Topic Papers The Council produced a series of LDP3 Evidence Report Topic Papers, covering the individual subject matters of NPF4’s suite of national planning policies. These papers, which set out the detailed evidence the Council has gathered to help produce our Evidence Report and which we hope to use to help prepare our Proposed Plan, were published on the Council’s Consultation Hub and open for comments for a period of 6 week during July and August 2024. As part of our consultation process for LDP3 Topic Papers we welcomed the views of our key stakeholders (who were contacted specifically via email regarding the consultation exercise) and the public at large, on the sufficiency of the evidence gathered, our interpretation of the implications of that evidence to the Proposed Plan, and on how we intend to use that evidence to develop our LDP3. We also asked respondents to provide links to other sources of available information or data which they felt we had not included, alongside an explanation of why they considered any additional sources of information to be relevant to the preparation of the LDP. Statements of Agreement/ Dispute Five responses were received on our Community Wealth Building topic paper. The majority of respondents either agreed with or had no comment to make on the evidence identified through the topic paper, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. Homes for Scotland stated their disagreement with the implications for the Proposed Plan, but did not wish to register their comments as a formal dispute. Two planning consultants (Gray Planning & Development, and Savills) made constructive comments on issues for the Proposed Plan to consider. Earn Community Council recommended that the outcomes of the Big Place Conversation should inform the Proposed Plan’s consideration of community wealth building; and that the Local Action Plans require updating. A summary of these comments, their status, and the Council’s response are provided in the table below. There were no formal disputes.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Historic Environment Scotland Agree List of Evidence/Datasets: Agree Summary of Implications for the Proposed Plan: Agree Further Comments: N/A Formal Dispute: No Noted, no response necessary Homes for Scotland Disagree, but does not wish to register as a formal dispute List of Evidence/Datasets: Agree Summary of Implications for the Proposed Plan: Disagree Further Comments: Each home builder is structured differently. Some will have direct labour with little opportunity for direct local employment opportunities whilst others will utilise sub-contractors tendering for work or being approached directly. Residential developments, even in the short-term, will generate indirect local employment through use of local services, such as retail provision. Some companies will have existing procurement arrangements and suppliers, especially if part of a larger company. Where this is not the case developers may go out to tender or approach local companies directly. It is, however, important to understand that local businesses may not have sufficient resources and/or output to meet the requirements of major housing developments and the development should not be unduly delayed at a time of a national Housing Emergency through delays in the local supply chain. Formal Dispute: No The respondent’s comments are noted, and it is agreed that different organisations will have different approaches in respect of the policy outcomes of NPF4 Policy 25 Community wealth building. However, community wealth building is an important part of the Development Plan so would always be taken into consideration when making planning decisions. The Council’s view would be that community wealth building is just as important during times of national housing emergency and its consideration as part of the development plan could deliver better outcomes.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Gray Planning & Development (Town Planning Consultants) Neither agree nor disagree List of Evidence/Datasets: Neither agree nor disagree Summary of Implications for the Proposed Plan: Neither agree nor disagree Further Comments: It would be useful if the main sectors or areas of economic growth in PKC and future trends and expectations are part of the evidence base. Also what is the effect or implications of the Tay Cities Deal on PKC relationship with other areas such as Dundee, North Fife, Angus for community wealth building? Formal Dispute: No These points are addressed under the issue of Business and Industry Earn Community Council Agree List of Evidence/Datasets: Agree Summary of Implications for the Proposed Plan: Agree Further Comments: This is one of the most relevant Topics to CC members where the outcomes of Big Place Conversation would have been beneficial. 2017 Local Action Plans require updating. Brundtland-report – Our Common Future –Definition - sustainable-development – “Sustainable development’ – “is development that meets the needs of the present without compromising the ability of future generations to meet their own needs” - A definition worthy of consideration & application in developing LDP3. Formal Dispute: No The Council agrees that community wealth building is of interest and is relevant to Community Councils, and the outcomes of the Big Place Conversation will be used to inform the Proposed Plan. Consideration will be given to updating Local Action Plans. The Proposed Plan will be required to consider the application of Sustainable Development principles. The principles of Sustainable Development are already embedded into the spatial principles of NPF4.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Savills on behalf of Scone Estate Neither agree nor disagree List of Evidence/Datasets: Neither agree nor disagree Summary of Implications for the Proposed Plan: Neither agree nor disagree Further Comments: There is the potential that renewables developers and/or landowners may be able to bolster the Community Investment Fund or set-up accompanying funds to help tackle the Council's Corporate Plan and/or help alleviate poverty etc. Formal Dispute: No The respondent’s comments are noted, and it is agreed that the Community Investment Fund, or equivalent, may be appropriate to help achieve community wealth building
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Issue: Business and Industry Corresponding NPF4 policies: • National Planning Framework 4 - Policy 26 Business and Industry • Other key NPF4 policy connections - Policy 20 Local Living and 20 minute neighbourhoods, Policy 25 Community wealth building, and Policy 29 Rural Development Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 026: Business and Industry (https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume nts/TP026_Business_and_Industry.pdf) Information required by the Act and NPF4 regarding the topic: In line with the requirement of the Act, section 15 (5) this paper will provide important background information for the Plan area regarding: • principal economic characteristics of the district and • principal purposes for which the land is used Additionally, under NPF4 Policy 26, NPF4 expects Local Development Plans to: • allocate sufficient land for business and industry, taking into account business and industry land audits, and current needs and market expectations • ensure that there is a suitable range of sites that meet current market demand, location, size, and quality in terms of accessibility and services. • allocate employment land taking account of local economic strategies and support broader objectives of delivering a low carbon and net zero economic recovery, and a fairer and more inclusive wellbeing economy. The Scottish Government’s Local Development Plan Guidance (May 2023) under it’s ‘Step by step guide’ provides advice on relevant evidence for the NPF4 policy topics to help planning authorities in considering the national planning policies when preparing their Evidence Report. With respect to NPF4 Policy 26, the Guidance advises that planning authorities are also expected to: • consider business and industry land audits • consider future risks arising from climate change when identifying major development sites and significant business clusters • support broader objectives of delivering a low carbon and net zero economic recovery, and fairer and more inclusive wellbeing economy • potentially identify appropriate locations for significant business clusters, taking into account the priorities of the NSET. This could include sites identified in Enterprise Areas, business parks, science parks, large and medium sized industrial sites and high amenity sites • assess all sites under consideration for allocation for their ability to meet current needs and market expectations. Flexibility and resilience for business and industry should be built into site allocation.
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• identify where existing business sites are underused, for example where there has been an increase in vacancy rates, and where reallocation to enable a wider range of viable businesses or alternative uses may be considered, taking careful account of the potential impacts on existing businesses on the site • potentially refer to analysis of employment need, local poverty, disadvantage and inequality, to identify where future business and industry development may provide most benefit • encourage, including by use of the spatial strategy and site allocations opportunities for home-working, live-work units, micro businesses, and community hubs. National Planning Framework 4 further supports Scotland’s move towards a wellbeing economy. It sets out the Scottish Government’s vision for measuring progress towards economic growth that is both sustainable and inclusive, using an outcomes-based approach. The Framework sets out 11 different outcomes and progress towards them is assessed using 81 indicators to give a measure of wellbeing that includes a broad range of social, cultural, and environmental factors as well as economic considerations. The supply/demand for employment land can contribute to several of the outcomes associated with ‘Economy’ and ‘Fair Work and Business’. These outcomes seek to ensure that the country’s businesses can thrive and that local, and national, economies are sustainable in the long term. Correspondingly it also contributes towards achieving the reduction of poverty through providing more opportunities within deprived areas. Local living and 20-minute neighbourhoods are referred to in Policy 15 in order to encourage the application of the Place Principle and create connected and compact neighbourhoods where people can meet the majority of their daily needs within a reasonable walking distance of their homes, preferably by walking, wheeling or cycling or using sustainable transport options. Local access to employment is part of this concept Links to Evidence: National economic strategies/analysis • Levelling Up the United Kingdom • Scotland's National Strategy for Economic Transformation • Scottish Index of Multiple Deprivation • Scottish Vacant and Derelict Land Survey 2023 • Town and Country Planning (Masterplan Consent Areas) (Scotland) Regulations 2024 which came into force on 5 December 2024 Regional economic strategies • Tay Cities Region Economic Strategy 2019-2039 • Tay Cities region deal Local economic/place strategies • Perth and Kinross Economic Wellbeing Plan 2020-2028 • Draff City Centre Design and Development Framework • Perth City Plan 3: Perth 2040 our agenda for change
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Local analysis • Employment land audit 2022 (The 2024 audit not available for the Evidence Report stage) • 20-minute neighbourhood and local living analysis and settlement audit work (will be prepared prior to preparation of Proposed Plan) • An urban capacity and brownfield study (will be completed prior to preparation of Proposed Plan) • Perth and Kinross Council Employment land matrices (Core Doc Ref: CD37) • LDP2 categorisation of two types of employment land, core and general (review may be completed prior to preparation of Proposed Plan, if these two categories are continued in LDP3 policy) • Perth and Kinross Council Employment Land & Property Market Analysis December 2022 • Big Place conversation summary report Summary of Evidence: Principal economic characteristics of the area Employment land audit 2022 (ELA) provides information on the supply and availability of employment land for business and industrial use within the Perth and Kinross Council area. The Perth & Kinross Employment Land Audit is produced annually to provide up to date and accurate information on the supply and availability of employment land for business and industrial use within the Council area. It was prepared from information provided in the LDP and through the monitoring of planning application approvals. The audit provides information on the following: Total Available Employment Land: This includes land that has been zoned for business, industrial and general employment use in the adopted LDP and windfall sites which have current planning permission for use classes 4, 5 and 6 of the Town and Country Planning (Use Classes) (Scotland) Order 1997. Marketable Land: can also be referred to as the effective land supply Major Constrained Land: is with significant constraints which can affect the immediate availability of the site Minor Constrained Land: with minor constraints Immediately Available land: with no known constraints Take up: which is the calculation of employment sites/ or part area thereof which has been completely developed Serviced employment land: which has road infrastructure up to the edge of the individual plot with the other services provided adjacent to the overall site (electricity connection, water supply connection, foul drainage connection, gas connection and telecommunication connection). The total area of identified Employment Land is 292.72 Hectares. The total area of effective land (Immediately available + marketable) is 290.32 hectares, and 36.94 Hectares of land is identified as serviced. Of the total area of identified employment land, 84% is constrained by minor factors including physical, amenity and ownership constraints. There was no 2023 audit, but it is not anticipated that there will be significant change to the marketable employment land when the 2024
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Employment land Audit is prepared. This 2024 audit will not be available for the Evidence Report stage, but it will provide baseline information on the supply and availability of employment land for business and industrial uses within the Perth and Kinross Council area for the preparation of the Proposed Plan. Ryden were appointed by Perth & Kinross Council to provide analysis of its employment land and property market (Perth and Kinross Council Employment Land & Property Market Analysis December 2022). Employment land and property are defined as being suitable for any use within, or ancillary to, those specified in Use Classes 4, 5 or 6 of the Town and Country Planning (Use Classes) (Scotland) Order 1997. Relevant to this section, the objectives of this study were to provide a market analysis of the current and future employment land and property market including Perth & Kinross LDP2 employment allocations, and the Council Commercial portfolio, considering: • Past - analysing the market supply both property and land, the take up of land, and the demand • Present - how the market is functioning including private sector investment and viability, and quality of existing property and land supply Relevant to this section, this report provides: • An overview of the Scottish market and comparisons to Perth & Kinross. • A competitive analysis of the Perth & Kinross offers with respect to other competing local authorities. Perth & Kinross has above average levels of employment in accommodation and food services, agriculture, forestry and fishing and mining, quarrying and utilities reflecting its attractiveness from a tourism perspective and its traditional employment base. These are not generally sectors which have a large employment land/property requirement (in terms of planning use classes). Perth & Kinross has below average levels of employment in health, business administration and support services, professional, scientific, and technical and information and communication. As such Perth & Kinross potentially has a lower overall employment land requirement than an ‘average’ Scottish local authority. The principal employment property locations in Perth & Kinross is the city of Perth itself in which Inveralmond Industrial Estate and North Muirton Industrial Estate are principal locations. There is also notable stock around Crieff, Blairgowrie, Kinross, Errol, and Aberfeldy with most of the smaller towns throughout the region having some industrial units. Take-up of employment land in Perth & Kinross over the last 8 years can be averaged at 2.1 ha per annum. Perth & Kinross has performed slightly better than Falkirk Council over the longer term however is outperformed by Dundee and Dumfries and Galloway. It is worth noting that both Dumfries & Galloway and Dundee achieved very high take up in 2016/17 at 32.93 ha and 22.51 ha respectively which has had a significant impact on their averages. There are presently eight employment sites being marketed in Perth & Kinross, totalling 32.72 acres (13.24 hectares). This includes sites at Arran Road and the Perth Food and Drink Park in North Muirton Industrial Estate, the former Travis Perkins’ site on Inveralmond Road (Inveralmond
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Industrial Estate), Pitheavlis (former Aviva training centre and hotel) and sites at Kinross West and Brioch Road in Crieff. This is an encouraging mix of developable plots although it does total less than 5% of allocated employment land. Key economic issues National context Levelling Up the United Kingdom, the UK Government published this White Paper early 2022, and its strategy seeks to ensure that more jobs are provided outside of London and opportunities are made available in all parts of the country. Businesses need to be attracted to invest in other areas of the country, similarly, job opportunities are to be created in areas where they have been lacking. As part of its vision to level up the country, the UK Government has also invested £1.5 billion since 2014 to City and Growth deals across Scotland. The White Paper notes the Tay Cities Deal operating in Perth & Kinross and the Community Renewal Fund covering the region which is delivering an employment and wellbeing programme. Scotland's National Strategy for Economic Transformation, published in March 2022, sets out a ten-year strategy, and provides a set of key priorities and actions with a vision of achieving a wellbeing economy that is prosperous for all the country’s people and places. One aspect of the strategy’s vision is for Scotland to be ‘the best place to start and grow a business’. A key issue highlighted by the strategy is that Scotland falls behind other countries in terms of its productivity. It notes that there are too few businesses scaling up or starting and that limited access to infrastructure is a factor in this problem. Each of the priorities and proposals identified in the Scottish National Strategy for Economic Transformation is a national objective and all have implications for Perth & Kinross. With a key focus of the strategy being on inclusive growth across the country, it is evident that Perth & Kinross requires economic growth and investment in high productivity sectors to raise local and national productivity rates. Having adequate supply of employment land and property is a factor in enabling this vision within Perth & Kinross and supporting business growth. In relation to the productivity challenge facing the national economy, the strategy also notes low national levels of research and development (R&D) activity. Again, as this is a national problem it is also likely to apply in Perth & Kinross. Data collected by the Scottish Government on Business Research and Development (BERD) shows that in 2020, businesses in Perth & Kinross spent just under £6 million on R&D, accounting for 0.4% of the total spend in Scotland during the year. The data also shows that R&D investment by businesses in Perth & Kinross peaked at £10.6m in 2014 but has since struggled to replicate this level. Even at this peak level, R&D expenditure by Perth & Kinross businesses as a proportion of total Scottish R&D expenditure was still just 1.1%. Perth & Kinross has 3% of Scotland’s population but 1% of R&D expenditure. In terms of planning’s role in helping to provide the foundation for growth, R&D investment in Perth & Kinross in excess of historic trends will require premises in locations that are suitable for businesses to conduct R&D. Scottish Index of Multiple Deprivation has some limitations to its use within Perth and Kinross. The SIMD Data zones in rural areas tend to cover a large land area and reflect a more mixed picture of people experiencing different levels of deprivation. The SIMD is less helpful at identifying the
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smaller pockets of deprivation found in more rural areas, compared to the larger pockets found in urban areas. Town and Country Planning (Masterplan Consent Areas) (Scotland) Regulations 2024 came into force on 5 December 2024. Schedule 5A Paragraph 5 is already in force and requires planning authorities to consider whether it would be desirable to make a scheme for a part or parts of their district, and to publish a statement as to their consideration of that, by 25 July 2024. Council Officers have held initial discussions with Binn Ecopark about the potential to take forward a Masterplan Consent Area for Binn Ecopark, Glenfarg and we intend to check whether opportunities exist elsewhere to take forward Masterplan Consent Areas. PKC intend to progress this further once the legal provisions for making Masterplan Consent Areas are in force. The Scottish Government has indicated that Masterplan Consent Areas could be used to support delivery of the local development plan. PKC will consider whether it would be desirable to make any Masterplan Consent Areas as part of our work on delivery linked to the Local Development Plan's Delivery Programme. This work is currently relevant to the existing LDP, and will in time become relevant to the delivery of the new LDP. Perth and Kinross context Perth and Kinross Economic Wellbeing Plan 2020-2028 was co-produced in the spring of 2021 by a Taskforce set up to help economic recovery because of the impact of Covid-19. The Economic Taskforce continues to monitor progress and to review the economic impact of the pandemic. The Plan names 73 actions under 3 broad headings of People (17 actions), Business (27 actions) and Place (29 actions). Those actions of direct relevance to employment property and land are: • Provide business support and micro-grants to micro businesses to support start-up or expansion costs. • Support the Circular Economy/Waste hub at Binn Eco-Park and across Perth & Kinross around Project Beacon (plastics recycling -Tay Cities Deal funded project) and attract £10m private investment. • Support Food and Drink / agriculture /bio-economy innovation. • Support an Engineering Innovation hub at Perth College/UHI linking to Aviation Academy/Tayside Engineering Partnership projects (Tay Cities Deal funded projects). • Examine options to set-up a revolving fund financing upfront infrastructure to open up new housing and mixed-use sites (including traditional developer contributions, joint ventures, or acquisition of land) in return for investment focused on Perth city and rural sites which are key to the delivery of the Local Development Plan (LDP) strategy. • Deliver Perth Eco Innovation Park linking to Perth Innovation Highway/Mobility Hub (Tay Cities Deal funded projects) 2020-2030. • Promote and support property adaptation and vacant site development. • Perth Transport Futures Phase 2 (Cross Tay Link Road / Destiny Bridge) as new major road infrastructure to support the growth of Perth and the future development of housing and employment areas.
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This strategy is undergoing a refresh, will be titled Perth and Kinross Economic Action Plan, and will be available by end of 2024, in time to inform the Proposed Plan Tay Cities region deal was signed in December 2020. In relation to Perth & Kinross property investment, there is funding allocated towards: • Two plant science centres at the James Hutton Institute in Invergowrie • Project Beacon’s new concept Advanced Plastics Recycling Facility (A-PRF) which enables ‘all plastic’ collections Other property investment, which is cultural and tourism related, is allocated towards: • Perth Museum which opened Spring 2024 • Pitlochry Festival theatre which is being supported to develop indoor and outdoor spaces to improve accessibility, sustainability, and experience • Aero Space Kinross to provide the foundation of a funding structure to construct a uniquely themed Aviation, Astronomy and Space Flight Science Centre • Crieff International Highland Centre, a new, purpose-built Centre it will be the first of its kind in Scotland, it aims to become a world base for Highland sports, dance, and music and to maintain and grow these essential elements of Scottish Highland culture • Library of Innerpeffray investment to help secure its long-term future by upgrading its education and visitor facilities Infrastructure wise the Deal also allocated funding towards: • Perth Innovation Highway a 5-mile smart technologies corridor linking Perth Eco Innovation Park at Perth West, a 25 hectares area of employment land with Perth City Centre • High-speed broadband access in rural Perth & Kinross • The Perth Transport Futures Phase 2 (Cross Tay Link Road / Destiny Bridge) which will provide new major road infrastructure to support the growth of Perth and the future development employment areas • A Low Carbon Transport and Active Travel Programme including the development of a low carbon transport hub at Broxden Park and Ride in Perth, active travel network across Perth and a hydrogen refuelling station at Perth West. This will help make this core employment location more sustainable. • A Perth Active Travel Hub in the city centre to transform a bus interchange • Perth Bus & Rail Interchange to support the redevelopment of Perth’s Bus and Railway Stations, improving connectivity between them and the city centre The Deal also supports a series of regional programmes which would also benefit Perth & Kinross as follows: • Improving skills and supporting key growth sectors such as Clean Growth • Support for engineering via Aviation academy and Tayside Engineering Partnership projects
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Ryden were appointed by Perth & Kinross Council to provide analysis of its employment land and property market (Perth and Kinross Council Employment Land & Property Market Analysis December 2022). This employment land and property market analysis will inform and underpin the development of the new Local Development Plan 3 (LDP3), the review of Perth & Kinross Council’s Investment Property Strategy, its Commercial land and property portfolio, and Commercial Property Investment Programme. The Council supplied Ryden with its employment land assessment matrices for 41 currently allocated sites. Ryden provided a summary assessment relating to these sites for the Perth area, Strathearn, Kinross, Highland, and Strathmore & Glens. The Council’s employment land matrices (Core Doc Ref CD37) utilise a ‘balanced scorecard’ approach to determine the sites most likely to require intervention. This considers marketability, any evidence of market failure, planning constraints, potential demand, and consideration of the site against strategic priorities. In rural areas income deprivation is dispersed, and nine out of ten people who are income deprived do not live in the 20% most deprived areas. Rural areas are defined by Scottish Government as being places with population less than 3,000, and Perth and Kinross has a rural population of 45.9%. This means the SIMD has significant limitations for identifying deprivation within nearly half of the population of Perth and Kinross. SIMD data indicates that only settlements of Perth and Blairgowrie and Rattray have areas within the most deprived quintile (20%), and maps 1 and 2 show areas involved. Figure 1 Blairgowrie SIMD (which shows some areas in Rattray within the most deprived 20% in purple)
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Figure 2 Perth SIMD (which shows some areas within Fairfield/Tulloch, Muirton, Letham and City Centre within the most deprived 20% in purple) 20-minute neighbourhood and local living analysis and settlement audit work will be carried out to support the preparation of the Proposed Plan. This analysis will inform the spatial strategy and may identify additional priority places where we should try to identify employment land opportunities if possible. It is planned as part of the Settlement Audit work for the Proposed Plan to develop a Localities Profile template which will set out those factors which officers need to take account of in developing their understanding of each place and its needs to satisfy the requirements of the Planning Act, Regulations, LDP Guidance and NPF4 policies. Scottish Vacant and Derelict Land Survey 2023 will also be a valuable information resource and having an up to date and accurate record of vacant and derelict land within the area, helps identify the scale of the problem and any issues relating specifically to Perth and Kinross which may require a local policy response in LDP3. It will also assist in the identification of potential development sites for the Proposed Plan. It is important, however, to note that not all brownfield land and vacant buildings will be included within the SVDLS. For further information on SVDLS sites in Perth and Kinross Area please refer to the Brownfield, Vacant and Derelict land, and Empty Buildings Issue Appendix A7. An urban capacity and brownfield study will target the development of brownfield sites through the preparation of a brownfield register of potential development sites and vacant properties. A pilot exercise has so far been undertaken for a specific area of Perth and Kinross which considered vacant and derelict land, vacant properties, community land audit, car parks, underutilised open space, land in council ownership, land allocated for employment safeguarding in LDP2, land allocated in LDP2 and the housing land audit but not yet fulfilled, and officer identified sites. The main purpose is to identify sites for affordable housing, including small sites that could be brought forward for development immediately or considered for the longer term via the LDP review process. An initial assessment identified those sites which could be immediately discounted, for example, those which would not comply with planning policy for housing. A full sites assessment was then carried out on the remaining sites, and these were then scored to identify:
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• green sites with few constraints and the potential for delivery in 1-2 years • amber sites with a small number of significant constrains (or a large number of small constraints) that make feasibility less uncertain and where further assessment is needed • red sites which have significant constraints, and which would need to be considered through the review of the LDP Partners, including development trusts are using the results of the pilot to engage with landowners and explore the development viability of green and some amber rated sites in more detail. The process has been reviewed and refined and will be rolled-out across the Perth and Kinross area. This study does, however, have the potential to amass a large amount of data. Of particular relevance to the preparation of the Proposed Plan will be the identification of ‘red’ sites which will require to be assessed through the LDP review process. An additional output beyond identifying land with housing potential, is a register of Brownfield sites for development that have current planning policy and preliminary development risks assessed. Having an up to date and accurate record of all known brownfield land within the area helps identify the scale of the problem and any issues relating specifically to Perth and Kinross which may require a local policy response in LDP3 Perth and Kinross Council Employment land matrices (Core Doc Ref CD37) utilise a ‘balanced scorecard’ approach to determine the sites most likely to require intervention to bring them forward. Whilst overall employment land supply is healthy, delivery is not without challenges with the share of employment sites owned by the Council low. These sites LDP2 sites are analysed in the Perth and Kinross Council Employment Land & Property Market Analysis December 2022. As per the Ryden’s report recommendation assessment should be amended to refer more consistently to active travel linkages. This aspect was considered through Strategic Environmental Assessment (SEA) of these sites, but it then needs to be carried forward in the matrices. There is also a need to add an assessment for the employment land at Oudenarde which is wrongly identified in LDP2 as an area of safeguarding for core employment uses (despite it not being developed yet). These matrices should also be updated to include any new employment sites that are allocated in the adopted LDP3. There is LDP2 categorisation of two types of employment land, core and general which has a different policy approach associated to them both, providing greater flexibility on acceptable uses for the general employment land, and less flexibility for the core. If the Proposed plan continues this approach, there will be a reassessment of their allocation as either core or general areas, in terms of existing function and character, and with consideration to vacancy rates. There will also be consideration through the Urban Capacity and Brownfield study as to where reallocation to enable a wider range of viable businesses or other alternative uses such as housing should be considered through the Proposed Plan process. Perth City Plan 3: Perth 2040 our agenda for change our agenda for change (August 2019) sets out an agenda for action through to 2040 and calls for businesses, communities, civil society, and public sector bodies to work together to achieve good growth. Perth City Development Board (PCDB) is an independent group tasked with setting out a vision for the future of Perth and championing good growth. The Plan carries forward the key aim
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from City Plan 2 of making Perth one of Europe’s great ‘small cities.’ The Plan acknowledges that Perth faces huge challenges to become the place it strives to be. From an employment use point of view this includes: The Future of Work: changing work patterns with more self-employment and home working. Artificial intelligence, robotics and automation could put 30% of jobs at risk by the mid-2030s, and the least skilled and educated will be most vulnerable. Perth needs to become a resilient, knowledge-based economy. Building New Communities: by 2040 Perth will need 5,000 new homes, as well as schools, healthcare facilities and employment locations. A Draft City Centre Design and Development Framework has been prepared by consultants under the Council’s instruction and guidance. The finalised framework will come back to committee for approval Spring 2025. The development of the guide builds on existing planning and economic design and development guidance and research and more recent political agreement to focus on both improvements to streetscape and properties within Perth city centre and a series of investment areas that have the potential to drive further sustainable economic growth and city centre revitalisation as follows: • Cultural Quarter • Mill Quarter • Harbour Quarter • University Quarter • and the Station Quarter This additional design and development guide will extend and complement the strategic framework of the City Plan and other planning and economic development frameworks at regional and local level and allow us to continue to promote and secure investment to deliver on key priorities for sustainable growth of the city and economy. This work will inform the development and promotion of property development and vacant and underdeveloped sites in Perth city and city centre. This will identify sites which will be further considered through Local Development Plan review. In the case of the harbour area, flood risk may restrict the acceptable range of uses, particularly residential. More information about the potential redevelopment of the harbour area is provided in the Coastal Development and Aquaculture issue Appendix A8. Key economic projections National context Scotland's National Strategy for Economic Transformation acknowledges that transition to becoming a net zero economy offers new market opportunities for businesses in Scotland, notably in the financial, manufacturing and energy sectors. Growth and investment in these sectors can take early advantage of such opportunities, in addition to creating a skilled workforce. To enable this growth, sites for expansion need to be available for firms, particularly for those looking to relocate to areas where opportunities are available. Large capital investments in this market will translate to economic growth in the areas in which they occur.
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Perth and Kinross context Tay Cities Region Economic Strategy 2019-2039 seeks to deliver on the agreements set out in the Tay Cities Region Deal. This includes supporting the growth and development of local businesses, innovation, productivity, skills, and employment. Facilitating this growth requires adequate access to employment land premises and creating such facilities that encourage investment into the area. Together with the Tay Cities Deal, the strategy has the vision of making the region an exciting place to live, work, visit and invest in, with the key ambition of increasing the number of businesses and jobs in the region. The strategy proposes doing so by investing in the area’s key business sectors, in skills and employability, and in businesses premises and employment land in the region. The Tay City Region business base tends to mirror that of Scotland as a whole, with a high proportion (87%) of micro businesses. Whilst the key business sectors noted in the strategy are: • Tourism • Food and Drink • Manufacturing and Engineering • Construction • Energy & Renewables • Digital & Creative Industries • Life Sciences Perth & Kinross has long-term strengths in the tourism, and food and drink sectors. However, the area is now also becoming a focus for agri-tech and eco-tourism. There is also a focus on innovation in the insurance and finance sectors and energy transition. This strategy is undergoing a refresh, and it is anticipated that it will be available in time to inform the Proposed Plan. Perth and Kinross Council Employment Land & Property Market Analysis December 2022, Ryden were appointed by Perth & Kinross Council to provide analysis of its employment land and property market. Relevant to this section, the objectives of this study were to provide a market analysis of the current and future employment land and property market including Perth & Kinross LDP2 employment allocations, and the Council Commercial portfolio, considering: • Future - market prospects considering economic changes, property and land requirements, and the health of the private market in different employment sectors and places, and where there is need for public sector intervention Relevant to this section, this report: • Identifies the appropriate level of the fully serviced development plot requirement at major employment locations to ensure a choice of locations and plot sizes and identifies how to support rural areas and micro businesses. • Provides an overview of public funding options available for potential investment into Perth & Kinross. • Provides a recommendation of key priorities for the Perth & Kinross Council Property Investment Strategy
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• Determines emerging land use and property occupation trends. The potential requirement for employment land and property in Perth and Kinross over the period to the anticipated end point of the next LDP (2038) is based upon the research and market analysis presented in this report. As markets continue to adjust post-pandemic and the policy and funding landscapes are changing, there is insufficient certainty to offer fixed projections, hence two scenarios are used: • A market scenario continuing current levels of activity. • A policy-on scenario whereby delivering sites and premises to meet latent market demand and accommodating future growth including through economic development strategies and project funding combine to raise the level of market activity. A figure of 50% above current levels is selected as an achievable target for the Perth & Kinross market area. The potential requirement for employment land and property in Perth and Kinross over the period to the anticipated end point of the next LDP (2038) is based upon the research and market analysis presented in this report. The target should be to sustain employment land take-up at above the historic rate of 2.1 hectares per annum, at c.3-4 hectares as strategic sites come on-stream. The overarching aim should be to provide a constant pipeline of fully serviced employment land across a mix of major employment locations and plot sizes. Employment land should be serviced not only at the strategic estate level but also capable of easy sub-division into plots down to 0.5 to 1.0 acres (0.2 to 0.4 hectares). Summary of Implications for the Proposed Plan: Quantitative analysis of business and industrial land strategy In terms of quantitative analysis there is a generous 290 hectares of marketable land in the 2022 ELA, which will not significantly change when we update our ELA (programmed for late 2024). This suggests a very healthy employment land supply. Taking account of the strategies covered in this issue, and their aims and objectives in LDP preparation process requires the LDP to allocate sufficient and appropriate locations for business and industry. To sustain employment land take-up at above the historic rate of 2.1 hectares per annum, at c.3-4 hectares, as strategic sites come on-stream as per the Perth and Kinross Council Employment Land & Property Market Analysis December 2022, would require for the LDP3 plan period 2027-2037 to identify at least 48 hectares of employment land (12 years supply, 4 hectares x12 =48 hectares, taking account of the 2 preceding years from Proposed Plan 2025 to adoption 2027). However, to calculate the overall employment land requirement, provision is suggested for any unanticipated larger industrial user/s as experience has shown in the take up for Dumfries & Galloway and Dundee, that authorities can massively exceed their average in this way. It is considered that an additional 30 hectares would be appropriate to account for this scenario. Additionally, for calculating housing land requirements, the MATHLR set out in NPF4 for each authority includes a generous flexibility allowance of 25-30% to compensate for sites stalling or not delivering as expected. A similar provision is suggested for employment land and leads to a potential minimum 100-hectare employment land requirement.
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Gaps, Uncertainties or Key Issues Raised: Summary of the potential Proposed Plan employment land requirement: • 48 hectares for the anticipated take up over 2025-2037 period • add 30 hectares for unanticipated larger industrial user/s • add between 25-30% for flexibility This suggests a potential minimum total of 100 hectares of effective employment land) may be an appropriate employment land requirement for LDP3. However, should the 2024 Employment Land Audit when it is completed to inform the Proposed Plan indicate a significant change in the average take up of employment land, this amount should be reevaluated accordingly. Qualitative analysis of business and industrial land strategy (viability/deliverability) The Perth and Kinross Council Employment Land & Property Market Analysis December 2022 identifies that the majority of allocated employment land supply is constrained and unlikely to be developed in the short-medium term without any public sector intervention. In terms of qualitative analysis, delivering Perth & Kinross’ market potential - including the industrial property projections suggested in the Perth and Kinross Council Employment Land & Property Market Analysis December 2022 - and creating capacity for mobile and unanticipated projects will require more of the land supply to move beyond allocation into servicing and marketing. Where development viability is weak or marginal, even small constraints to development of land such as survey costs and risks, minor works, landscaping/parking/paths, or plot servicing can become absolute constraints to occupiers or developers making their investment. Mainly this issue is a market one, and there will be a need for public sector intervention and investment. However, private interventions and planning interventions could also assist. Gaps, Uncertainties or Key Issues Raised: To help address this viability and deliverability issue, LDP3 will need to consider further opportunities for mixed uses allocations where appropriate and ensure there is appropriate cross funding between housing and employment uses. This approach would also support the 20- minute neighbourhood, local living policy. Also to ensure cross funded serviced sites are oven ready consideration should be given to defining serviced employment land in the LDP so that there is a consistency in the quality of the cross funded employment land delivered. In terms of qualitative assessment, when completed, the SVDLS, and the Urban Capacity and Brownfield Study will provide an effective review of capacity and potential of development sites and vacant properties. The key strategy is to retain employment land in the good locations and consider reallocating to other/mixed uses where existing business sites are underused or unsuitable. After the identification of potential LDP allocations, or alternative uses for existing allocations, there will be SEA site assessment of all sites. The Proposed Plan will consider any potential new employment land sites, whether any existing ones should be deallocated, and where mixed-use allocations could improve deliverability and viability of employment land and/or address local living objectives.
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Qualitative analysis of business and industrial land strategy (inclusive economic growth) There are some common aims and objectives within the national, regional, and local strategies and policies analysed. These common aims and objectives include generating economic prosperity for all people and places, focussing on economic wellbeing, reducing poverty, and moving towards economic growth that is both sustainable and inclusive. Supporting these aims and objectives, it is suggested that the Proposed Plan may refer to analysis of employment need, local poverty, disadvantage, and inequality, to identify where future business and industry development may provide most benefit. Gaps, Uncertainties or Key Issues Raised: In a Perth and Kinross context, there are significant limitations to using the Scottish Index of Multiple Deprivation (SIMD) data to inform our employment land strategy as rural deprivation is dispersed, and the rural population accounts for nearly half of the Perth and Kinross population. In terms of generating economic prosperity for all people and places, and reducing poverty, the SIMD highlights the importance of the Proposed Plan identifying sufficient employment land within Perth, and Blairgowrie and Rattray. However, their position within the settlement hierarchy, and the market demand within them, supports this approach too. It is considered that the Proposed Plan strategy should where possible provide employment land provision within the following settlements (which are tiered settlement locations from the LDP2) • Perth core area • The 3 regional centres (Crieff, Kinross/Milnathort, and Blairgowrie/Rattray) • and the local centres (Pitlochry, Dunkeld and Birnam, Aberfeldy, Auchterarder, Alyth, and Coupar Angus) • also further locations to meet market demands, and other policy objectives, such as reuse of brownfield land, and 20 minute neighbourhood/local living aims and objectives should be considered. To identify where future business and industry may provide the most benefit there is a current gap in evidence in terms of the settlement audit work which when completed will help inform work on Local Living and 20 Minute Neighbourhoods required under NPF4 Policy 15. The template has yet to be developed but will be in place prior to work beginning on the Proposed Plan and will consider the range of employment opportunities, and availability of LDP employment land. These settlement audits will be informed by results of our LDP3 Big Place Conversation exercise (using the Place Standard Tool) which are being collated to produce summaries for each of the localities. The Big Place Conversation summaries will be considered through our future Settlement Audit work. Perth and Kinross Council Employment land matrices utilise a ‘balanced scorecard’ approach to determine the sites most likely to require Council intervention and their relative attributes. When preparing these assessments, there was not always enough consideration of active travel links, an area of increased emphasis in national policy. Also, since they were prepared, there is an increased emphasis on generating economic prosperity for all people and places.
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Future updates of these matrices should consider those aspects carefully. Informing these matrices, analysis of the spatial distribution of existing serviced employment land, Perth and Kinross Council employment property records, together with consideration of the 20-minute neighbourhood and settlement audit analysis will help identify priorities. Tactran notes that it is difficult to understand the scale of the problem and the potential impact new development can have on business and industry without knowing the baseline data in relation to, for example, traffic levels (including congestion and journey times), wider connectivity and origins and destinations of the relevant travel to work areas as well as average travel to work times. As such, Tactran suggest any audit should consider those parameters. PKC will be carrying out a transport appraisal after the Evidence Report stage to inform the Proposed Plan, this will consider the cumulative impact of potential new development. Whilst it is unclear how the methodology once agreed with Transport Scotland will consider potential impacts on existing business and industry it will at a broad level consider how development could affect the communities involved. This work considering LDP employment land allocations and their relative priority for public sector intervention will inform the LDP review, help with delivery of LDP sites, and will inform Perth & Kinross Council’s Investment Property Strategy, its Commercial land and property portfolio, and Commercial Property Investment Programme. It will also assist in maintaining the Perth and Kinross Council Corporate plan performance indicator for the area of immediately available serviced business land to an appropriate level. Updating Employment land matrices will help prioritise public sector intervention and hopefully help deliver constrained sites. Summary of Stakeholder Engagement: On the 10th of November 2023, the Council held a sharing of study output event for the: • Perth and Kinross Employment land and Property Market Analysis, December 2022 Invitees for these events were identified as follows • agents/landowners identified by LDP team, through previous communication with these groups/agents on retail/employment land planning matters • local business interest groups • and national federations representing business interests in the area The Employment land event included a presentation (PKC and Rydens) to introduce key findings of the study and was followed by a Q+A discussion. Key discussion points included a business mentioning their difficulty in securing larger premises, or serviced land for premises. Concern was also expressed about struggle to get services in upfront to provide serviced land and attract businesses. Council intervention was sought. The discussion acknowledged that this does illustrate the study’s findings that there is limited serviced employment land ready to go for businesses, and that the market is not always meeting needs due to the lack of viability. Comment was also made regarding the 136 year land supply mentioned in the presentation, and whether the Local Development Plan will look to other uses and mixed uses. Discussion concluded that this will be a consideration through the Local Development Plan review process. Also mentioned was the difficult experience for the landowners of employment land getting the electricity and water connections. There was
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concern that utilities do not prioritise allocated industrial sites. Discussion followed around importance of liaison with utilities, during Proposed plan preparation. Comment was made regarding a logistics hub seeking clarity on what the potential is within this Council area as opposed to the central belt. Discussion that followed acknowledged that there is potential for national (link with north east) and also sub regional and local logistics (last mile). The Council produced a series of LDP3 Evidence Report Topic Papers, covering the individual subject matters of NPF4’s suite of national planning policies. These papers, which set out the detailed evidence the Council has gathered to help produce our Evidence Report and which we hope to use to help prepare our Proposed Plan, were published on the Council’s Consultation Hub and open for comments for a period of 6 week during July and August 2024. As part of our consultation process for LDP3 Topic Papers we welcomed the views of our key stakeholders (who were contacted specifically via email regarding the consultation exercise) and the public at large, on the sufficiency of the evidence gathered, our interpretation of the implications of that evidence to the Proposed Plan, and on how we intend to use that evidence to develop our LDP3. We also asked respondents to provide links to other sources of available information or data which they felt we had not included, alongside an explanation of why they considered any additional sources of information to be relevant to the preparation of the Local Development Plan. Prior to that formal consultation, as part of the process of preparing the topic papers, there was liaison with the Council Enterprise and Investment and Estates teams to ensure their feedback was incorporated into the topic paper that went out for wider public consultation. There was also joint working prior to this stage, with the Perth and Kinross Employment land and Property Market Analysis, December 2022, jointly commissioned by Planning and Enterprise and Investment teams. Big Place conversation summary report The work and local economy indicator for the BPC Place Standard consultation asked participants are there opportunities for people to work, train or volunteer locally. A summary of the comments on this topic identifies that: + Some areas feel that there is a good range of employment opportunities including part time and local opportunities + Work experience opportunities through school or youth groups is good in some areas + There are opportunities for volunteering in some local areas - Nearly every area commented on the need to commute to work, local jobs can be limited in roles and professional jobs require travel. Significantly, there is a lack of a variety of work opportunities in villages and in Perth neighbourhoods. - Many areas mentioned that the local economy is dominated by only a few sectors, for example tourism, agriculture, retail. This limits job opportunities, especially for younger people - Some areas mentioned that access to workplaces, especially in the evening, is adversely affected by transport issues. This was mentioned in Perth city neighbourhoods as well as in rural areas - A few areas mentioned poor access to Further Education and Higher Education, which undermines local economic growth
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- A few areas mentioned a shortage of housing undermines economic growth Suggestions were made to improve o Many areas suggested providing more support for small businesses, including affordable premises o Some areas suggested improving promotion of the tourism sector of the economy o A few areas suggested simplification of planning processes to make better use of existing spaces for a mix of uses o Better transport links to major centres were also suggested o One or two areas suggested development of remote work hubs with improved digital connectivity One or two areas suggested that more people would be able to live in the area in which they work if improvements were made to the range and quality of local housing
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Statements of Agreement/ Dispute 9 responses were received on our Business and Industry Topic Paper. 6 respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 026, or the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and/or highlighted other potential implications for the Proposed Plan. A summary of these comments, their status, and the Council’s response are provided in the table below. Three respondents disagree with the evidence, one also wished their comment to be treated as a formal dispute to the Evidence Report. Those two responses who are in disagreement but have not registered a formal dispute have been highlighted in orange and the one formal dispute has been highlighted in red in the table. Respondent Agree or Dispute Summary of Comments PKC’s Response Ristol Consulting Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Ristol Consulting agree with the evidence but disagree with the implications for the Proposed Plan. Ristol support the approach to a just transition to climate adaptation, and believe Perthshire is incredibly well placed to underpin the spatial strategy with an innovation led agenda through integrated energy, mobility and digital infrastructure, set within a circular approach and focused on place-based outcomes. Further Comments: Ristol consider the allocation of commercial sites, with space to expand is necessary to ensure future investment is aligned with the outcomes of NPF policy 26 (a) sites. Ristol consider PKC should explore the role of Masterplan Consent Areas to support innovation led development, such as at the Binn Eco Park with its range of strategic renewable energy, resource, commercial and applied research activities. Ristol consider there is continued support for rural business diversification as set out in LDP policy 8 & NPF policy 29. Ristol also consider there should be provision for the assessment of development contributions for rural projects where revenue is lower and projects that advance an innovation agenda, Note comments regarding need for commercial allocations, rural business and diversification policy, exploring Masterplan Consent Areas, and also on developer contributions regarding low carbon development, these are noted as considerations for the Proposed Plan stage, or in the case of MCAs for the delivery stage of a LDP. However, whilst not covering the full scope of this comment, it is noted that almost all renewables energy proposals that come in have nil contribution requirement. Also, developer contributions are always considered on a case by case basis. While MCAs will not be part of the development plan, they will be a delivery mechanism which can support the spatial strategy and policies and proposals in the development plan. Town and Country Planning (Masterplan Consent Areas) (Scotland) Regulations 2024 come into force on 5 December 2024. However, Schedule 5A Paragraph 5 is in force and requires planning authorities to
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Respondent Agree or Dispute Summary of Comments PKC’s Response particularly in low carbon construction, materials, environmental performance and support local supply chains and skills. Formal Dispute: Ristol has no formal dispute. consider whether it would be desirable to make a scheme for a part or parts of their district, and to publish a statement as to their consideration of that, by 25 July 2024. Council Officers have held initial discussions with Binn Ecopark about the potential to take forward a Masterplan Consent Area for Binn Ecopark, Glenfarg and we intend to check whether opportunities exist elsewhere to take forward Masterplan Consent Areas. PKC intend to progress this further once the legal provisions for making Masterplan Consent Areas are in force. PKC will consider whether it would be desirable to make any Masterplan Consent Areas as part of our work on delivery linked to the Local Development Plan's Delivery Programme. This work is currently relevant to delivery stages of the existing LDP and will in time be relevant to the new LDP, an amendment has been made to this Evidence Report Issue to reference MCA regulations, their role, and the discussions with regard to Binn Ecopark, Glenfarg. Errol Community Council Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Errol Community Council neither agree nor disagree with the list of evidence/datasets, and neither agrees nor disagrees with the implications for the Proposed Plan. Further Comments: None Formal Dispute: Errol Community Council has not indicated whether they have a formal dispute. Appreciate at this stage that there can be some uncertainty for stakeholders. There will be further engagement as PKC prepare the Proposed Plan.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Tactran Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Tactran offers no comment. Further Comments: Tactran considers that this paper establishes the size of marketable employment land available within Perth and Kinross. It notes that further audit work will be required to identify new LDP allocations, especially with regard to constrained sites. Tactran notes that it is difficult to understand the scale of the problem and the potential impact new development can have on business and industry without knowing the baseline data in relation to, for example, traffic levels (including congestion and journey times), wider connectivity and origins and destinations of the relevant travel to work areas as well as average travel to work times. As such, any audit should consider those parameters. Paragraph 2.52 states that “there was not always enough consideration of active travel links, an area of increased emphasis in national policy.” It is worth noting that the RTS suggests that reducing the car dependency of new developments (Action1) may be achieved by the development management process “ensuring new development is realistically accessible by a range of modes”. The purpose of this principle is recognising that all developments may not be able to be accessible by all modes due to their location (and the size of the development will determine the expectations put on it in the development management process), but it is critical that there is a choice, so they are accessible by people who do not have access to a car. For example, an accessible walking/wheeling route from the development to the closest public transport opportunity is the minimum level of provision required to ensure that a development is accessible by all. It is, subsequently, important to understand the potential impact new development allocations. As such, the scope of any Noted and it is agreed that the consideration of active travel links is important and will be included within the SEA site assessment process. It is noted that Tactran highlight any audit of LDP allocations should consider baseline data in relation to transport and traffic. In this regard it should be noted that PKC will be carrying out a Transport Appraisal after the Evidence Report stage to inform the Proposed Plan, and this will consider the cumulative impact of potential new development. Whilst it is unclear how the methodology once agreed with Transport Scotland will consider potential impacts on existing business and industry it will at a broad level consider how development could affect the communities involved.
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Respondent Agree or Dispute Summary of Comments PKC’s Response assessment should include the aforementioned data as a starting point. Formal Dispute: Tactran has not indicated whether they have a formal dispute. Homes for Scotland Disagree – but does not register as a formal dispute List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Homes for Scotland consider the evidence sufficient but disagree about the implications for the Proposed Plan. Homes for Scotland consider that there is potentially an issue in that the 2024 Employment Land Audit will not be available to inform the Evidence Report, particularly given a 2023 audit was not prepared. An “urban capacity and brownfield study” is also referenced, although there appear to be no known noted timescales for its completion. This document should be available for review prior to the Evidence Report being submitted to the Gate Check. Further Comments: None Formal Dispute: Homes for Scotland say they do not have a formal dispute, but their comments suggest there is a dispute, as the urban capacity and brownfield study will not be available prior to Gate Check. Whilst the 2024 Employment Land Audit (ELA) is not available yet, it is committed that there will be an update to inform the preparation of the Proposed Plan. It is envisaged that the ELA, will not show significant increase of employment land take up. Take-up of employment land in Perth & Kinross over the last 8 years prior can be averaged at 2.1 ha per annum. The section on the quantitative analysis of business and industrial land strategy sets out in more detail the methodology, and we can identify likely need for a minimum 100 hectare employment land requirement when we prepare the Proposed Plan. However, when we prepare our ELA 2024 if it shows a much higher uptake than the 8 year historic average, we will reconsider the minimum employment land requirement and adjust it accordingly. The Evidence Report Issue has been updated to reflect this position. These comments on the urban capacity study are similar to a formal dispute as the urban capacity study will not be available prior to the Evidence Report being submitted to the Gatecheck. It is not considered necessary to have the findings available for the Evidence Report stage, the need will be for this work to inform the preparation of the Proposed Plan. This work will be site specific and is more appropriate for post Evidence Report stage. Appropriate consideration of this matter and
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Respondent Agree or Dispute Summary of Comments PKC’s Response decisions will be made later in the plan preparation process. Montagu Evans LLP on behalf of Loch Developments Ltd Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Loch Developments Ltd neither agree nor disagree with the list of evidence/datasets, and neither agrees nor disagrees with the implications for the Proposed Plan. Further Comments: None Formal Dispute: Loch Developments Ltd does not have a formal dispute Appreciate at this stage that there can be some uncertainty for stakeholders. There will be further engagement as PKC prepare the Proposed Plan. Scottish Water Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Scottish Water neither agree nor disagree with the list of evidence/datasets, and neither agrees nor disagrees with the implications for the Proposed Plan. Further Comments: Scottish Water notes the contents of Topic Paper No.026: Business and Industry but has no further comments to add currently. Formal Dispute: Scottish Water does not have a formal dispute Appreciate at this stage that there can be some uncertainty for stakeholders. There will be further engagement as PKC prepare the Proposed Plan. Earn Community Council Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Earn Community Council agrees with the list of evidence/datasets, and with the implications for the Proposed Plan. Further Comments: Earn Community Council hope that the Business & Industry sector within P&KC will help identify/answer questions raised in this topic in regard to context, analysis & employment land requirement. A review of the present 290 hectares on land available presently is credible to remove land not suitable relative to NPF4 Policies and Note that Earn Community Council are comfortable with the methodology proposed for the preparation of the employment land strategy within the Proposed Plan as outlined in this issue. It is acknowledged that there is some uncertainty about future needs and demands for emerging sectors, and a strategy which incorporates both some generosity and flexibility will be advisable.
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Respondent Agree or Dispute Summary of Comments PKC’s Response identify potential new sites with the development of Oudenarde, the Western Edge, and revitalise Perth City Centre. With the proposed LDP3 being a long lifetime plan – there is a great unknown where business & industry is heading in general with greater reliance on digital connectivity and developments in AI (artificial intelligence) along with advancement in green energy projects. This raises questions around what type of land will be required, what capacity will be required, and how much employment will be required. Formal Dispute: Earn Community Council has not indicated whether they have a formal dispute. Savills on behalf of Scone Estates Neither but they have registered a formal dispute List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Scone Estates note that there is a growing consensus that private wire connections from renewables could assist business land being brought forward due to lessening the cost of up-front infrastructure. We are also intrigued that although public sector intervention is mentioned in terms of unlocking business land, private sector intervention is not mentioned? Scone estates support adding land for large single use and then adding a generosity allowance on top. Further Comments: Scone Estates want to see the Council's explicit recognition that investment in the Cross Tay Link Road (CTLR) is intended to unlock significant additional investment and the Evidence Report and LDP3 must reflect this by freeing up development opportunities in conjunction with the opening of the new road infrastructure. The restrictions created by the existing green belt designation should be addressed, this should Noted, and it is acknowledged that private investment can unlock business land too. This Evidence Report Issue acknowledges private interventions. We welcome feedback on the matter and note Scone Estates support for adding land for large single use and a generosity allowance to our minimum employment land requirement. The Perth Transport Futures project includes the CTLR which is a central element of that project. It is anticipated that the CTLR construction will be complete in February 2025. The project will improve the local transport network and traffic flow and reduce journey times. It will also enhance pedestrian and cycle safety, increase network capacity as well as significantly reducing traffic congestion and related pollution in Perth city centre. The CTLR project will also help unlock
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Respondent Agree or Dispute Summary of Comments PKC’s Response go further than simply making the CTLR the green belt northern boundary. Formal Dispute: Scone Estates have a formal dispute significant housing and employment land in the existing Local Development Plan 2019. PKC will be carrying out a Transport Appraisal after the Evidence Report stage to inform the Proposed Plan, this will consider the cumulative impact of potential new development. Potential opportunities will be considered in this context, statements about the CTLR freeing up opportunities would be premature to this process. With regard to the Greenbelt a further review of the boundary will be carried out to inform the Proposed Plan in line with Schedule 8 of the Local Development Planning Guidance. This matter is considered further in the Issue on Greenbelts (Appendix A6), where PKC have responded to Scone Estate’s suggestion that PKC take a root and branch approach to the review of the green belt. In summary it is considered that the greenbelt review and the assessment of potential development sites will be considered through the Proposed Plan preparation and cannot be fully addressed at Evidence Report Stage. Appropriate consideration and decisions will be made later in the plan preparation process. Stuart Buchanan on behalf of Cardross Asset Management Ltd Disagree – but does not register as a List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): It is noted with concern that PKC appears to be using the 2022 Ryden Report re demand & supply analysis for Classes 4, 5 & 6. This report is nearly 2 years out of date and must be updated. Also there must be up to date and robust assessment of "effectiveness" of existing LDP sites. For example, Please see our response to Homes for Scotland above, for more detail. However, when we prepare our ELA 2024 if it shows a much higher uptake than the 8 year historic average, we will reevaluate the minimum employment land requirement and
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Respondent Agree or Dispute Summary of Comments PKC’s Response formal dispute Perth West requires delivery of a substantial road junction, and there is no certainty that this junction can be provided via City Deal. Further Comments: There appears to be an inference that for Classes 4, 5 & 6 development that LDP3 site allocation should broadly reflect the settlement hierarchy within PKC, and further that "mixed use" development should be encouraged. This is in our view completely flawed, as particularly major Class 6 developments are likely to have 24/7 operations so require some separation from existing residential conurbations. So substantial Class 6 development at strategic transport junctions but in smaller settlements should also be supported within LDP 3. Formal Dispute: Cardross has not indicated whether they have a formal dispute, this comment was received in response to consultation on the development plan scheme. adjust it accordingly. This Evidence Report Issue reflects this position. The ELA 2024 will be updated prior to preparation of the Proposed Plan. The ELA 2024 will provide assessment of each LDP and windfall site and consider whether they are major, minor constrained or if they are immediately available sites. LDP3 will need to ensure it allocates sufficient employment land that is either minor constrained or immediately available. However, although there is a generous 290 hectares marketable land available the majority of LDP2 employment land is unlikely to be developed in short-medium term without public sector intervention, and this market situation, is unlikely to change for LDP3. With regard to the inference that for class 4,5 and 6 that LDP3 allocation should be broadly reflective of the settlement hierarchy, this is part of the methodology, however this Issue also acknowledges that the strategy will also include ‘ further locations to meet market demands, and other policy objectives, such as reuse of brownfield land, and 20 minute neighbourhood/local living aims and objectives should be considered.’ This means that Class 6 development at strategic transport junctions in smaller settlements will also be considered for allocation within LDP 3, as part of the market needs.
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Respondent Agree or Dispute Summary of Comments PKC’s Response The respondent has not indicated whether this is a formal dispute, as it was a response to the Development Plan Scheme consultation.
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Issue: Retail, City, Town and Commercial Centre Corresponding NPF4 policies: • NPF4 - policies 27 City, town, local and commercial centres and policy 28 Retail • Other key NPF4 policy connections – 1 Tackling the climate and nature crises, 2 Climate mitigation and Adaptation, 7 Historic assets and places, 9 Brownfield, vacant and derelict land and empty buildings, 13 Sustainable Transport, 14 Design, quality and place, 15 Local Living and 20 minute neighbourhoods, 16 Quality Homes, 18 Infrastructure first, 20 Blue and green infrastructure, 21 Play, recreation and sport, 23 Health and safety, 25 Community wealth building, 26 Business and Industry, 29 Rural development, 30 Tourism, 31 Culture and creativity Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 027: Retail, City, Town and Commercial Centres (https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume nts/TP027_Retail.pdf) Information required by the Act and NPF4 regarding the topic: In line with the requirement of the Act, section 15 (5) this paper will provide important background information for the Plan area regarding: • principal economic characteristics of the district and • principal purposes for which the land is used Additionally, under NPF4 Policy 27, NPF4 expects Local Development Plans to: • support sustainable futures for city, town and local centres, in particular opportunities to enhance city and town centres. They should, where relevant, also support proposals for improving the sustainability of existing commercial centres where appropriate • identify a network of centres that reflect the principles of 20 minute neighbourhoods and the town centre vision • be informed by evidence on where clustering of non-retail uses may be adversely impacting on the wellbeing of communities. • should also consider, and if appropriate, identify any areas where drive- through facilities may be acceptable where they would not negatively impact on the principles of local living or sustainable travel. • should provide a proportion of their Local Housing Land Requirements in city and town centres and be proactive in identifying opportunities to support residential development. Additionally, under NPF4 Policy 28, NPF4 expects Local Development Plans to: • consider where there may be a need for further retail provision, this may be: where a retail study identifies deficiencies in retail provision in terms of quality and quantity in an area; or when allocating sites for housing or the creation of new communities, in terms of the need for neighbourhood shopping, and supporting local living • identify areas where proposals for healthy food and drink outlets can be supported.
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The Scottish Government’s Local Development Plan Guidance (May 2023) under it’s ‘Step by step guide’ provides advice on relevant evidence for the NPF4 policy topics to help planning authorities in considering the national planning policies when preparing their Evidence Report. With respect to NPF4 Policy 27, the Guidance also advises that planning authorities are also expected to: • consider the designation of emerging or new centres is encouraged as part of key new land releases • explain how centres in the network can complement each other • develop town centre strategies and audits, for each centre included in the network to enhance their vibrancy, and spatial elements of town centre strategies can be included in the Proposed Plan • consider the broader role of town centres as important places that support an inclusive economy, our wellbeing and quality of life, and as key elements of the identity of our place. • consider preparing and reviewing the spatial implications of a brownfield urban capacity study • consider preparing and reviewing the spatial implications of a local economic strategy With respect to NPF4 Policy 28, the Guidance also advises that planning authorities are also expected to: • consider if it is useful for the Evidence Report to assess the nature of the food environment in the area, including the diversity and availability of food through retail and how it is or is not contributing towards healthy diet and weight in the area Links to Evidence: Place audits, assessments and strategies • Understanding Scotland’s Places • Scottish Vacant and Derelict Land Survey 2023 • 20-minute neighbourhood and local living analysis and settlement audit work (which will be carried out to support the preparation of the Proposed Plan) • An urban capacity and brownfield study (which will be carried out to support the preparation of the Proposed Plan) • City Centre Design and Development Framework (draft used to engage stakeholders, expected to return to committee Spring 2025 for approval) • Perth City Centre Customer and occupier demand study • Perth and Kinross City and Town Centre Retail study (city, town centre, and neighbourhood reviews) • Big Place Conversation summary report Retail and leisure sector guidance and capacity • Perth and Kinross City and Town Centre Retail study (retail capacity conclusions and policy consideration, and market context and trends) • Scottish Government Diet and healthy weight: out of home action plan • The Out of Home Environment Food Standards Scotland Permitted development rights
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• The Town and Country Planning (General Permitted Development and Use Classes) (Scotland) Miscellaneous Amendment Order 2023 Summary of Evidence: Place audits, assessments and strategies Understanding Scotland’s Places provides assessment of settlements over 1,000 population. This provides information on the population characteristics of these settlements, their level of independence and how reliant they are on neighbouring localities, and their diversity of retail offer. 20-minute neighbourhood and local living analysis and settlement audit work will be carried out to support the preparation of the Proposed Plan. This analysis will inform the spatial strategy and may identify priority places where the Council should try to identify neighbourhood retail opportunities to encourage local living. It is planned as part of the Settlement Audit work for the Proposed Plan to develop a Localities Profile template which will set out those factors which officers need to take account of in developing their understanding of each place and its needs to satisfy the requirements of the Planning Act, Regulations, LDP Guidance and NPF4 policies. These settlement audits will be informed by results of our LDP3 Big Place Conversation (BPC) exercise (using the Place Standard Tool) which are being collated to produce summaries for each of the localities. These BPC summaries will be available for inclusion in the Evidence Report and considered through our Settlement Audit work for the Proposed Plan. Scottish Vacant and Derelict Land Audit will also be a valuable information resource and having an up to date and accurate record of vacant and derelict land within the area, helps identify the scale of the problem and any issues relating specifically to Perth and Kinross which may require a local policy response in LDP3. It will also assist in the identification of potential development sites for the Proposed Plan. It is important, however, to note that not all brownfield land and vacant buildings will be included within the SVDLS. The Proposed Plan will need to use the most up to date data available. For further information on SVDLS sites in Perth and Kinross Area please refer to the Appendix 7 Brownfield, Vacant and Derelict land, and Empty Buildings Issue. An urban capacity and brownfield study will target the development of brownfield sites through the preparation of a brownfield register of potential development sites and vacant properties. A pilot exercise has so far been undertaken for a specific area of Perth and Kinross which considered vacant and derelict land, vacant properties, community land audit, car parks, underutilised open space, land in council ownership, land allocated for employment safeguarding in LDP2, land allocated in LDP2 and the housing land audit but not yet fulfilled, and officer identified sites. The main purpose is to identify sites for affordable housing, including small sites that could be brought forward for development immediately or considered for the longer term via the LDP review process. An initial assessment identified those sites which could be immediately discounted, for example, those which would not comply with planning
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policy for housing. A full sites assessment was then carried out on the remaining sites, and these were then scored to identify: • green sites with few constraints and the potential for delivery in 1-2 years • amber sites with a small number of significant constrains (or a large number of small constraints) that make feasibility less uncertain and where further assessment is needed • red sites which have significant constraints, and which would need to be considered through the review of the LDP Partners, including development trusts are using the results of the pilot to engage with landowners and explore the development viability of green and some amber rated sites in more detail. The process has been reviewed and refined and will be rolled-out across the Perth and Kinross area. This study does, however, have the potential to amass a large amount of data. Of particular relevance to the preparation of the Proposed Plan will be the identification of ‘red’ sites which will require to be assessed through the LDP review process. An additional output beyond identifying land with housing potential, is a register of Brownfield sites for development that have current planning policy and preliminary development risks assessed. City Centre Design and Development Framework at topic paper stage was being prepared by consultants under the Council’s instruction and guidance. It was latterly approved by Council on the 4th of September. The development of the guide builds on existing planning and economic design and development guidance and research and more recent political agreement to focus on both improvements to streetscape and properties within Perth city centre and a series of investment areas that have the potential to drive further sustainable economic growth and city centre revitalisation as follows: • Cultural Quarter • Mill Quarter • Harbour Quarter • University Quarter • and the Station Quarter This additional design and development guide will extend and complement the strategic framework of the City Plan and other planning and economic development frameworks at regional and local level and allow us to continue to promote and secure investment to deliver on key priorities for sustainable growth of the city and economy. This work will inform the development and promotion of property development and vacant and underdeveloped sites in Perth city and city centre. It identifies some property improvement and redevelopment opportunities such as: • St John’s Shopping Centre • Debenhams, King Edward Street • Beales/McEwans, St John Street • Matalan car park, Victoria Street • New Look/Next upper floors, High Street • Fergusson Gallery • Gap sites
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This will identify sites which will be further considered through Local Development Plan review. This includes sites identified for potential improvement or open space which are currently car parks protected in LDP2 as transport infrastructure. The consultation completed on the 17th of January, and it is intended to come back to committee in Spring 2025 for approval. The Perth and Kinross City and Town Centre Retail study was updated in February 2023 it provides in-depth reviews of the health and function of the city and town centres including their qualitative needs for improvement. These are based on detailed site visits and place reviews, the results of household and business surveys and, where available, the findings and outputs of Community Action Plans (CAPs) and ‘Charettes’. Retail and Leisure sector guidance and capacity The Perth and Kinross City and Town Centre Retail study was updated in February 2023. It provides the evidence base to assist PKC with its work on the LDP review and related economic development frameworks; and supports the development management function of the local planning authority. It also informs the regular performance monitoring of the city and town centres in the Perth and Kinross area. Reflecting the Local Development Plan 2, principal settlements, see figure 1, the Study is focused on the following centres: ▪ Perth City Centre ▪ Aberfeldy Town Centre ▪ Alyth Town Centre ▪ Auchterarder Town Centre ▪ Blairgowrie Town Centre ▪ Coupar Angus Town Centre ▪ Crieff Town Centre ▪ Dunkeld & Birnam Town Centre ▪ Kinross Town Centre ▪ Pitlochry Town Centre ▪ Perth’s Neighbourhood Centres Figure x: Local Development Plan 2, principal settlements
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The Study was prepared in the context of significant changes and events since the 2016 Study. These include Brexit, changing economic conditions, the Covid-19 pandemic, the continued growth of online shopping, widespread retailer closures, and (responding in part to such challenges) the newly adopted Fourth National Planning Framework for Scotland (‘Adopted NPF4’) and other potential planning reforms in relation to permitted development rights The study provides a retail and leisure market trends overview and highlights the need to move on from retail led city and town centres towards more multi-purpose destinations in their offer, use and experience. The retail study also considers the existing hierarchy of centres in the Perth and Kinross area and considers it largely remains appropriate to: ▪ define Perth City Centre at the apex of the hierarchy, reflecting its role as a sub-regional centre and principal focus for comparison goods shopping, services, offices, leisure and other commercial activity in the Perth and Kinross area; ▪ define the existing Town Centres of Aberfeldy, Alyth, Auchterarder, Blairgowrie, Coupar Angus, Crieff, Dunkeld & Birnam, Kinross and Pitlochry as ‘second-tier’ centres in the hierarchy. Although these centres differ in terms of their size and diversity of uses, they each (to varying degrees) provide an important local function serving the basic needs of residents and other users. However, Coupar Angus is the one centre where it may be appropriate to redefine as a neighbourhood centre; and ▪ define Neighbourhood Centres as ‘third-tier’ centres in the hierarchy recognising their small scale and predominantly walk-in catchments. The retail capacity forecasts for retail floorspace has identified an overall over-supply of both convenience and comparison goods in the Perth and Kinross area covering the Local Development period from 2027 to 2037. The amount of surplus retail floorspace forecasted is particularly acute in Perth City Centre, and this is additional to the centre’s vacancies which, in floorspace terms, stand at circa 14% according to Experian Goad. The Out of Home Environment Food Standards Scotland publishes data on the out of home (OOH) food and drink landscape, including how this environment has changed over time, the types of businesses visited, and the most popular foods and drinks purchased OOH. This data will inform the Proposed Plan’s approach to drive through retail. Scottish Government Diet and healthy weight: out of home action plan provides a framework to help outlets provide healthier foods, and supports organisations to adopt the framework given the need to address diet- related health inequalities. This includes the ability to enforce access to healthier food and take account of the location and density of food outlets in local areas. To help deliver this, NPF4 identifies that LDPs should identify areas where proposals for healthy food and drink outlets can be supported, and where drive throughs would be appropriate. The Town and Country Planning (General Permitted Development and Use Classes) (Scotland) Miscellaneous Amendment Order 2023 came into effect on 31st of March 2023 and introduced new and extended Permitted Development Rights and changes to the use class order in relation to changes of use in centres. As of 31 March 2023, there is a new use class 1A for "Shops, and financial, professional and other services", and associated changes to permitted development rights (PDR). The new class
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combines current use classes 1 (shops) – and 2 (financial, professional and other services) to form a single use class. The principal implication of this change is to enable the change of use of premises between financial or professional services users and retail users without applying for planning permission. There is also a new permitted change from financial/ professional service to car showroom, but only up to 235 square metres. Another change is greater flexibility to open a restaurant or other class 3 food and drink use (but not a hot food takeaway, which is sui generis). However, the qualification that the premises are not below or within 1m of a dwelling will limit its use as in many situations there are flats on upper floors of buildings within town centres. New flexibility also includes the right to change from various town centre uses to class 4 Offices, research & development and light Industrial, up to 300 square metres. These changes impact on how freely changes of uses can occur without requiring planning permission. Summary of Implications for the Proposed Plan: NPF4 retail policy has marked a considerable shift in the policy framework for retail, with a greater focus on a plan led approach, unless the proposal is in a town centre, or is a neighbourhood scale or a rurally appropriate proposal. NPF4 identifies that rural retail should be ancillary to other uses such as farm shops, craft shops and shops linked to petrol/service/charging stations and should support local living. NPF4 requires a plan led approach whereby a retail study identifies any deficiencies in retail provision in terms of quality and quantity so that appropriate allocation can be made for any needs. This is important context to inform the preparation of the Proposed Plan. Analysis of the Perth and Kinross City and Town Centre Retail study in February 2023, and consideration of its retail forecasts indicates there should be no requirement to plan for major new retail development. The retail capacity forecasts for retail floorspace has identified an overall over- supply of both convenience and comparison goods in the Perth and Kinross area from 2027 to 2037. Whilst this surplus is particularly acute for Perth the outlook for the nine town centres in terms of quantitative capacity is generally less ‘negative’ or more settled. However, whilst these smaller centres will be less exposed to multiple retailer downsizing than the City Centre, they will not be immune to structural changes in the retail sector which are impacting on demand and the viability of some businesses. Some of the area’s centres – including but not limited to Aberfeldy, Dunkeld & Birnam and Pitlochry Town Centres – may fare better than others due to their attractiveness to and reliance on tourists. The estimated percentage change in total retail floorspace the study predicts is necessarily indicative, but it serves to highlight the degree to which most of the centres are likely to be faced with retail contraction over the plan period to 2037. The estimated forecasted capacity for new convenience and comparison goods floorspace in 2037 (end of LDP period) is: • - 6,300 square metres net for Perth (-18% from 2022-2037) • - 300 square metres net for Kinross (-20% from 2022-2037) • + 50 square metres net for Auchterarder (1% from 2022-2037) • - 1,000 square metres net for Crieff (-15% from 2022-2037)
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• - 300 square metres net for Alyth (-37% from 2022-2037) • - 2,200 square metres net for Blairgowrie (-18% from 2022-2037) • - 50 square metres net for Coupar Angus (-11% from 2022-2037) • - 200 square metres net for Dunkeld and Birnam (-23% from 2022-2037) • 200 square metres net for Aberfeldy (12% from 2022-2037) • -50 square metres net (-1% from 2022-2037) for Pitlochry The evidence all points to a need to move on from retail led city and town centres towards more multi-purpose destinations in their offer, use and experience. The use classes and permitted development rights March 2023 changes in Scotland provides additional flexibility which should help centres adapt, as it means premises can change use more freely between retail, business, financial / professional services, office, and food and drink. It will allow businesses and landlords to adapt and repurpose vacant and/or under-utilised retail space for alternative uses. However, it will also somewhat restrict the control the planning authority has in supporting local living and accessibility to services. For example, the only convenience store in a centre (class 1 shop) could change its use to an estate agent’s office (class 2 professional services) without requiring planning permission. Future performance and recovery will much depend on how each centre adapts to future changes and remains relevant and attractive to shoppers and other town centre users. They will all, regardless of scale, need to be more multi-purpose in their offer, use and experience. It will be important to develop a Proposed Plan response which considers how change can be supported and managed in the city and town centres to ensure their future vitality and viability. Analysis of the Perth and Kinross City and Town Centre Retail, the urban capacity and brownfield study, the City Centre Design and Development Framework, the 20-minute neighbourhood and local living analysis, and the settlement audit work will identify any local issues and opportunities which will support the Proposed plan preparation. Gaps, Uncertainties or Key Issues Raised: Considering the retail forecasts of the Perth and Kinross City and Town Centre Retail study, there is no requirement to plan for major new retail development, but there will be a need to consider neighbourhood scale retail. Also, whilst there is a need to move on from retail led centres, the Proposed Plan should afford sufficient protection for footfall generating activities and allow for proper scrutiny of change of use proposals from town centre use(s) to ground floor residential. This is something which should be considered further when preparing the Proposed Plan. There will be a need for the LDP to identify the town centres, neighbourhood centres, and commercial centres (the network of centres reflecting the principles of 20 minute neighbourhood). There will also be a need to consider if Perth city centre and the town centre extents should be redefined, or whether a policy approach will be sufficient. There is a need to consider the opportunities for town centre living. Carrying out a future urban capacity and brownfield study will help identify the scale of the opportunities and any issues which require a response in the Proposed Plan. It will help in identifying suitable conversion and new build opportunities for residential development within the centres. This
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study will identify longer term red sites with some constraints associated to them, which may or may not be supported, and these should be considered through LDP review, and through SEA site appraisal. The settlement hierarchy in the existing LDP is largely appropriate however the Perth and Kinross City and Town Centre Retail study 2023 does provide some guidance on what will require review in the Proposed Plan. This concerns whether Coupar Angus should be redefined as a neighbourhood centre, and also requires defining neighbourhood centres in a more comprehensive way. The retail study suggests some additional neighbourhood centres within Perth, whilst future 20-minute neighbourhood and local living analysis and settlement audit work to support the Proposed plan, may identify the need to identify further neighbourhood centres. The Perth and Kinross City and Town Centre Retail study provides recommended definitions to help with the interpretation of NPF4 Policy 28 Retail with reference to edge of centre sites, to small scale neighbourhood retail, and to the floorspace threshold at which an impact assessment will be required. These are matters which it is generally too early to consider and will be considered at the Proposed Plan stage. However, since the Proposed Plan will need to consider opportunities for neighbourhood scale retail, it might be useful to be aware that the study suggests this should be defined as comprising no more than 500 sqm gross in total, with individual retail units measuring no more than 200 sqm gross. These controls would ensure development principally serves local retail needs and is consistent with the principles of 20- minute neighbourhoods. The eating out of the home sector continues to grow, and it is important that this growth sector supports existing centres which are losing some of their retail function. In terms of future food and drink development opportunities, these will be directed to existing centres as per NPF4 policy 27. The evidence from the Perth and Kinross City and Town Centre Retail study, the availability of existing drive through provision, and the recent planning permissions granted for drive through provision at Broxden in Perth suggests that it is unlikely that the Proposed Plan will need to allocate any new sites for drive-through restaurants. This analysis is informed by NPF4 Policy 27 City, town, local and commercial centres, which identifies drive throughs are only appropriate where they would not negatively impact on the principles of local living or sustainable travel. There is also scope to consider drive through applications on retail allocations without necessarily requiring specific allocations for drive throughs. In terms of the NPF4 consideration of potential clustering of hot food takeaways, high-interest money lending, and betting shops, Perth city centre area does have multiple fast-food take-aways and some (but not high numbers) betting shops. This reflects the nature and function of a city centres and is not problematic. The food and beverage overview within the Perth and Kinross City and Town Centre Retail study does not note any problematic clustering of takeaway provision. Therefore, clustering of these non-retail uses is not an obvious issue within Perth and Kinross. Summary of Stakeholder Engagement: On the 15th of June 2023, the Council held an in person sharing of study output event for the:
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• Perth & Kinross City and Town Centre Retail Study, February 2023 Invitees for these events were identified as follows • agents from LDP email list we stay connected with on progress of the Local Development Plan • other agents/landowners identified by LDP team, through previous communication with these groups/agents on retail/employment land planning matters • local business interest groups • and national federations representing business interests in the area As well as providing presentations on the study, the feedback received from the attendees considered that town centres are too reliant on multiples, and there are visible ones that are closing. It was suggested that the pendulum is swinging away from multiples, back to independents, and there is a need for splitting and smaller units. Mix of uses was also considered important. The Council then produced a series of LDP3 Evidence Report Topic Papers, covering the individual subject matters of NPF4’s suite of national planning policies. These papers, which set out the detailed evidence the Council has gathered to help produce our Evidence Report and which we hope to use to help prepare our Proposed Plan, were published on the Council’s Consultation Hub and open for comments for a period of 6 week during July and August 2024. As part of our consultation process for LDP3 Topic Papers we welcomed the views of our key stakeholders (who were contacted specifically via email regarding the consultation exercise) and the public at large, on the sufficiency of the evidence gathered, our interpretation of the implications of that evidence to the Proposed Plan, and on how we intend to use that evidence to develop our LDP3. We also asked respondents to provide links to other sources of available information or data which they felt we had not included, alongside an explanation of why they considered any additional sources of information to be relevant to the preparation of the Local Development Plan. Prior to that formal consultation, as part of the process of preparing the topic papers, there was liaison with the Council Investment team to ensure their feedback was incorporated into the topic paper that went out for wider public consultation. There was also joint working prior to this stage, with the Perth and Kinross City and Town Centre Retail Study, February 2023 jointly commissioned by Planning and Enterprise and Investment teams. The Big Place conversation summary report provides a summary of comments on place standard questions. There is no specific retail question, but respondents considered what are the Streets, Squares and Buildings like in my place. This picked up on concerns about vacant buildings within centres, and where some streets/buildings have a negative impact. Then under Facilities and Services, respondents considered what is my place like for accessing services we need. This identified mixed views as to whether local shops and services in rural areas met people's needs, some areas were content with existing provision, but some areas noted travel was necessary to access shops and services. Also, food shopping was felt to be expensive in local shops and there is a lack of choice of local shopping options. Some areas suggest developing rural hubs to deliver essential services and facilities to accommodate growth.
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Statements of Agreement/ Dispute 9 responses were received on our Retail, City, Town and Commercial Centres Topic Paper. Two thirds of the respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 27, or the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and/or highlighted other potential implications for the Proposed Plan. A summary of these comments, their status, and the Council’s response are provided in the table below. Three respondents wished their comments to be treated as a formal dispute to the Evidence Report. Those responses have been highlighted in red in the table. Respondent Agree or Dispute Summary of Comments PKC’s Response Errol Community Council Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Errol Community Council neither agree nor disagree with the list of evidence/datasets, and neither agrees nor disagrees with the implications for the Proposed Plan. Further Comments: None Formal Dispute: Errol Community Council does not indicate whether they want to make a formal dispute. Appreciate at this stage that there can be some uncertainty for stakeholders. There will be further engagement as PKC prepare the Proposed Plan. Nature Scot Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Nature Scot neither agree nor disagree with the list of evidence/datasets, and neither agrees nor disagrees with the implications for the Proposed Plan. Further Comments: Nature Scot indicate is useful to include all relevant policies as listed under Policy 27 of NPF4 (p. 83). Formal Dispute: Nature Scot does not indicate whether they want to make a formal dispute. Appreciate at this stage that there can be some uncertainty for stakeholders. There will be further engagement as PKC prepare the Proposed Plan.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Historic Environment Scotland Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Historic Environment Scotland agree with the list of evidence/datasets, and with the implications for the Proposed Plan. Further Comments: Historic Environment Scotland considers that the topic paper recognises the ongoing change of focus in some of these centres from retail to other uses. Many of our town centres and high streets have significant clusters of historic buildings, places and spaces and changes of use will offer both opportunities and challenges to these assets. Formal Dispute: Historic Environment Scotland does not have a formal dispute. Noted, opportunities and challenges for these assets will be considered further through the urban capacity study and preparation of the Proposed Plan. Lichfields on behalf of McDonalds Dispute List of Evidence/Datasets: McDonald’s Restaurants Ltd (‘McDonald’s) disagree and suggest Perth and Kinross Council must discuss with lead industry operators to accurately identify areas which have a need for new drive-thru developments. This will ensure that areas which have been identified as having a specific requirement are properly assessed and considered for allocation as part of the future LDP. McDonald’s can assist with the provision of evidence. Perth and Kinross Council need to undertake work with the industry to identify demand in the local authority area. Once this initial consultation has been carried out, Perth and Kinross Council should produce evidence accordingly to prepare an accurate and robust Evidence Report. Perth and Kinross Council should also discuss with landowners to identify future opportunities, as this The Chief Planners letter on transitional arrangements dated 8 February 2023 states for drive throughs that, ‘Suitable locations may include for example those allocated for Class 1 shops or Class 3 Food and drink, depending on the nature of the proposal involved in each case. In looking at the potential impact of the development as a whole, as always, decisions will depend on the facts and circumstances of each individual case and regard should be given to wider policies within NPF4, including those relating to reducing emissions that contribute to climate change and to wider policies that aim to improve town centres and support local living.’ An amendment has been made within this Issue to acknowledge that there is scope to consider drive through applications on retail allocations without necessarily requiring specific allocations for drive throughs. The topic paper considered that there was no need for allocating specifically for drive through development in
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Respondent Agree or Dispute Summary of Comments PKC’s Response will help to guide future allocations and policy wording for specific sites. Sources of evidence listed that are still currently being prepared, include the City Centre Design and Development Framework and the Scottish Vacant and Derelict Land Audit and opportunity should be provided for key stakeholders to comment on once the documents are finalised. Perth and Kinross Council should undertake discussions with lead drive-thru operators in the industry to establish requirements and to ensure that data is sufficient. Summary of Implications for Proposed Plan (PP): The topic paper refers to drive-thru units and states that the evidence from the Perth and Kinross City and Town Centre Retail study, the availability of existing drive- through provision, and the recent planning permissions granted for drive through provision at Broxden in Perth suggests that it is unlikely that the proposed plan will need to allocate any new sites for drive-through restaurants. However, the topic paper does not make clear how the information has been assessed to reach this conclusion. The Perth and Kinross City and Town Centre Retail Study which is listed as one of the main evidence bases in Section 2 of the topic paper does not assess drive-thru developments. In addition, this study only focuses on town and local centres, and it should be recognised that there are other suitable locations for drive-thru developments to be located. Furthermore, while new planning permissions have been granted for drive-thru developments in Broxden (ref. LDP3, due to the existing operators at Inveralmond and at Broxden (along with the 5 additional drive through units permitted at Broxden) in Perth. This topic paper consultation provided opportunity for industry operators to get involved. The existing provision at Broxden and planning permissions can serve motorway and road users, although it is also observed to serve local custom. This analysis has been informed by NPF4 Policy 27 City, town, local and commercial centres, which identifies drive throughs are only appropriate where they would not negatively impact on the principles of local living or sustainable travel. It is considered that the specific need for drive through provision (so proposals do not significantly impact on local living, town centres, and climate change) is for long distance road travellers. In Perth and Kinross existing provision and planning permissions at key transport locations Broxden and Inveralmond in Perth cater for this market. It is considered that specific allocations for drive throughs elsewhere in Perth and in other settlements, if not in our centres, likely would have a negative impact on our centres, and on local living, and emissions. Beyond current operators, and planning permissions, the specific need for local customers in Perth, Blairgowrie, Crieff, Kinross and Pitlochry is for drive to/takeaways and restaurants which can be accessed by all users vehicular and non-vehicular, and these formats/space requirements tend to be accommodated more easily within town and local centres. There is a need to move on from retail-led city and town centres towards more multipurpose destinations in their offer, use and experience. Capacity within this sector needs to be directed to the network of
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Respondent Agree or Dispute Summary of Comments PKC’s Response 23/00193/FLL and ref. 23/00504/FLM), it is considered that this does not satisfy the requirements for drive-thru restaurants elsewhere in the Perth and Kinross Council area. Several existing restaurants within the Perth and Kinross area are trading at levels above their planned capacity – which is a reflection of demand across the area. Such high levels of trading at the existing restaurants do, however, bring issues – both in terms of the customer experience, and also in terms of highway capacity at peak times. These are issues which McDonald’s are keen to address and they would like to do so through the planned development of more restaurants to respond to customer demand. In addition to dealing with the identified issues, this will bring added benefits, both in terms of reducing distances travelled to access the restaurants, and in terms of new employment opportunities/wider economic benefits. McDonald’s have a commercial requirement for new drive-thru restaurants in several towns in Perth and Kinross, including Perth, Blairgowrie, Crieff, Kinross and Pitlochry. McDonald’s would welcome further discussion in relation to these requirements and how they can be addressed through policies and allocations within the forthcoming LDP. Further Comments: McDonald’s outline the diversity of their offer and customer experience. McDonald’s have identified a shortfall in provision in several areas in Perth and Kinross which puts unnecessary pressure on existing facilities with some customers travelling some distance to access them. More localised provision is therefore desirable, and McDonald’s have requirements for several centres to ensure their vitality (as there is contraction of retail). Also, if we do not capture that local food and drink market within our centres, then they will not be in the right location to support local living or sustainable travel and will instead encourage local residents to use their cars to reach locations that are difficult to reach by active travel means. With regard to the City Centre Design and Development Framework, a draft was consulted on providing opportunity for feedback. The finalised version when available will inform the preparation of the Proposed Plan. The Scottish Vacant and Derelict Land Audit is prepared using the Scottish Government guidance note and is a factual return and has now been completed for 2023 (information on this is provided in the Brownfield Issue appendix A7), the urban capacity study will be broader in scope, and will be available to inform the Proposed Plan preparation.
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Respondent Agree or Dispute Summary of Comments PKC’s Response areas in Perth and Kinross, including Perth, Blairgowrie, Crieff, Kinross and Pitlochry. McDonald's would welcome the opportunity to work with the Council to develop an up-to-date evidence base to support the preparation of a new LDP which accurately reflects and responds to the need and demand for drive- thru development across the area, through a positive policy environment which identifies preferred locations for new development. Formal Dispute: McDonalds has a formal dispute and reasons are provided above. The evidence listed within Perth and Kinross’ Topic Paper is not considered sufficient to accurately create new policy wording in the future LDP regarding drive-thru developments. Montague Evans on behalf of Loch Developments Ltd Dispute List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Loch Developments Ltd disagree. They consider the conclusion that there is no requirement to allocate major retail development is incorrect and are of the view that there is a need for initial retail development within Kinross which could be accommodated on the former BCA site. Loch Developments Ltd also disagree that there is no need to allocate sites for drive-through restaurant, the site of the former BCA in Kinross could accommodate a new Class 3 use, with associated drive through. Loch Developments Ltd welcome the commitment to review the LDP Town Centre boundaries and we would contend that the former BCA site, accessed from Kinross High Street, should form part of an extension to the Town Centre in Kinross. Loch Developments seek a retail and drive through allocation for the Proposed Plan. However, what is currently being considered is whether the evidence is appropriate on which to make the decision at the Proposed Plan stage. Loch Developments do not contest the Perth and Kinross City and Town Centre, Retail Study, February 2023, or suggest alternative evidence should be considered. Perth and Kinross Council supports the study and its conclusions. Analysis of the Perth and Kinross City and Town Centre Retail study in February 2023, and consideration of its retail forecasts indicates there should be no requirement to plan for major new retail development at Proposed Plan stage.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Loch Developments Ltd would note that the Perth and Kinross City and Town Centre, Retail Study, February 2023 specifically notes that the town would benefit from better signage and events to integrate the town centre and the Loch Leven Pier and Loch Leven Castle, which the development of this site could help to provide. Further Comments: The former BCA site in Kinross should be allocated as a mixed use site within the boundary of the Kinross Town Centre. The site could accommodate a mix of uses including retail, drive through restaurant, and residential. Formal Dispute: Loch Developments Ltd has a formal dispute, and seeks the allocation of the former BCA for mixed uses, retail, drive through and residential. Regarding drive through provision please see the response above to McDonalds. Specifically with regard to Kinross there is food and drink provision for road traffic users at Moto Kinross, and whilst there is currently no drive through provision it provides a similar function/meets a similar need as a drive to facility. Scottish Water Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Scottish Water neither agree nor disagree with the list of evidence/datasets, and neither agrees nor disagrees with the implications for the Proposed Plan. Further Comments: Scottish Water acknowledge the contents of Topic Paper 027: Retail, City, Town and Commercial Centres and support Perth and Kinross Council's ambitions to continue building sustainable economic growth opportunities throughout the region and will continue to work with all agencies to deliver development proposals. When considering proposals around redevelopment of existing retail or town spaces, Scottish Water request, where possible, the inclusion of sustainable surface water management principles and plans to inform and influence the design and planning process of town centres and Note Scottish Water’s comments with regard to sustainable water management and will take these on board for the preparation of the Proposed Plan.
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Respondent Agree or Dispute Summary of Comments PKC’s Response associated retailing, this includes redevelopment of existing town centre spaces. Scottish Water continues to emphasise the need for closer partnership working to deliver blue green infrastructure required to transform towns and urban environments to long term sustainable communities. Formal Dispute: Scottish Water does not have a formal dispute. Avison Young on behalf of Aldi Stores Ltd Dispute List of Evidence/Datasets: Aldi Stores neither agree nor disagree with the list of evidence/datasets and focus specifically on the sections relating to the Perth and Kinross City and Town Centre Retail Study. The findings of the 2023 study offer significant contrast to the conclusions of the Council's previous retail study, the Perth and Kinross Town Centre and Retail Study from 2016. The conclusions are largely a product of the methodology used and if the 2016 approach had been repeated, the newer study would likely have identified retail capacity. Issues with the latest report are that the 2023 Study does not take account of the evidence of overtrading that is currently present within the Perth area and take this forward into calculations of potential capacity. The 2016 report did however do this (see Table 9.1). This overtrading is a sign of qualitative deficiency and lack of choice. Incorrect conclusions have been reached about future retail capacity within Perth and Kinross with potential implications for the future policy framework. The 2023 Study states "It is important to note that the retail capacity forecasts serve only as a guide for future planning policies, development frameworks and/or Overall methodology of the 2023 study It should firstly be noted that the 2023 study is consistent with good retail planning practice and is based on the latest available information, including a new household telephone survey of shopping patterns, up-to-date population and expenditure projections, and robust estimates for Special Forms of Trading (i.e. online retail sales). The retail market has changed significantly since the 2016 study, due in part to changes in shopping habits and expenditure growth rates, and therefore different findings and conclusions are to be expected. Approach to over-trading Underpinned by up-to-date survey research into shopping patterns, the 2023 study establishes an overall picture of currently under-performing i.e. under-trading convenience floorspace across the Perth and Kinross area relative to estimated ‘benchmark’ levels. This is illustrated in Figure 6.7 of the 2023 study (the sum of the “Estimated over/under trading” column being circa -£44m). It includes: ▪ -£16.8m in Perth City Centre; ▪ -£2.1m in Kinross Town Centre; and ▪ +£5.8m in relation to Non- central stores in the Perth and Kinross area (as a group). It
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Respondent Agree or Dispute Summary of Comments PKC’s Response decisions on planning applications. They are not prescriptive and the further ahead the forecasting year, the less certain the forecasts." We agree with that comment. Paragraph 8.13 states "In reality, should proposals for new foodstore development come forward, these are likely to be supported in expenditure terms by attracting market share from existing convenience goods floorspace, including but not limited to the ‘non-central’ main foodstores which (as set out in section 6 previously) dominate the catchment area market shares and are estimated to be over-trading relative to benchmarks levels." We recommend that this be considered when preparing the next LDP. Aldi also note differences between the 2016 study and the 2023 information in terms of calculations of inflow of expenditure from beyond Perth and Kinross (including tourism). This additional expenditure generates further capacity within the area. The 2023 retail study used an assumption of only 3%, when the 2016 study (see Table 8.4) suggested 6% visitor spending. Less capacity has been identified and inaccurate conclusions reached about deficiencies across Perth. Summary of Implications for Proposed Plan (PP): Aldi Stores disagrees with the implications for the Proposed Plan. Aldi recommend that any associated policy wording within the emerging LDP does not rely too heavily upon the conclusions of the 2023 Retail Study. This would be a misinterpretation of that report and would not allow applications to come forward to address deficiencies shown by the evident overtrading. is presumed it is the latter (relating to Non-central stores in the Perth and Kinross area) which the Aldi representations identify as evidence of over-trading that is currently present in the area. Regardless of the study estimates of over or under trading at the base year of 2022, the capacity forecasts set out in the 2023 study assume existing convenience floorspace performs at benchmark turnover levels from 2027 onwards. As set out at paragraph 8.7 of the 2023 study: the forecasts are on the assumption that, where existing convenience goods floorspace is shown in the model to be trading above or below average benchmark levels (as considered in section 6 of this report), the sales density will fall or rise to that benchmark level from 2027 onwards. In reality, some stores may continue to trade above or below average benchmark levels. This approach is entirely appropriate, and there is no justification for exploring the implications of over-trading on the basis the evidence does not point to over-trading and spare capacity in the area. Rather, it reveals an overall picture of under-trading and a substantial theoretical over-supply of convenience floorspace in the Perth and Kinross area and most of its main centres / sub areas. Although the survey-indicated market shares would suggest that Non-central stores in the Perth and Kinross area (as a group) are trading +£5.8m above benchmark turnover levels, this is not significant and is broadly in line with ‘acceptable’ levels (assumes trading approximately 2% above total benchmark sales of £260.6m). Using benchmark turnover levels, as opposed to the above- average turnover indicated by the survey research,
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Respondent Agree or Dispute Summary of Comments PKC’s Response Aldi would be happy to submit more detailed retail tables if it would assist Perth and Kinross Council. Further Comments: None Formal Dispute: Aldi Stores has a formal dispute. It is considered that less capacity has been identified than available and inaccurate conclusions reached about deficiencies across Perth. Aldi stores also disagree with the implications for the Proposed Plan. Further details of this dispute have been outlined above. therefore provides a reasonable baseline for forecasting purposes. The Aldi representation suggests the 2023 study does not take account of the evidence of overtrading that is currently present within the Perth area and take this forward into calculations of potential capacity. The 2016 report did however do this (see Table 9.1). The 2023 study does not follow the same approach as the 2016 study in this respect because the 2023 study establishes an overall picture of under-trading convenience floorspace across the Perth and Kinross area, and thus no spare capacity; whereas the 2016 study estimated substantial over-trading and spare capacity in the Perth sub area (in addition to the Highland sub area). This is a key difference between the findings of the two studies. Notwithstanding, our consultants have explored alternative capacity forecasts for Non-central stores in the Perth and Kinross area (as a group) whereby the +£5.8m ‘over-trading’ figure is included in the calculation of expenditure capacity to support new convenience floorspace (as opposed to sales falling to estimated benchmark levels from 2027 onwards). They applied this only to the early part of the forecasting period (i.e. by 2027) consistent with the 2016 study. The resulting forecasts indicate no material change to the level of capacity forecasted for Non-central stores in the Perth and Kinross area. There would remain a small theoretical over-supply of convenience floorspace by 2027 (-50 sqm net sales area as opposed to -550 sqm net sales area identified in the 2023 study).
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Respondent Agree or Dispute Summary of Comments PKC’s Response Thus the claimed evidence of over-trading that is present in the area, as implied by the Aldi representations, if taken forward into calculations of potential capacity, as per the alternative capacity forecasts described above, does not generate sufficient expenditure capacity to support new convenience floorspace in Non-central stores in the Perth and Kinross area. Even if ‘positive’ capacity is identified, this does not mean that such capacity forecasted should necessarily be accommodated in the form of ‘non-central’ foodstore development (rather the sequential approach should be applied) as set out at paragraph 8.12 of the 2023 study. Approach to clawback/leakage Developing an appropriate strategy for re-capturing trade ‘leaked’ and retaining a higher proportion of expenditure available within an area is influenced by many factors – including the level of retail capacity forecasted. The 2023 study identifies a substantial theoretical over- supply of convenience floorspace in the Perth and Kinross area from 2027 (i.e. no spare capacity). There is no sound basis therefore on which to plan for additional convenience floorspace as a means of clawing-back expenditure and reducing leakage. The 2023 study identifies the most appropriate strategy for clawing-back expenditure leakage will involve addressing the issues and qualitative needs for improvement identified for the area’s centres in section 4 (see paragraphs 6.28-6.34 of the 2023 study). This approach – in the context of no spare capacity – would help to redirect footfall and expenditure to existing centres and achieve a more sustainable network of centres in the Perth and Kinross area. It would include, in part, redirecting market shares of expenditure from ‘non- central’ locations to shops and stores in the existing centres
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Respondent Agree or Dispute Summary of Comments PKC’s Response (in accordance with the ‘town centres first’ policy). This approach differs from the 2016 study approach to clawback/leakage. The 2016 study explores clawback in the Perth and Highland sub areas (only) i.e. where ‘spare capacity’ is estimated. It does not follow the same approach for the sub areas of Kinross, Strathearn and Strathmore & The Glens because, it says, ‘The current under-trading does not suggest a strong platform for introducing additional floorspace through clawback of some leakage, so there is no ‘high estimate’ (see footnote to Table 9.5 in the 2016 study). Approach to forecasting range(s) The low and high estimates of retail capacity set out in the 2016 study, for the Perth and Highland sub areas (only), factor in the scope for clawback mentioned above. 1.23 Paragraph 8.5 of the 2023 study sets out a justification for not modelling a ‘clawback’ scenario and therefore a low and high estimate of retail capacity: The consultants were aware that the 2016 Study provided a low and high estimate of the expenditure-based capacity for new retail floorspace; the ‘high’ estimate being based on broad assumptions in relation to the potential clawback of expenditure leakage. However, as mentioned, the 2016 Study identified a baseline position of ‘spare’ capacity and took the view that the Perth and Highland sub-areas (only) had sufficient capacity for the high estimates to be relevant. Those findings contrast with the up-to-date capacity forecasts set out and described [in the 2023 study], which point to over-supply, and therefore it is considered that an additional scenario is not necessary for, or additive to, assessing retail needs for the purpose of the LDP. Given expenditure growth projections and the substantial proportion of spending online, even significant upward adjustments to the survey indicated market shares attracted to the shopping destination modelled would not
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Respondent Agree or Dispute Summary of Comments PKC’s Response result in ‘positive’ retail capacity where substantial over- supply is forecasted. Visitor allowances With regard to visitor allowances, these are set out in Figure 7.3 of the study, and are fit for purpose, based on knowledge of the city and town centres, including their propensity to attract tourists, in addition to the results of the household telephone survey and the business-to-business interview surveys. These vary by settlement, and Perth is identified for 3% for convenience spend, whilst Dunkeld is identified for 10 % acknowledging the greater impact of visitor spend in Dunkeld. Overall conclusions Considering the retail forecasts of the Perth and Kinross City and Town Centre Retail study, there is no requirement to plan for major new retail development, but there will be a need to consider neighbourhood scale retail. Whilst the Perth Aldi proposal at Cherrybank was looking at much larger store and large catchment, there may be opportunities identified for Aldi or other operators, to provide local store format provision which helps with 20- minute neighbourhoods, and local living. There has been a move towards smaller Aldi stores around 450m2. However, it is noted this is still bigger than the neighbourhood format, where the study suggests, ‘the new LDP defines such development as comprising no more than 500 sqm gross in total, with individual retail units measuring no more than 200 sqm gross. These controls will ensure development principally serves local retail needs and is consistent with the principles of 20-minute neighbourhoods.’
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Respondent Agree or Dispute Summary of Comments PKC’s Response Private Individual (row 9) Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Respondent neither agree nor disagree with the list of evidence/datasets and disagrees with the implications for the Proposed Plan. Respondent considers that Perth city centre is in poor state, with not enough to attract people to come into town. Beyond the museum it is considered that there needs to be a more culture and arts focus. Further Comments: None Formal Dispute: Respondent does not have a formal dispute. Thanks for your comment, this feedback reflects comments we received about Perth City centre during the Big Place Conversation, about care and maintenance which scored a fairly low 3.4 out of 7, and Identity and Belonging which also scored a fairly low 3.6 out of 7. The main purpose of these conversations is to help shape the next Local Development Plan as well as to provide an evidence base for community-based plans, our emerging Mobility Strategy, and the preparation of the Draft City Centre Design and Development Framework. Earn Community Council Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Earn Community Council agree with the list of evidence/datasets, and with the implications for the Proposed Plan. Further Comments: Earn Community Council note there is no page numbering provided on this Topic paper. Notes the policy outcomes for NPF4 City, town, local and commercial centres, and NPF4 Retail policies, and considers that the keynote of discussion around take- aways, money lending and betting shops, does not personify Perthshire retail and all that it can offer. Also considers this topic makes 'Retail' very food orientated. Agrees there is no need for further 'Drive Thru' culture. It is also noted that there is a lot of information still to garner for this evidence report via conclusion of: 20-minute neighbourhood and local living analysis and settlement audit work Scottish Vacant and Derelict Land Audit Note Earn Community Council supportive comments, and agree that discussion around take-aways, money lending and betting shops, does not reflect Perthshire retail. Planning Authorities are asked to consider if clusters of these uses are an issue in their settlements, and this topic paper suggested that clustering of these non-retail uses is not an obvious issue in Perth and Kinross. This response supports this conclusion. Note comment in support of no need for further drive thru cultures. With regard to 20 minute neighbourhood provision, we will consider retail provision in our settlement audits, and note your comments with regard to retail space being desirable within Bridge of Earn at Oudenarde. The level of provision should be at an appropriate to neighbourhood scale. As per this Issue, ‘The Proposed Plan will need to consider opportunities for neighbourhood scale retail, it might be useful to be aware that the study suggests this should be defined as
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Respondent Agree or Dispute Summary of Comments PKC’s Response An urban capacity and brownfield study City Centre Design and Development Framework With regard to 20 min neighbourhood provision, it is suggested that supermarket retail space at Oudenarde would relieve congestion within Bridge of Earn on Main Street, and reduce use of car to Perth. Formal Dispute: Earn Community Council does not have a formal dispute. comprising no more than 500 sqm gross in total, with individual retail units measuring no more than 200 sqm gross. These controls would ensure development principally serves local retail needs and is consistent with the principles of 20- minute neighbourhoods.’
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f╛╛╩¾مك• ╩╗ÏΓك?¾◘¾Γ→╔σ ¾τ╤ Corresponding NPF4 policies: • National Planning Framework, Policy 17 Rural Homes (part) • National Planning Framework, Policy 29: Rural Development • Other key NPF4 policy connections - 1: Tackling the climate and nature crises; 2: Climate mitigation and adaptation; 4: Natural Places; 5: Soils; 6: 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; 16: Quality homes; 18: Infrastructure First; 20: Blue and green infrastructure; 22: Flood risk and water management; 26: Business and industry; 27: City, town, local and commercial centres; 28: Retail; 30: Tourism; 31: Culture and Creativity; 32: Aquaculture; 33: Minerals. Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 028: Rural Development and Homes https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume nts/TP028_Rural%20Development%20and%20Homes.pdf Information required by the Act and NPF4 regarding the topic: Section 15(5) of the Town and Country Planning (Scotland) Act 1997, as amended: • The desirability of allocating land for the purposes of resettlement. • The extent to which there are rural areas within the district in relation to which there has been a substantial decline in population. Under Policies 17 and 29 NPF4 expects Local Development Plans to: • Set out tailored approaches to housing in rural and island areas and where relevant include proposals for future population growth. • Identify the characteristics of rural areas within the plan area, including the existing pattern of development, pressures, environmental assets, community priorities and economic needs of each area. • The spatial strategy should set out an appropriate approach to development in rural areas which reflects the identified characteristics. The Scottish Government’s 6-fold Urban Rural Classification 2020 should be used to identify remote rural areas. • Spatial strategies should support the sustainability and prosperity of rural communities and economies. • Previously inhabited areas which are suitable for resettlement should be identified in the spatial strategy. 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 intent for Policy 29: • To encourage rural economic activity, innovation and diversification • whilst ensuring that the distinctive character of the rural area and the service function of small towns, natural assets and cultural heritage are safeguarded and enhanced. 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. Policy outcomes for Policy 29:
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• Rural places are vibrant and sustainable and rural communities and businesses are supported. • A balanced and sustainable rural population. The Scottish Government’s Local Development Plan Guidance (May 2023) under it’s ‘Step by step guide’ provides advice on relevant evidence for the NPF4 policy topics to help planning authorities in considering the national planning policies when preparing their Evidence Report. With respect to NPF4 Policy 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 housing land audit, an understanding of population change over time, locally specific needs and market circumstances in rural and island area, identification of Remote Rural Areas, Strategic Housing Investment Plan, and local economic strategy. Due to the cross-over with NPF Policy 16 Quality Homes, some of the above is discussed under Appendix C1: Homes. Other relevant information suggested for consideration include information available on previously settled areas. With respect to NPF4 Policy 29, the Guidance advises that planning authorities should take into account the characteristics of rural areas within the plan area, including the existing pattern of development, pressures, environmental assets, community priorities and economic needs of each area, and identification of Remote Rural Areas. Links to Evidence: • Scottish Government Urban Rural 6-fold Classification 2020 • Perth and Kinross Housing Land Audit 2023 • NPF4 and Rural Planning – RTPI Scotland Thinkpiece • Understanding Scottish Places • Scottish Agritourism Growth Tracker 2022 • Tay Cities Region Economic Strategy 2019-2039 • Perth and Kinross Economic Wellbeing Plan 2020-2028 • NRS Small area population estimates for Scotland 2021 • The James Hutton Institute: Population projections and an introduction to economic-demographic foresight for Scotland’s sparsely populated areas (2018-43) • Scottish Government Advisory Group: Place-based policy approaches to population challenges – Lessons for Scotland • A Scotland for the future: opportunities and challenges of Scotland’s changing population • Perth and Kinross Local Housing Strategy Framework 2022-27 and Action Plan • Tay Forest National Park Evidence Report • Tayside and Central Scotland Regional Transport Strategy 2024-2034 • Perth and Kinross Mobility Strategy • Aberfeldy and surrounding area Community Housing Needs Survey July 2022 • Comrie area Community Housing and Business Needs Survey Report Nov 2022 • Highland Area Local Plan 2000 Summary of Evidence: NPF4 specifically expects the characteristics of rural areas to be identified, including the existing pattern of development, environmental assets, economic needs, pressures, and community priorities in each area. Data which helps build this picture of rural areas are set out below. Existing.and.Future.Pattern.of.Development Scottish Government’s Urban Rural Classification Section 2: Profile of the Perth and Kinross Area sets out the urban rural split in population as defined in the Scottish Government’s Urban Rural Classification. Figure 17 from Section 2 is reproduced below for reference.
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Perth City is the only settlement identified within the Other Urban Areas category. The areas extending from Perth City are classified as Accessible Rural Areas and within this Auchterarder, Kinross and Scone are identified as Accessible Small Towns. The remainder of the Perth and Kinross area is identified as Remote Rural. Within this only Blairgowrie and Crieff are identified as Remote Small Towns. All the main settlements in the Highland Perthshire area (Pitlochry, Aberfeldy and Dunkeld and Birnam) are identified as Remote Rural using the 6-fold classification. Overall, the largest percentage of the Perth and Kinross population live within areas identified as Accessible Rural (35%). Although the Remote Rural Area covers by far the largest area, only around 11% of the total population live within this area with a further 11% living in Remote Small Towns. House completions and land supply The housing land audit identifies the number of houses which have been built in each town and in each of the housing market area landward areas. The chart below shows how completions compared in the landward areas (including rural villages and smaller settlements), the rural towns located within accessible or remote rural areas (Alyth, Blairgowrie, Coupar Angus, Aberfeldy, Pitlochry, Kinross, Milnathort, Auchterarder, and Crieff), and in Perth City in the 10-year period since the adoption of LDP1 (2014 to 2023). Source: Perth and Kinross Housing Land Audit 2023 The following charts show the distribution of completions in the different areas for small sites (less than 5 units) and those on sites of 5 or more, many of which will be sites allocated in the LDP. 2104 (33%) 2202 (35%) 2062 (32%) ALL HOUSE COMPLETIONS All landward (rural) areas All rural towns Perth City
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Source: Perth and Kinross Housing Land Audit 2023 Source: Perth and Kinross Housing Land Audit 2023 These charts highlight the significant contribution which small sites make to the overall supply of new houses in the rural areas of Perth and Kinross, and the comparatively smaller share of completions on sites of 5 or more. The audit also identified the available supply of land for building new houses and this is discussed in Section 5 and Appendix C: Homes of the Evidence Report. The chart below shows how the current programmed housing land supply is split between the rural areas and towns, and Perth City. Source: Perth and Kinross Housing Land Audit 2023 Whilst total completion rates have been fairly evenly split between the landward areas, rural towns, and Perth City, nearly half of the future supply of land is in Perth city. As shown in the map below, Perth City and the immediate surrounding area has not only the largest supply of land overall, but also the largest individual sites. 766 78% 155 16% 63 6% COMPLETIONS ON SMALL SITES All landward (rural) areas All rural towns Perth City 1338 25% 2047 38% 1999 37% COMPLETIONS ON SITES OF 5+ All landward (rural areas) All rural towns Perth City 5126 (30%) 4078 (23%) 8155 (47%) TOTAL EFFECTIVE HOUSING LAND SUPPLY All landward (rural) areas All rural towns Perth City
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Location of the remaining housing land supply at 2023 by size of allocation Source: Perth and Kinross Housing Land Audit Environmental.assets Section 2: Profile of the Perth and Kinross Area sets out the principle physical and environmental characteristics of Perth and Kinross which will inform the preparation of the Proposed Plan. This includes landscape character types within the area, habitats, land capability for agriculture and forestry, and information on the extensive range of environmental designations particularly in parts of rural Perth and Kinross. Section 5 and Appendix A: Sustainable Places of the Evidence Report under biodiversity and natural places, historic assets and places, forestry, woodland and trees, and soils, and the SEA baseline will all help to build the picture of rural areas in Perth and Kinross for the purposes of meeting the expectations set out in the NPF. Environmental designations and constraints have been an issue in previous LDPs for the Highland Perthshire settlements in particular. The extent and significance of the designations in this part of Perth and Kinross have made the identification of sites for housing development challenging. This led to 10% of the housing land requirement for the Highland Perthshire Housing Market area being reallocated to the Greater Perth Housing Market Area in LDP2. Economic.needs Tay Cities Region Economic Strategy 2019-2039 The Strategy identifies strengths and opportunities, and the key issues and challenges for each of the 3 key inter-related themes: key business sectors, place: investment and infrastructure, and people: skills and employability. A key strength is that the rural economy accounts for 27% of Scotland’s overall economy. The key challenges identified for rural areas relate to poor transport and digital connectivity and the impact this has on businesses, workers and visitors. This strategy is currently being refreshed and will be available in time to inform the preparation of the proposed plan. Perth and Kinross Economic Wellbeing Plan 2020-2028 The Perth and Kinross economy had experienced growth up until the pandemic with higher-than-average employment rates, very low unemployment, and higher than the national level increases for VAT business registrations. It was highlighted that the Council and its partners would need to intervene and support recovery and growth post pandemic with a need to make a swifter transition to a digital economy, to plan for clean growth and to support businesses to become more future focused. Underlying economic challenges post-pandemic include enhancing the resilience of the rural economy. © Crown copyright [and database rights] 2024 OS AC0000805756. parties in any form.
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Programme themes for the Wellbeing Strategy include: • Enhanced connectivity with a more rapid move to full-fibre broadband, and development of more active travel options • Maximising the economic opportunities of clean growth • Planning for change in our city, town and neighbourhoods through a post covid lens This strategy is currently being refreshed and will be available in time to inform the preparation of the proposed plan. Scottish Agritourism Growth Tracker The Growth Tracker supports the sustainable development of Scottish agritourism and farm retail activity by providing the evidence base that informs the sector’s development strategy (as referred to in Section 5 and Appendix E: Productive Places of the Evidence Report under Tourism). The Tracker demonstrates that at 2022, agritourism was worth around £60m to the Scottish economy. This value was similar to pre-covid levels and demonstrates the resilience and strong appeal of the sector especially to a local / domestic market. Barriers inhibiting growth of the sector are identified. The inherent value in the sector is maximising the synergies and added value from combining agriculture, tourism, and food and drink. Central to this is the selling of onsite farm produce direct to visitors, however, only around a third of agritourism businesses at that time offered food and drink consumption onsite. Issues impacting on growth of the sector were identified as: • The planning system • Perceived high VAT levels • Concerns over the short-term lets licencing scheme • Availability of finance and grant support • Cost of living crisis • Brexit and the availability of skilled tradespeople Commuter flows Section 2: Profile of the Perth and Kinross Area sets out the principle economic characteristics of the area. To supplement this the Understanding Scottish Places website provides a range of data on the towns across Scotland. Of particular relevance to this topic is the mapping which shows commuter flows from individual settlements. A number of these maps, as they relate to the 6-fold urban rural classifications set out above, are reproduced below. Key to maps • Coloured lines/pins show the main flows that exceed 2% of this town’s population or 2000 people. • Grey lines/pins show smaller flows that still exceed 0.5% of this town’s population or 500 people. • The thickness of each line is proportional to the size of the flow (both inbound and outbound). • Flows representing less than 10 people in total are not shown. Maps are subject to the Google Terms of Service These maps clearly indicate the dominance of Perth City as the main commuter destination from all towns although there are also significant relationships between Blairgowrie and Dundee, and Kinross and Edinburgh.
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ACCESSIBLE SMALL TOWNS Auchterarder New Scone Kinross
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REMOTE SMALL TOWNS Blairgowrie Crieff
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OTHER TOWNS IN THE REMOTE RURAL AREAS Aberfeldy Dunkeld and Birnam Pitlochry
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Pressures Section 5 and Appendix E: Productive Places of the Evidence Report under Tourism identifies pressures in relation to the needs of communities, visitors, the tourism industry and the environment in Perth and Kinross and these should be read in conjunction with the following. Population Pressures Section 15(5) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to set out their views on the extent to which there are rural areas within their district in relation to which there has been a substantial decline in population. Section 2: Profile of the Perth and Kinross Area gives an overview on population in Perth and Kinross. The NRS mid-year estimates 2021 showed a 1.3% increase in population from 2020, and the population of Perth and Kinross is projected to continue to increase in the period to 2028. Although the overall picture in Perth and Kinross is one of population growth, that growth has not been evenly distributed across the Plan area. As shown in the map and table below, a number of areas within Perth and Kinross have seen a decline in population of more than 6%. This ranges from a 6% fall in the Comrie, Gilmerton and St Fillans datazone, to an 11.5% decline in the Rannoch and Aberfeldy datazone. Source: NRS Small Area Population Estimates 2021 © OpenStreetMap contributors ©
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Rural areas with a decline in population of more than -6% Datazone Percentage change 2011-21 Area type Rannoch and Aberfeldy -11.5 Remote Rural Coupar Angus and Meigle (2 datazones) -11.5% -10.7% Accessible Rural Bridge of Earn and Abernethy -7.4% Accessible Rural Guildtown, Balbeggie and St Madoes -7.3% Accessible Rural Stanley and Murthly -6.5% Accessible Rural Blair Atholl, Strathardle and Glenshee -6.1% Remote Rural Comrie, Gilmerton and St Fillans -6% Remote Rural Source: NRS Small Area Population Estimates 2021 Of the 8 datazones with a population decline of 6% or more, 3 are Remote Rural Areas. The other 5 datazones are Accessible Rural Areas showing that even in the more accessible parts of Perth and Kinross there are still pockets where the population has been in decline. Scottish Government-funded research identifies those parts of Scotland where less than 10,000 people can be reached within 30 minutes travel using roads and ferries. One of these Sparsely Populated Areas incorporates part of the Perth and Kinross area. Overall parts of the Highlands and northern Scotland (including Perth and Kinross and Stirling Sparsely Populated Area) are projected to lose between 13% and 17% of their overall populations, and more than 20% of their working age populations from 2018 to 2043 if current trends continue. Source: Population projections and an introduction to economic- demographic foresight for Scotland’s sparsely populated areas (2918-43) J Hopkins and S Piras Further Scottish Government research (Scottish Government Advisory Group: Place-based policy approaches to population challenges – Lessons for Scotland, p.4) considers how population within individual datazones
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has been changing with a view to identifying those areas with high numbers of ‘shrinking’ datazones. Generally, the sparsely populated areas, very remote rural areas, and very remote small towns are the most affected. Least affected are generally accessible rural areas. In Perth and Kinross 12 datazones are identified as shrinking. This, however, only accounts for 6.5% of all datazones in the area and 5.5% of the overall population meaning that across Scotland Perth and Kinross ranks 29th both in terms of percentage of the number and population living within shrinking datazones. The Scottish Government identifies three population challenges which population projections for Scotland highlight: • Maintaining a sustainable total population size • Maintaining sustainable age structures within the population • Maintaining a sustainable spatial balance of population across urban, rural and remote locations Issues relating to these challenges include: • Population growth over the next 20 years is projected to come from inward migration. • The ending of freedom of movement could lead to a reduction in the working age population of Scotland of between 3% and 5%. • Life expectancy has been increasing and the birth rate declining so Scotland’s population overall is ageing. This means that that the proportion of the non-working age population is projected to increase dramatically over the coming decades to 22.9% by mid- 2043. Furthermore, the number of people aged 90+ is anticipated to double between 2019 and 2043. • Without more working age people pressure on fiscal sustainability, tax revenues, public services and welfare will increase. Housing Pressures The Local Housing Strategy includes a profile for rural housing in Perth and Kinross. Key facts include: • 47% of the Perth and Kinross population live in rural areas • 86% of dwellings in rural areas are houses or bungalows compared to 76% in urban areas • 30% of rural dwellings were built before 1919 compared to 25% in urban areas • 57% of homes in rural areas are off gas grid compared to 36% in urban areas • 26% of households in the Highland Housing Market Area live in the private rented sector • 44% of all affordable houses in Perth and Kinross are located in rural areas • There are roughly 5 applicants for every affordable house which becomes available in rural areas of Perth and Kinross • In 2021 second homes and holiday lets accounted for 3% of the housing stock in Perth and Kinross but 12% in Pitlochry, 18% in Aberfeldy and almost 40% in Kinloch Rannoch Tacking housing induced poverty is identified as a particular challenge in rural areas. This is driven by poorly paid local employment, cost of living pressures, and high housing costs. Access to affordable housing options is also identified as being severely limited in many rural areas of Perth and Kinross. The LHS Action Plan seeks to maintain a 53% / 47% split in affordable completions across urban and rural areas. The RTPI Thinkpiece highlights a number of issues in relation to the delivery of affordable housing in rural areas that both reflects the diverse housing needs of communities and supports quality placemaking: • Securing high proportions of developer contributions for affordable housing is difficult in rural areas due to higher construction costs. • Concentrated patterns of land ownership in rural areas can increase land prices, slow development and reduce the quality of placemaking.
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• The need for housing in rural areas must be balanced against the need to direct development to sustainable locations which usually means the key settlements. • The need to discourage loss of housing stock to second homes. These are all issues relevant to the rural areas of Perth and Kinross. In addition to the Perth and Kinross wide Housing Needs and Demand Assessment (which is considered under Section 5 and Appendix C: Homes of the Evidence Report), a number of local needs assessments have been carried out in rural communities in Perth and Kinross. Examples include the Aberfeldy and surrounding area Community Housing Needs Survey in July 2022, and the Comrie area Community Housing and Business Needs Survey Report in Nov 2022. A key conclusion of both these is that there is high demand for new housing from existing residents, people wishing to relocate into the area, and to support businesses. A particular issue in rural areas of Perth and Kinross is the demand for self- build opportunities. This is considered in Section 5 and Appendix C: Homes of the Evidence Report but of relevance to this issue is that demand is spread across the whole of Perth and Kinross, including in many of the rural postcode areas. Natural and Historic Environment Pressures In preparing the bid for the Tay Forest National Park submission, key pressures and challenges being faced as a result of tourism and visitor management in that specific part of Perth and Kinross were highlighted as follows. Protection, recovery and restoration of the areas’ natural assets – pressures and challenges identified included: climate change, invasive non- native species and disease, overgrazing, habitat fragmentation, afforestation, recreational pressures, water abstraction, water pollution, peatland destruction, wildlife crime, and a lack of knowledge. Conservation and enhancement of the area’s cultural heritage / historic environment assets – pressures and challenges identified included: climate change causing more extreme weather events, development pressures, visitor pressures / damage, and declining intergenerational knowledge. These are exacerbated by increased maintenance costs along with an overall decline in funding for heritage management. Sustainable use of the area’s natural resources – pressures and challenges identified included: • Agriculture is facing ecosystem pressures such as overgrazing, fragmentation of habitats and the effects of climate change. • Sporting activities such as shooting and fishing are facing pressures from climate change, and policy changes e.g. relating to land management and fishing regulations. Socio-economic Pressures The Tay Forest National Park submission also identified economic and social development and wellbeing pressures and challenges. Issues identified include: • Social isolation – 30.5% of dwellings in the Highland and Strathtay area are occupied by one adult many of which are elderly people • Availability and deliverability of social care – due partly to the limited supply of affordable housing and also the challenges associated with providing health and social care services to those in the most remote and rural areas • Poor access to services and facilities – large areas of the proposed National Park area rank in the top 10% most deprived SIMD areas in terms of geographic access, particularly in areas outwith the main settlements • Overdependence on poorer paying employment sectors such as hospitality, retail and agriculture • Need for support for existing local businesses and new job creation
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• Local housing affordability and housing options – a lack of affordable housing resulting in people moving out of the area, and a lack of downsizing options • Public transport accessibility Many of these issues are also relevant in other parts of rural Perth and Kinross. The Regional Transport Strategy for Tayside and Central Scotland identifies the strategic transport priorities for the Angus, Dundee City, Perth and Kinross, and Stirling Council areas. Key issues identified in the Strategy include: • Nature of the region and the urban / rural split – 37% of the region live in rural areas, 67.3% of people in Perth and Kinross, many of whom are dependent on strategic routes to access jobs, services and healthcare • Transport and the consequences or rural hinterlands – 79% of trips to work in Perth and Kinross are made by car, and Angus, Perth and Kinross, and Stirling all have higher per capital transport CO2 emissions compared to the Scottish average • Social inclusion and rural isolation – 20.4% of Perth and Kinross data zones are in the 10% most access deprived geographies as defined in the SMID In delivering the Strategy and providing an alternative to the car, there is a need to work together to provide integrated solutions across all stages of the non-car journey. In rural areas residents often have to travel further for services increasing costs and limiting opportunities. Most rural areas within the region are popular tourist destinations helping contribute to the higher transport CO2 emissions. Low population densities mean it is difficult to provide extensive and regular public transport and so many residents and visitors rely on the car to travel to, from and between rural areas. Not all households, however, have access to a car. To help people access services and reduce car kilometres there is a need to enable people to access interchange points, and improve bus, coach and train services between centres. More services also need to be provided locally. A specific action is identified in the Strategy for planning authorities to reduce the car dependency of new developments by: • Development plans promoting land use travel patterns that reduce the need to travel and enable travel by sustainable modes, and • The development management process ensuring that new development is realistically accessible by a range of modes A new Mobility Strategy (previously known as a local transport strategy) for Perth and Kinross was approved by the Climate Change and Sustainability Committee on 23 Oct 2024. Transport Planning Objectives include: • To improve the ability of rural communities and communities with protected characteristics to access jobs, education and services • To reduce CO2 emissions produced by transport across Perth and Kinross by reducing car kilometres, decarbonising motorised transport and increasing the share of everyday journeys of people and goods by sustainable and active travel modes • To support local development that encourages and facilitates local living and sustainable access across Perth and Kinross by achieving an increased active travel and public transport mode split to and from new developments • To improve labour market access through sustainable transport, active travel and digital opportunities to and from Perth and Kinross. Fuel poverty is identified as an issue in addressing the LHS priority to deliver quality homes with affordable warmth, zero emissions and SMART technology. 28% of households in Perth and Kinross are estimated to be fuel poor compared with 24% in Scotland. 18% of households are estimated to be in extreme fuel poverty compared to 12% nationally. The
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high proportion of households in Perth and Kinross living in rural areas is identified as a particular issue as many households have no access to the gas grid and many properties in rural locations are older and more difficult to install energy efficiency improvements. The average annual fuel bill in Perth and Kinross was estimated to be 17% higher than the Scottish average. Community.Priorities Much of the data sources identified below will also feed into the other characteristics discussed in the sections above. Big Place Conversation Issues and priorities in rural areas identified through the BPC Place Standard discussions included: • Public transport – community bus-led services a positive asset for rural areas but limited coverage of public transport generally. • Natural spaces – Strong biodiversity thrives across both rural and urban settings, but some areas have poor access to nature despite their rural surroundings which requires residents to drive to access natural spaces. • Play and recreation – very limited facilities and organised activities in rural communities, including indoor facilities and activities, often requiring travel by car to access formal opportunities. • Facilities and services – travel necessary to access shops and services for some rural communities although many appreciate the value of mobile services including libraries. The need to travel to bigger settlements which can limit access, and the lack of secondary schools in rural areas were identified as particular issues by children and young people. A need identified to develop rural hubs to deliver essential services or develop more facilities to accommodate growth. • Work and local economy – access to workplaces in some rural areas adversely affected by transport issues, especially in the evening. • Housing and community – a significant lack of housing in some rural communities to meet a wide range of needs, including affordable housing, which results in young people moving away. A need identified in some rural areas to protect housing for local people / workers. • Social interaction – village halls identified as important for rural communities there are fewer venues for meeting up. A need to improve outreach for rural communities with public transport and active travel opportunities identified. Local Action Plans, Community Action Plans and Local Place Plans The Local Living and 20-minute Neighbourhoods section identifies the LAPs which cover Perth and Kinross, and the 11 CAPs which cover the rural Perthshire areas of: Meigle and Ardler, Stanley, Alyth, Coupar Angus, Dunkeld and Birnam, Crieff, Blairgowrie and Rattray, Pitlochry and Moulin, Muthill and Tullibardine, Auchterarder and Aberuthven, and St Fillians. A CAP is also in development for Comrie. The Local Living and 20-minute Neighbourhoods section includes links to all these plans and sets out their purpose. Of particular relevance to this topic paper is that CAPs focus in part on identifying priorities and actions needed to enhance a place. Also highlighted in Section 5 and Appendix B: Liveable Places under Local Living and 20 Minute Neighbourhoods is that an invitation has been extended to community bodies to prepare an LPP for their area. Allocating.land.for.the.purposes.of.resettlement Section 15(5) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to set out their views on the desirability of allocating land for the purposes of resettlement. A significant proportion of Perth and Kinross is identified as Remote Rural under the Scottish Government’s 6-fold Urban-Rural Classification.
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There are a number of areas within Perth and Kinross where there has been a significant decline in population. This is particularly prominent in the most remote areas of Highland Perthshire. In an effort to address this, previous Local Plans for the Highland Perthshire area designated ‘Development Zones’ where the Council’s general policy on housing in the countryside was relaxed in favour of individual houses. The success of the Development Zone approach was mixed, however, with some zones experiencing little development whilst others attracted some highly prominent houses, almost to the extent of suburban sprawl to the south of Pitlochry. Summary of Implications for the Proposed Plan: Identification of a spatial strategy for rural areas NPF requires the LDP to set out an appropriate approach to development in rural areas which reflects the identified characteristics including the existing pattern of development, pressures, environmental assets, community priorities, and economic needs. The key will be balancing the need for development to sustain rural areas and encourage growth, against directing the majority of growth to the most sustainable locations whilst protecting the most environmentally sensitive areas. The spatial strategy for the Proposed Plan will therefore have to include an appropriate tailored approach for rural areas which considers how to distribute the land supply requirements for housing, employment uses etc, against the requirement to reduce the need to travel and avoid suburbanisation of rural communities, particularly in rural areas which are currently declining and those rural populations which are most at risk of transport poverty. This will need to draw on information from a number of other issues in the Evidence Report including, in particular, on Local Living and 20 Minute Neighbourhoods (Section 5 and Appendix B: Liveable Places). This could include identification of those small towns and villages within rural areas which have good accessibility to public transport, or identification of those areas where additional development, whilst perhaps not in itself delivering new or improved facilities, can help to sustain existing facilities, services and infrastructure especially in areas where they are underutilised. The housing land requirement for LDP2 was set by the strategic development plan, TAYplan which allowed a percentage of the requirement in a housing market area to be reallocated to another area where there were ‘serious cases of appropriately evidenced environmental or infrastructure capacity constraints’ (TAYplan, policy 4). For the Highland Perthshire area specifically, this was up to 15% and 10% in other areas. The Minimum All-Tenure Housing Land Requirement set by NPF4 is for the whole of Perth and Kinross. There is no longer a requirement to split this by housing market area in new LDPs. This potentially gives more flexibility in the distribution of the housing land supply in the Proposed Plan. In relation to the allocation of land for resettlement, there are no specific areas which stand out as being suitable for, or where it would be particularly appropriate to, allocate land for this purpose in Perth and
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Kinross. It is not therefore anticipated that this will feature as part of the Proposed Plan spatial strategy. Efforts were made through the Topic Paper consultation to engage with some of the existing landowners and estates in Perth and Kinross. Only one response was received with comments on this issue. Further consideration will therefore need to be given as to how to consider the needs and long- term plans of landowners in developing both the spatial strategy and policy framework for rural areas in the proposed plan. Consideration will need to be given as to how best to bring all the abovementioned information together. This could incorporate the overlaying of some data layers spatially, for example, environmental assets, existing patterns of development, and possibly development pressures, similar to the approach taken by Moray Council in their Evidence Report section 15. Rural Development. Bringing together the data in a comprehensive way to inform the preparation of the spatial strategy will also be informed by the SEA for the Proposed Plan. Local policy response to NPF4 policy NPF4 policy 17 indicates that, where relevant, LDPs should include proposals for future population growth. This includes provision for small scale housing. LDP2’s existing Housing in the Countryside policy and associated supplementary guidance currently supports new houses in open countryside where a house is essential on animal welfare grounds. To date, the Council has generally not supported proposals on other grounds, for example, woodland management. The Proposed Plan will need to consider whether a more flexible and / or innovative approach to housing delivery, particularly affordable housing, and increasing the resilience of rural areas (especially remote rural areas) would be appropriate in light of the support in NPF. For example, design codes linked to self and custom build housing, or the opportunities for innovative approaches in responding to climate change. In this respect local level policy may be appropriate to provide a Perth and Kinross- specific interpretation of NPF policy. As abovementioned, previous Local Plans for the Highland Perthshire area designated ‘Development Zones’ in certain areas to encourage small-scale housing developments. The lessons learnt from this approach will also help inform any local policy response. Gaps?.Uncertainties.or.Key.Issues.Raised¿ Local Place Plans Whilst the Council has received some expressions of interest from community bodies, no LPPs have yet been registered. There is, therefore, a potential issue in aligning the timescales for the preparation of LPPs and the Proposed Plan. Work is programmed to begin in early 2025 on preparing the Proposed Plan. Realistically, therefore, LPPs will need be registered by Spring 2025 if they are to have the best opportunity to influence the Plan. It is not known, however, how realistic this timescale will be for community bodies. Summary of Stakeholder Engagement: Big.Place.Conversation. The Council carried out its ‘Big Place Conversation’ exercise to kick start the LDP3 process across Perth and Kinross communities during most of 2023. This was a substantial exercise involving over 100 events throughout the Council area. The events ranged from drop-in information sessions, meetings, and online surveys to workshops and online sessions using the Place Standard Tool to capture the views of local communities about different aspects of their places. The results of the BPC are summarised as part of a separate report on the outcomes and findings across the different locality areas. LDP9.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
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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: Scottish Land and Estates, Rural Housing Scotland, and the Scottish Rural Network.
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Statements of Agreement/ Dispute 12 responses were received on our Rural Development and Homes Topic Paper. Just over half of respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 028, and the summary of the implications of that evidence for the Proposed Plan provided by the 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 Rural Development and 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 Nature Scot Not stated List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: It is useful to see the key policy connections. It would be worth expanding this list to include all relevant policies as listed under policy 17 of NPF4. We welcome the consideration of landscape under 2.2 Environmental Assets. Formal Dispute: No Agreed. The full list of policies is now included. Tactran Not stated List of Evidence/Datasets: The paper makes reference to Perth and Kinross Council’s Draft Mobility Strategy and the respective transport planning objectives. Tactran notes that it is a requirement for Councils to perform their functions as they relate to transport consistently with the respective Regional Transport Strategy. It is worth noting that the RTS suggests that reducing the car dependency of new developments (Action1) may be achieved by the development management process “ensuring new development is realistically accessible by a range of modes”. Tactran further refers to its comments in relation to the principles established by the RTS, especially with regard to the need to provide integrated solutions to provide a realistic alternative to the car and encourage the required mode shift whiles recognising the different circumstances and The Regional Transport Strategy has been included as evidence to inform the LDP3 Proposed Plan, and Tactran’s comments have helped inform the Summary of Implications for the Proposed Plan section of the Evidence Report.
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Respondent Agree or Dispute Summary of Comments PKC’s Response opportunities as they relate to the rural and urban populations across the region. Summary of Implications for Proposed Plan (PP): Rural populations are at the highest risk of transport poverty. New development should consider ensuring a realistic choice of travel to reduce the risk of new development increasing the scale of the problem of transport poverty. Formal Dispute: No Scottish Water Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: Scottish Water acknowledges the contents of Topic Paper No. 28: Rural Development and Homes and recognises the importance of supporting sustainable rural communities to thrive and develop in line with set out policy. The issue of water and wastewater infrastructure serving rural expansions should be considered carefully when considering new areas for allocation, either for domestic or non-domestic purposes. Scottish Water will continue to work closely with all parties, including Perth and Kinross Council, to input our availability of public infrastructure and its capacities when consulted on specific site proposals. However, in many scenarios, there may not be Scottish Water owned public water and/or wastewater infrastructure in locations and this should be considered as early as possible. Indeed, where Scottish Water do have assets serving existing rural communities, these may require capital investment to accommodate increasing growth from new connections. Scottish Water is funded to provide this increased growth to meet domestic demands, but we require early engagement. Infrastructure capacity will be one of many factors considered in identifying the areas for future development and the allocation of specific sites in the Proposed Plan. Scottish Water’s comments are noted and their commitment to continued collaborative working during the consideration of site allocations for the Proposed Plan is welcomed.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: No Earn Community Council Agree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: Transport, education, employment and services need to be maintained and enhanced in order to maintain population in rural areas. Question whether there should be an increase in affordable homes in rural areas if there is a lack of sustainable transport, employment and vital services for the less well off or elderly. The average age of the population is rising (estimated to double for the 90year old + by 2043) and the percentage of people of working age is dropping meaning pressure on tax, public services and welfare. Bridge of Earn and surrounding area had very little mention in previous studies carried out, or as an area of particular concern or interest. It may be seen as a satellite to Perth and not rural, with rural priorities. It is within the accessible rural area. Formal Dispute: No Earn Community Council’s comments have helped inform the Summary of Evidence section of the Report. The availability of existing services and infrastructure to meet the needs of the community will be one of many factors considered in identifying the areas for future development and the allocation of specific sites in the Proposed Plan. Other comments are noted. Errol Community Council Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Formal Dispute: No No action required Private individual Neither List of Evidence/Datasets: No comments Summary of Implications for Proposed Plan (PP): The Local Place Plans have not been widely publicised Comments on LPPs are noted. Socio-economic issues, including access to transport, are
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Respondent Agree or Dispute Summary of Comments PKC’s Response Public transport is being reduced by Stagecoach and not much effort by PKC to ensure that the transport meets social needs as well as business needs. Formal Dispute: No considered in the Evidence Report. Homes for Scotland Disagree, but does not wish to register as a formal dispute List of Evidence/Datasets: 1. The Topic Paper states that the Council considers there to be a need for further data on housing system pressures in Perth and Kinross and that research to address this data gap is currently underway. This research must be available for review prior to the submission of the Evidence Report to the Gate Check process. 2. The Existing Housing Need in Perth and Kinross report, commissioned by Homes for Scotland (HFS), and shared with the Council earlier this year, must be considered. To support the Evidence Report, primary survey data of unmet housing need, has been completed and shared with the Council. This survey carried out by Rettie and the Diffley Partnership provides detail of key housing market drivers and housing stock profiles. Summary of Implications for Proposed Plan (PP): 3. It is important to recognise that whilst new development in rural areas may not be of a scale to deliver improvements to local facilities, services and infrastructure, it can help sustain existing services where changes in demographics mean that they are underutilised. New homes can make a positive contribution to local living. The socio-economic benefits of home building cannot be understated. Further Comments: 4. Further and more detailed commentary regarding the Local Housing Land Requirement (LHLR) and associated matters is set out in our response to the Homes Topic Paper. Formal Dispute: No 1. This data was published on the Council’s website on 21 August 2023 and Homes for Scotland informed. 2. The Diffley report is considered in Section 5 and Appendix C: Homes of the Evidence Report. 3. Homes for Scotland’s comments have helped inform the Summary of Implications for the Proposed Plan section of the Evidence Report. 4. Noted
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Respondent Agree or Dispute Summary of Comments PKC’s Response Savills on behalf of Scone Estate Not stated List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: Note that work on identifying 20-minute neighbourhoods has not yet commenced. It must be remembered that PKC is predominantly rural, and that work should be done to increase resilience of settlements via innovative means to deliver critical Local Living focused services, as opposed to blanket restrictions on development based on current services. The sustainability of rural areas is dependent on population growth. People will be needed to live on the land managing it for sustainable outcomes. Lack of local housing in rural areas is driven by restrictive planning policies and weak markets with limited housebuilder activity. Planning policies should seek to be supportive of housing in rural areas as the market and availability of builders form their own deterrent to any proliferation of rural housing. Provision of homes is an essential element of Scone Estates business. More can be done, and there is significant demand, but this needs to be balanced with the ability to sell small and medium-scale housing sites to raise revenues for rural businesses which can then be re-invested in the environment and economy of Perth and Kinross. There is good potential for new housing north and northeast of Perth to fully use the CTLR and the active travel connections it brings. There are also opportunities to improve placemaking and resilience of areas such as Stormontfield. Formal Dispute: Savills on behalf of Scone Estate wish to formally dispute this issue on the grounds that the assessment of Self and Custom Build demand/need should use broader data sources and not just rely on historic planning consents. Comments have helped inform the Summary of Implications for the Proposed Plan section of the Evidence Report. Comments relating to specific locations / areas are considered under Place Based Comments. Conclusion on dispute: Given that the dispute relates to self-build data which is addressed in Section 5 and Appendix C: Homes of the Evidence Report (and under which Savills have raised the same dispute), this is not being considered as a formal dispute under the Rural Development issue. Savills on behalf of Scone Estate Not stated List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments These comments were originally made in relation to the Plan Area
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Respondent Agree or Dispute Summary of Comments PKC’s Response Further Comments: Table 1 of Topic Paper 001 shows historic land use within Perth and Kinross, with 45.5km2 in the “built up” area, which rural settlements account for just 4.3Km2 of – indicating, in their view, the centralisation of PKC and a lack of support for growth in rural settlements and housing clusters despite its significant land area and rural hinterland. Scone Estates considers that data on population densities across PKC should be analysed to show the need to revitalise rural areas with supportive planning policies and generous housing allocations. The PKC area seems to have a population density of 27 people per Km2, while the Scottish average is 67 people/km2. They highlight that other local authority areas with broadly similar characteristics to PKC all have higher population densities, some significantly so. https://www.undiscoveredscotland.co.uk/usfeatures/areas/councilareas.html is suggested as a source of information on population densities. These findings clearly show that one challenge to PKC in drafting its LDP policies is the need to address rural depopulation and an unevenly spread population density which may be pointing to poor planning policy support for rural areas as one factor. Formal Dispute: Savills on behalf of Scone Estate wish to formally dispute this issue on the grounds that the Council must consider data sources regarding population to support growth in rural settlements and housing clusters to revitalise rural areas with supportive planning policies and generous housing allocations. Topic Paper, but it was considered more appropriate to consider them in the context of the Rural Development section. The population density data quoted in the suggested website dates from 2014. More recent population data is available (NRS mid-year estimates and Small Area Population Estimates 2021) and this has been referenced under ‘Population Pressures’. The towns and villages of Perth and Kinross vary significantly in terms of population density. Rather than focus on a single population density figure for the whole area it is considered more appropriate to take a holistic view of population issues as set out in the Summary of Evidence and the Summary of Implications for the Proposed Plan sections of the Evidence Report. Conclusion on dispute: It is considered that the grounds of dispute have been addressed and / or incorporated into the Evidence Report and the dispute is therefore resolved.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Montagu Evans LLP on behalf of Loch Developments Ltd Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Formal Dispute: No No action required Andrew McCafferty Associates Disagree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): 1. There is a need to undertake a more fine-grained analysis of completions of new dwellings and supply in rural areas over the last two LDPs to establish where completions have been distributed and where supply / allocated sites have remained undeveloped. Suggest the analysis should reveal the number/scale of completions separately within "All landward (rural) areas" and "All rural towns" to understand the spatial distribution of historic demand, evidenced by completions, and remaining allocated opportunity sites. The data should be separated into isolated/individual units in open countryside; houses in "small towns"; and houses in "villages". 2. The number of completions on allocated sites should be identified, as should the reasons for non-development of allocated sites. 3. The percentage figure is missing for "Perth City" in the pie chart of housing completions. 4. It appears that the percentage share of housing land supply sites in Perth City as at HLA 2023 is almost 50% of the total supply whereas the house completions at 2023 show over 70% in "landward (rural) areas" together with "all rural towns". This points towards a need for a continued supply of new allocations in these rural areas. 5. There is a need to identify small towns and villages within the "landward (rural) areas" which have good accessibility to public transport. 1. The housing land audit only records sites of 5 units or more so completions on smaller sites are not individually recorded. The smallest sites (generally less than 14 units) are not identified in LDP2 as allocations. It is not therefore possible to break this analysis down as suggested. The housing land audit does, however, record completions on small sites separately and this analysis has been included in the Evidence Report. A description of what is included within the ‘landward’ and ‘rural towns’ categories has also been included to improve clarity. 2. As for small sites, an additional chart has been added separating out the allocated sites in the same way. The reasons for non- development of allocated sites
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: Andrew McCafferty Associates wish to formally dispute this issue on the following grounds: More fine-grained analysis of up-to-date completions and land supply data is required for the rural areas to understand where demand has been met and where allocations have not been delivered. There is a need for a continued supply of new allocations in rural areas and a review of historic allocations which have not been delivered. A more fine-grained analysis of the HLA 2023 or, if available, the HLA 2024 should be undertaken to establish trends in housing completions in the rural areas in order to inform the Evidence Report. are considered in Section 5 and Appendix C: Homes of the Evidence Report. 3. Corrected 4. The supply of existing allocations in rural areas will be dependent on the LDP spatial strategy. The existing Perth City land supply is largely made up of long-term strategic sites which will provide a supply of land well beyond the plan period, and for much longer than is currently planned for in other areas. The LDP Guidance indicates that Plans should provide an ‘indication of the place in 20 years’ time…and that for the longer term (beyond 10 years) the plan may identify broad areas with potential for development’ (para. 145). This may have an impact on the distribution of the longer-term supply in LDP3. 5. The Evidence Report defines areas according to their category in the Scottish
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Respondent Agree or Dispute Summary of Comments PKC’s Response Government’s urban – rural classification. This does not specifically include access to public transport but rather categorises areas by population and the length of drive time from larger areas of population. That said, accessibility to public transport could be a consideration in identifying the spatial strategy for rural areas and this has therefore been incorporated into the Summary of Implications for the Proposed Plan section of the Evidence Report. Conclusion on dispute: It is considered that each of the grounds of dispute have been addressed and / or incorporated into the Evidence Report and the dispute is therefore resolved. Ristol Consulting Disagree, but does not wish to register as a formal dispute List of Evidence/Datasets: No comments Summary of Implications for Proposed Plan (PP): Within rural areas would welcome exploring a policy framework to accelerate the delivery of affordable, sustainable homes. The impact the shortage in such homes is having on rural communities and business is significant, adversely affecting lives and businesses, and new policies which set out a pathway for securing permission swiftly could materially improve the Comments have helped inform the Summary of Implications for the Proposed Plan section of the Evidence Report. Some comments have also been raised and responded to under
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Respondent Agree or Dispute Summary of Comments PKC’s Response situation. The policy scope could cover the spatial direction or policy requirements (or both - perhaps through a masterplan consent area approach), design codes linked to custom and self-build housing and the role of local energy neighbourhood and a mobility hub, consistent with the intent and outcome of NPF policies 16, 17 and 18. Perthshire is incredibly well placed to deliver an innovation led agenda to the just transition for climate adaptation. This will open up the potential for new forms of land use change that could challenge (positively) previous approaches. Within the context of new rural housing and development this could create opportunities to locate new rural homes in more sensitive landscapes and settings than previously considered. Examples may be within sensitive woodland which through elevated foundations and materials enable local people or businesses to continue to locate/remain within their communities. Would welcome a policy approach that enables this necessary flexibility to unlock innovation to deliver sustainable land use change over the 10-year plan period. Continued support for rural business diversification as set out in LDP policy 8 & NPF policy 29. 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 other issues in the Evidence Report.
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Meeting the requirements of the Act: The Act sets out a number of requirements which local authorities have to set out in the preparation of their Evidence Report. Allocation of Land for the Purposes of Resettlement Part 2, Section 16B(3) and Section 15(5)(cc) of the Planning Act 2019 requires planning authorities, in the preparation of their Evidence Report, to set out their views on the desirability of allocating land for the purposes of resettlement. A significant proportion of Perth and Kinross is identified as Remote Rural under the Scottish Government’s 6-fold Urban-Rural Classification. There are also a number of areas within Perth and Kinross where there has been a significant decline in population. This is particularly prominent in the most remote areas of Highland Perthshire. There are no specific areas, however, which stand out as being suitable for, or where it would be particularly appropriate to, allocate land for the purposes of resettlement as part of the spatial strategy in the Proposed Plan.
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Issue: Tourism Corresponding NPF4 policy: • National Planning Framework, Policy 30: Tourism • 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; 10: Coastal Development; 13: Sustainable transport; 14: Design, quality and place; 16: Quality homes; 17: Rural homes; 23: Health and safety; 25: Community wealth building; 27: City, town, local and commercial centres; 28: Retail; 29: Rural development; 31: Culture and Creativity. Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 029: Tourism https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume nts/TP029_Tourism.pdf Information required by the Act and NPF4 regarding the topic: Section 15(5) of the Town and Country Planning (Scotland) Act 1997, as amended: • the principal physical, cultural, economic, social, built heritage and environmental characteristics of the district; and • the principal purposes for which the land is used. Under Policy 30 NPF4 expects Local Development Plans to: • Support the recovery, growth and long-term resilience of the tourism sector. • Include a spatial strategy identifying suitable locations which reflect opportunities for tourism development by taking full account of the needs of communities, visitors, the industry and the environment. • Include a spatial strategy which identifies areas of pressure where existing tourism provision is having adverse impacts on the environment or the quality of life and health and wellbeing of local communities, and where further development is not appropriate. Policy intent for Policy 30: • To encourage, promote and facilitate sustainable tourism development which benefits local people, is consistent with our net zero and nature commitments, and inspires people to visit Scotland. Policy outcomes for Policy 30: • Communities and places enjoy economic, social and cultural benefits from tourism, supporting resilience and stimulating job creation. The Scottish Government’s Local Development Plan Guidance (May 2023) under it’s ‘Step by step guide’ provides advice on relevant evidence for the NPF4 policy topics to help planning authorities in considering the national planning policies when preparing their Evidence Report. With respect to NPF4 Policy 30, the Guidance advises that planning authorities should take into account the needs of communities, visitors, the industry and the environment, and any areas of pressure where existing tourism provision is having adverse impacts on the environment or the quality of life and health and wellbeing of local communities. Other relevant information suggested for consideration include relevant local sector driven tourism strategies. Links to Evidence: • Visit Scotland’s Insight on Tourism in Perthshire • Perth and Kinross STEAM Tourism Economic Impacts Report and Summary for 2012-2023
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• Scotland Outlook 2030 Responsible Tourism for a Sustainable Future • Historic Environment Scotland: Responsible Tourism Framework – Transforming Heritage Tourism, 2023 • Scottish Agritourism – A Strategy for Sustainable Growth • Tay Cities Region Deal • Tay Cities Region Tourism Strategy 2019-2024 • Tay Cities Region Economic Strategy 2019-2039 • Perth and Kinross Economic Wellbeing Plan 2020-2028 • Perthshire Tourism Action Plan 2021-2025 • Visit Scotland Visitor Management Plan • Visitor Management in Rural Areas Report to Environment and Infrastructure Committee 28 Oct 2020 • Short-term Let Control Area: Proposals for Consultation Report to Environment, Infrastructure and Economic Development Committee 31 May 2023 • Scottish Tourism Alliance Recovery of Scotland’s Tourism Sector Key Findings • ASSC Survey: The Impact of Scottish Government Regulations on Business • Tay Forest National Park Evidence Report and map of draft indicative boundary Summary of Evidence: Tourism in Perth and Kinross Visit Scotland Insight on Tourism in Perthshire Visit Scotland publish on their website an insight on tourism in Perthshire which comes from a range of sources including tourism monitors, national statistics, and commission research The key statistics for overnight tourism in Perthshire are: • 690,000 total overnight visits by International and domestic visitors in 2023 • 2.35m nights spent in accommodations by domestic and international visitors in 2023 • total spend by international and domestic visitors in 2023 was £210m with an average overnight visitor spend of £305 Visit Scotland commissioned the Scotland Visitor Survey in 2023 to gather insight on visitor attitudes and behaviours. The survey explores all aspects of the visitor experience in Scotland and can be broken down into specific areas. Profiles are available for Perthshire and Perth City. For Perthshire: • 68% of visitors came from Scotland or the rest of the UK and 32% were international • Visitors spent an average of 3.6 nights in Perthshire • 47% of visitors stayed in serviced accommodation and 55% in non- serviced (some visitors stayed in more than one accommodation type) • The top attractions or activities undertaken in Perthshire were shopping (43%), visiting a castle or fort (35%), visiting a historic house, palace, stately home (34%), view architecture and buildings (32%), hill walk, mountaineering, hike or ramble-guided or self- guided (30%) For Perth: • 57% of visitors came from Scotland or the rest of the UK and 43% were international • Visitors spent an average of 2.7 nights in Perth • 70% of visitors stayed in serviced accommodation and 31% in non- serviced (some visitors stayed in more than one accommodation type) • The top attractions or activities undertaken in Perth were visiting a historic house, palace, stately home (42%), shopping (35%), visited a castle or fort (31%), view architecture and buildings (31%), visiting a cathedral, church, abbey or other place of worship (29%)
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Perth and Kinross STEAM Report and Summary STEAM is a tourism economic impact modelling process by Global Tourism Solutions which quantifies the local economic impact of tourism, from both staying and day visitors, through analysis and use of variety of inputs including visitor attraction numbers, tourist accommodation bedstock, events attendance, occupancy levels, accommodation tariffs, macroeconomic factors, visitor expenditure levels, transport use levels and tourism-specific economic multipliers. The 2023 statistics for Perth and Kinross show the following. Note the figures in brackets show change from 2022: • 2.3m tourism visits (up 15%) • 1.5m visits by visitors staying in the area (up 12%) • 4.9m visitor days and nights generated (up 1.5%) • Average stay of 2.7 nights (down from 3.1) • £165m spent on local accommodation (down 4.5%) • 0.8m tourism visits by day visitors (up 21%) • £703m generated directly and indirectly within the local economy (up 8.8%) • £62m generated from day visits (up 37%) • £641m economic impact from staying visitors (up 7%) • More than 8,200 full time equivalent jobs generally locally (up 1%) The 2019-2023 trends for Perth and Kinross were: • +9% economic impact • Staying visitor numbers returned to pre-covid levels • -9% total visitor days and nights In 2023, 1.5m visitors stayed in accommodation within the area. Visitor numbers staying in serviced accommodation increased by 18% over the year and is now 3% above pre-covid 2019 figures. Visitors staying in non- serviced accommodation grew 7% over the year and is now -6% below pre- covid levels. The day visitor sector grew by 21% in 2023 but is still -11.5% below pre-covid levels. Accommodation type 2023 Establishments 2023 Beds Change in Establishments 2022 - 2023 Change in Beds 2022 - 2023 Change in Establishments 2012 - 2023 Change in Beds 2012 - 2023 +50 rooms 17 3,703 +1 +314 -2 -192 26-50 rooms 16 1,214 0 0 -4 -257 <26 rooms 77 1,514 +10 +73 -59 -453 Guest houses / B&Bs 55 796 -7 -74 -79 -773 Total serviced accommodation 165 7,227 +4 +313 -144 -1,675 Self catering 244 8,075 -38 -314 -125 +583 Touring / camping 48 5,637 -1 -699 +19 +1,443 Total non- serviced accommodation 292 13,712 -39 -1,013 -106 +2,026 Source: STEAM report for 2012-2023
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LDP2 Tourism sites LDP2 identifies those areas which are currently in tourism use. © Crown copyright [and database rights] 2024 OS AC0000805756.
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National Parks Parts of the Perth and Kinross Council area fall within the two existing National Parks. A small area at St Fillians falls within the Loch Lomonds and the Trossachs National Park. A larger area of northern Perthshire falls within the Cairngorms National Park. Tourism is vital to Scotland’s National Parks. In the Cairngorms, for example, tourism accounts for 30% of the economy and 43% of employment. Strategies relating to Tourism Scotland Outlook 2030 Responsible Tourism for a Sustainable Future The national tourism recovery programme recognises that the role of tourism has changed as a result of the climate crisis, advances in technology, the exit from the European Union, and changes in consumer behaviour. It sets out a vision of 21st century tourism as an industry which ‘can and will benefit every person who lives in Scotland, visits Scotland and works in Scotland’. Key factors which will influence the long-term growth, development and success of the tourism industry are identified as: • Our Environment – tourism has contributed to the climate emergency and has become vulnerable as a result. Action is needed now to halt further decline, reverse damage and bring about long- term change. • Impact of technology – the use of technology impacts on every aspect of tourism and results in a greater need for all businesses across Scotland to be better connected digitally. • Tomorrow’s traveller – changes in technology, society and consumer behaviour have resulted in new attitudes including an increase in ethical travel with people making decisions based on conscience and perceived impact. The national vision is for a tourism sector which: • makes a full contribution to the national ambition to become net- zero by 2045, • leads to improved community wellbeing and nurtures thriving places, and • delivers shared prosperity for all, by encouraging the right growth in the right areas. Achieving this will require a number of ‘conditions for success’. This includes an understanding and acknowledgement of the potential contribution that tourism can deliver with the right policy and regulatory landscape in place to support the vision of 21st century tourism. HES’s Responsible Tourism Framework Sets out how tourism in the historic environment can contribute to better quality of life and meaningful experiences for all, now, and for future generations. Objectives include: • responding to rapidly growing visitor expectation and demand for ethical, low carbon tourism experiences, alongside changing visitor behaviours, and numbers, due to climate change • innovating creative ways to welcome visitors, and to communicate environmental stewardship, both physically and virtually Transforming activities around tourism to incorporate responsible tourism principles will be challenging in some areas but will also create new opportunities. HES also have 33 Properties in Care in Perth and Kinross and a number of commercial developments, enterprises, collaborations or initiatives. For example, engagement with Perthshire Tourism Partnership, measures to incentive car-free travel to properties, support learning and inclusion by offering free learning visits, and the facilitation of community events and religious services at HES sites.
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Scottish Agritourism – a Strategy for Sustainable Growth Agritourism has become a growing consumer trend in Scotland with an increasing number of farming enterprises responding by looking to diversify their operations. The Strategy highlights that there are around 500 businesses currently operating in the sector and experience from other countries demonstrates that agritourism has the ability to add value and employment to even the smallest of farms. The core strategic objectives of the Strategy are to: • develop a Scottish Agritourism offering based on food and drink and farm experiences • attract, develop and retain a skilled, committed and diverse workforce, both family employment on farm and employees • create, develop and promote a thriving and responsible sector • provide quality, unique, and memorable market led experiences • build financially sustainable, profitable, and resilient businesses and to play a key role in sustaining the future of Scottish Agriculture Given the rural nature of much of Perth and Kinross agritourism is likely to continue to be a growth sector in the future. Tay City Region Deal The Deal brings together public, private and voluntary organisations in the council areas of Angus, Dundee, Fife and Perth and Kinross to deliver a smarter and fairer region. The aim of the Deal is to catalyse inclusive economic growth across the region. Scottish and UK Governments will invest to enable the region to empower and promote inclusion, innovate and internationalise, and to connect. As part of an innovative, international Tay is investment in a Regional Culture and Tourism Investment Programme. The programme will build on and strengthen the existing culture and tourism offer to make the regional a highly desirable place to visit and live, work and invest in. It brings together and aligns the culture sector with the tourism sector and the visitor economy. Included in the programme is funding to support the development of the Pitlochry Festival Theatre for physical improvements and develop capacity to deliver high quality cultural activities and education opportunities for the region. Additional property investments are earmarked for Aero Space Kinross and Crieff International Highland Centre, more details of which are set out in Section 5 and Appendix E: Productive Places under Business and Industry. Tay Cities Region Tourism Strategy 2019-2024 Strategic objectives are identified as: • growing the value of overnight stays • improving the all-round experience for visitors • addressing common challenges such as connectivity, accessibility, seasonality and productivity The regional approach to tourism development is identified as: • strengthening the product offer in a way that capitalised on the strengths as a region and contributes to sustainable growth across the region • complementing and enhancing local identity and the process of local destination development • being industry-led with opportunities for businesses of all sizes to be involved in decision-making and implementation Tourism businesses across the region highlight that visitors are: online everywhere, international, taking short breaks more often, looking for authentic experiences, caring more about the impact of their visit, and wish to explore on the open road. At a regional level three particular strengths were identified which connected the whole region – culture and the creative industries, food and drink, and outdoor adventures. The strategy sets out priorities for action relating to each of these.
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Tay Cities Region Economic Strategy 2019-2039 In analysing economic performance within the Tay Cities Region, the strategy identifies tourism as the no.1 sector ranking by employment in Perth and Kinross with 8,000 jobs. Sustainable tourism accounts for nearly 12% of all jobs in Perth and Kinross. The strategy focuses on three key strategic themes – key business sectors, place: investment and infrastructure and, people: skills and employability. Sustainable tourism is identified as one of six growth sectors under the key business sectors theme. Strengths and opportunities include: • The variety and density of experiences that visitors to Scotland are looking for, including heritage, world-class attractions and a wide variety of landscapes • Iconic golf courses, including Gleneagles, and a flourishing golf tourism sector • Popular long distance walking routes including the Cateran Trail and Rob Roy Way in Perthshire • Perth Racecourse is the most northerly course and the only Scottish track to achieve five-star status in the National Association of Racing Staff’s Racecourse Ratings 2018 • A strong programme of events, festivals and performing arts networks and venues • Wide network of creators in arts, crafts, textiles and ceramics • Well places to benefit from significant growth in Green Tourism • Potential opportunities in relation to the further development of business tourism to the region, with links to other key sectors and regional expertise Key issues and challenges are identified as: • Creating authentic visitor experiences • The seasonality of the tourism sector and an over-reliance on day visits and the domestic market • Scope for a more joined-up approach to development and marketing of tourism to the region • Impact of poor rural transport connectivity and digital connectivity on businesses, workers and visitors • Conflict between low paid jobs and a need to enhance the quality and consistency of the visitor experience Actions identified in the strategy for the tourism sector include: • Taking a new regional approach to developing tourism • Seek to improve business-to-business collaboration between sectors • Implement the Perth Cultural Transformation Project • Invest in the development of Pitlochry Festival Theatre • Implement the Tay Cities Deal Regional Culture and Tourism Investment Programme • Promote investment in hospitality skills and training Perth and Kinross Economic Wellbeing Plan 2020-2028 The Perth and Kinross economy had experienced growth up until the pandemic with higher-than-average employment rates, very low unemployment, and higher than the national level increases for VAT business registrations. Tourism revenue had also grown with tourism related employment accounting for 13% of the total workforce. It was highlighted that the Council and its partners would need to intervene and support recovery and growth post pandemic with a need to make a swifter transition to a digital economy, to plan for clean growth and to support businesses to become more future focused. More detail is set out in Section 5 and Appendix E: Productive Places of the Evidence Report under Business and Industry. Perthshire Tourism Action Plan 2021-2025 The Plan identifies the strategic issues of relevance for Perth and Kinross include: • Environmental impacts and climate change – the move to net zero carbon economy by 2045 will have wide-reaching impacts on the tourism industry. There is now greater awareness of the
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environmental impacts of tourism with particular concerns relating to the impact of the growing motorhome / campervan market, freedom camping and other traffic and waste concerns. The Strategy’s action plan outlines developing a sustainable and responsible approach to tourism growth and implementing visitor management measures. • Changing regulatory environment – including powers to develop a ‘tourism tax’ and legislation on short-term lets. • Employment and skills – the challenges of attracting and retaining staff particularly in the hospitality sector post Brexit. Prior to the pandemic 89% of visitors to Perthshire were from the UK market and of that 65% were Scottish residents. The remaining 11% of visitors were international and there was a focus to grow the number of visitors from the USA, Canada and Germany. Post lockdown the domestic market has been the first to return but with a shift in behaviours including: • Need for greater reassurance on safety • Car becoming the preferred mode of travel • Shift towards outdoor produces and activities and demand for outdoor space The Action Plan looks to target the domestic visitor focussing on encouraging day trippers, staycations, workcations and growing the length of stay. To do this includes an aim to maximise the extra capacity across the area. Opportunities are identified as: • Touring and slow adventure – the preferred mode of travel is car but the longer-term aspiration is to encourage more active modes of travel and use of public transport. Encouraging visitors to explore alternative routes will help distribute traffic and a focus on supporting investment in motorhome and camping infrastructure should support the appeal to tourers / fly drive. • Responsible tourism – a growing emphasis on minimising environmental impacts and maximising local benefits. The current approach to visitor management in the rural areas will see further investment and community involvement in visitor infrastructure. • Active, nature and wellness – consumer demand for nature and experiencing the outdoors brings opportunity to build on current strengths such as the area’s outdoor assets. • Heritage, arts and culture – maximise opportunities from recent and future investment e.g. in Perth City Centre and Pitlochry Festival Theatre. • Local food and drink – opportunities to strengthen the area’s reputation as a food tourism destination. Needs of Communities, Visitors, the Industry, and the Environment In relation to this topic the Act requires information for the Plan area regarding the principal physical, cultural, economic, social, built heritage and environmental characteristics of the district, and the principal purposes for which the land is used. In this regard the information below supplements the information already set out in Section 2: Profile of the Perth and Kinross Area. Visitor Management in Rural Areas Report In 2020 the number of visitors to many rural areas rose dramatically. The sheer volume of visitors created pressures in these areas as well as the issue of ‘dirty camping’. There is a difficult balance between ensuring open access to the countryside and implementing the restrictions advocated by residents and communities to curb inappropriate behaviour. The main concerns expressed by communities and residents during 2020 were:
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• Substantial increase in vehicular traffic overloading popular destinations • Inappropriate parking on roads preventing access for residents, farmers and emergency vehicles • Litter and fly-tipping • Damage to fields and trees • Human waste not disposed of appropriately • Unattended campfires • Other anti-social behaviour through alcohol consumption Managing the increased visitor numbers is recognised as a complex challenge, and one that communities, landowners and residents are well placed to identify solutions to. A review of communities’ and officers’ experience from the 2020 season identified the main hotspot areas for future priority action as: Clunie Loch, Foss Road, Rannoch, Schiehallion, St Fillians and south Loch Earn, and Kenmore and Loch Tay. Highland Perthshire is also identified as a key hotspot area by Visit Scotland as referenced in their Visitor Management Plan. A need to work at a strategic level with local and national partners was recognised to ensure a coordinated approach to visitor management. Based on community and Council officer feedback the proposed priority issues for infrastructure were identified as parking, toilet provision, litter, wastewater and toilet waste disposal points for camper vans and motorhomes. Through the consultation exercise carried out on the Tourism Topic Paper Scottish Water indicated that the disposal of human waste from campervans and RVs in rural areas can present as a challenge for them too, as well as the seasonal spike in water demands within specific areas in Perth and Kinross. Also raised during the consultation, specifically in relation to Kenmore but of relevance to other areas too, was the need to relieve pressure on existing village facilities by providing additional parking, parking specifically for motorhomes where they can dispose of waste and take on fresh water, and recycling facilities. Big Place Conversation Issues and priorities relating to tourism identified through the BPC Place Standard discussions included: • Traffic and parking – the influx of tourists and visitors to natural spaces and key attractions impacts negatively on local areas. A need for better signposting to public car parks to help mitigate congestion was identified. • Work and economy – in many areas the BPC Place Standard consultation highlighted that the local economy is dominated by only a few sectors, for example tourism. There was a concern that this can limit job opportunities especially for younger people. Some areas also suggested a need for improving the promotion of the tourism sector of the economy. • Housing and community – short term lets and holiday / second homes reducing housing availability and affecting housing market e.g. higher prices. A need to protect housing for local people / workers was identified for some rural areas along with restrictions on short term lets and second / holiday homes. • Social interaction – impact on community life from tourists / visitors. • Care and maintenance – impact from wild campers / lack of public toilets. A need for more public toilet provision and an improvement in the facilities for campervans / tourists were identified. As perhaps expected, the main area experiencing the pressures identified above is Highland Perthshire. These are set out in more detail in the Highland and Strathtay BPC Ward Summary Reports.
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The tourism / hospitality sector is particularly dominant in the local economy in the Highland and Strathtay wards. The volume of traffic as a result of visitors / tourists was identified as a particular issue in Pitlochry and Aberfeldy. The impact is also felt in some scenic spots such as Loch Tay, Kenmore, and Loch Rannoch during high season. In Dunkeld and Birnam the number of visitors / tourists is considered to impact on daily life in the villages, particularly in relation to moving around and traffic and parking. The impact on the availability of affordable housing was also highlighted in this area. In relation to key areas of opportunity, the BPC Ward Summary Reports for Blairgowrie and Glens, Carse of Gowrie, and Strathmore all identify the potential for development or growth of tourism in the area. In the Kinross- shire ward it was particularly considered that more could be made of local history for tourism. Tay Forest National Park bid submission In preparing the bid for the Tay Forest National Park submission an overview was given of tourism and visitor management issues within the proposed national park area. The proposed area encompassed northern Perthshire, adjoining the Cairngorms National Park to the north and the Loch Lomonds and the Trossachs National Park to the south-west. The eastern and western boundaries were defined by the Council boundary and the majority of the southern boundary was demarcated by the Highland Boundary Fault line. The area attracts many visitors and tourism is key to the local economy, but the area also faces issues associated with high visitor pressures. During the public consultation communities identified the following key issues: • Limited access to public transport with a large number of communities ranking in the top 10% most deprived in terms of geographic access to services – any increase in visitor numbers needs to be coupled with improved public transport connectivity, frequency and reliability. • Certain settlement centres and key attractions are pressure points which experience greater effects of high visitor numbers. • A lack of housing for local workers including hospitality / seasonal workers with some businesses unable to operate at full capacity due to lack of available staff. • The adaptability and resilience of local business to change. Recent challenges include rising energy prices, the cost of food and supply chain, and the cost-of-living crisis affecting people’s ability to afford holidays. Unfortunately, the national park bid was unsuccessful as designation would have helped bring investment into the area. This in turn could have helped support the provision of new and enhanced infrastructure such as public toilets, parking, camp sites and recreational facilities. Short-term Let Control Area: Proposals for Consultation This committee report sought approval to consult on the principle of introducing a short-term let control area for Highland Perthshire and part of Eastern Perthshire. The report highlights that increased competition in the residential market, including competition from buyers for second homes and short-term lets operating as a business, can impact on the availability and affordability of houses for local people and to provide homes for staff to support rural businesses and public sector services. Short-term lets are, however, also recognised as an important part of the visitor economy which encourage spend locally. Communities have referred to second homes and short-term lets as an issue in Local Housing Needs Assessments for: • Pitlochry • Dunkeld and Birnam (PH8 area) • Aberfeldy, Weem, Strathtay, Grandtully, Logierait and Ballinluig
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• Mount Blair Community Council area • Comrie Community Council area New planning legislation allows for Council’s to designate short-term let control areas. There are, however, limitations and risks to seeking to manage short-term lets through the planning system: • The legislation only allows for the control of short-term lets and not second homes, empty homes, or purpose-built holiday accommodation • Short-term lets contribute to the operation of the tourism industry which is a significant economic driver in some parts of Perth and Kinross • A control area will not necessarily result in significant number of residential properties coming back onto the market – they may instead revert to a second home Analysis indicated that Highland Perthshire and the northern part of Eastern Perthshire have relatively high concentrations of self-catering and second homes. These areas coincide with the communities that have been identifying pressure on housing, business opportunity and service provision in combination with falling school rolls. A further report to committee in August 2024 sought approval to commence the formal statutory process to introduce a short-term let control area in parts of Perth and Kinross which the Committee decided against. The issues raised in the consideration of this issue are, however, still relevant to take into account in the preparation of the LDP Evidence Report. Distribution of licenced short-term lets Source: Perth and Kinross Council Licencing Scheme © Crown copyright [a database rights] 2024 OS AC0000805756.
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ASSC Survey: The Impact of Scottish Government Regulations on Business 531 businesses responded to the survey carried out in April 2024. 50% of respondents were in a rural or island location and 50% of respondents had just one property. Key results included: • 77% said the STL regulations had had a negative impact on their operations • 64% said the regulations had adversely impacted on how their business was perceived by the public • 46% do not consider that the underlying policy objective of the licencing scheme to improve health and safety had been met • 70% considered that the policy has failed on addressing anti-social behaviour and residential amenity • 88% do not believe the regulations have transferred more housing stock to residential use STA Recovery of Scotland’s Tourism Sector Key Findings The STA is the largest member organisation for tourism and hospitality businesses in Scotland. A survey of 744 businesses in 2022 highlighted that the top three challenges facing businesses were rising energy costs, an increase in supplier costs, and recruitment and staffing. 60% of hotels, 43% of visitor attractions and 45% of bars, pubs, restaurants and takeaway businesses responding said that they were unable to trade to their optimum and efficiently as they would like with the level of staff they currently have. Barriers to recruitment included a lack of available staff wanting and able to work, UK immigration policy / Brexit, and a negative perception of the industry. Barriers to retaining staff included business seasonality and for many businesses their inability to pay more competitively. Improving infrastructure and transport, refraining from introducing policies which seek to impose further tax on businesses and tourists, and the need to improve the quality of the visitor experience were the top three things businesses listed that Scotland needs to do to be a more globally competitive tourist destination. Whilst the ASSC and STA surveys provide a useful picture nationally, only around 7% of respondents (33 responses and 49 responses respectively) came from Perth and Kinross businesses. Summary of Implications for the Proposed Plan: The tourism industry is a significant economic driver in Perth and Kinross accounting for the largest percentage share of all jobs within the area. As the evidence above highlights, however, the Proposed Plan will need to strike a balance between supporting the recovery and future growth of the sector against the existing and potential for adverse impacts on local communities and the environment of accommodating that recovery and growth. A further challenge will be to create sustainable tourism within the required commitments in NPF4 to tackling the climate and nature crises. Spatial Strategy To meet the requirement of NPF4 the LDP spatial strategy will need to identify suitable locations which reflect opportunities for tourism development. The current LDP2 identifies areas that are already in tourism use within settlements. For example, caravan sites, holiday lodges, holiday parks, and larger hotels. This will be reviewed through the settlement audits to be carried out to inform the Proposed Plan. LDP3 will also need to consider how to spatially identify opportunities for tourism development which lie outwith settlements given that tourism in rural Perth and Kinross is often a dispersed activity since many visitors come for the outdoor and scenic experiences offered. There will be a need to take account of the varying, and often conflicting, needs of communities, visitors, the industry and the environment. In this respect the data above identifying those areas which are already under pressure will help inform the spatial strategy in terms of identifying both areas of
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opportunity and those areas where further development is not appropriate. Given that a key appeal of Perth and Kinross is the scenery and landscape, information set out in Section 2: Profile of the Perth and Kinross Area on those areas with environmental designations such as National Scenic Areas and Wildland Areas will help inform this process. Although much of the draw in Perth and Kinross is to countryside areas, consideration also needs to be given to opportunities within settlements, particularly in relation to the scope to build on heritage, arts and culture opportunities within the towns and city as identified in the Perthshire Tourism Action Plan. Need for a local policy response The Proposed Plan will need to consider whether there is a requirement for a local policy response to help ease identified pressures, particularly on communities and the environment. Consideration will also be needed as to the appropriate response to the identification of areas of potential growth and restraint in the rural areas of Perth and Kinross. As abovementioned, the NPF requires LDPs to identify both suitable locations for development and areas of pressure. Within rural areas existing and future opportunities are likely to be more dispersed and may be more difficult to plan for. A criteria-based policy approach may therefore be more appropriate in some areas than the identification of specific areas or sites on a proposals map. Gaps, Uncertainties or Key Issues Raised: Age of data Lack of up-to-date data is an issue. For example, both the Tay Cities Region Tourism Strategy 2019-2024 and the Perthshire Tourism Strategy have either reached or are nearing the end of the time periods they were prepared to cover. A new economic plan for Perth and Kinross is currently being developed and this will help inform the preparation of the Proposed Plan. The Report on Visitor Management in Rural Areas dates from October 2020 although some of the findings were reiterated during the Big Place Conversation consultation, for example, the impact of large visitor numbers on popular destinations. It will be important that any decisions relating to visitor management considers more recent levels of usage. Availability of data at the Perth and Kinross level A significant amount of data is available from the Scotland Visitor Survey 2023, for example on attitudes towards responsible tourism, accommodation used by visitors, planning and booking behaviours, accessible and inclusive tourism, types of visitors, and how they travel. Also available is data on visitor interests and activities including, culture and heritage tourism, cycling tourism, food and drink tourism, motorhomes etc tourism, outdoor activities tourism, and wellness tourism. At present, however, this data is only available at a Scotland-wide level. Data on active and sustainable transport Tactran highlight that there are problems in relation to active and sustainable transport and the implications both for visitors and hospitality workers. It remains difficult, however, to understand the scale of the problem, and the potential impact new development can have on tourism and culture, without understanding for example the baseline data in relation to traffic levels, wider connectivity and origins and destinations of the relevant travel to work areas. Data problems are (i) origins / destinations / length of stay / purpose of visit, and (ii) origins / destinations of workers. Summary of Stakeholder Engagement: Big Place Conversation The Council carried out its ‘Big Place Conversation’ exercise to kick start the LDP3 process across Perth and Kinross communities during most of 2023. This was a substantial exercise involving over 100 events throughout the Council area. The events ranged from drop-in information sessions,
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meetings, and online surveys to workshops and online sessions using the Place Standard Tool to capture the views of local communities about different aspects of their places. The results of the BPC are summarised as part of a separate report on the outcomes and findings across the different locality areas. LDP3 Evidence Report Topic Papers The Council produced a series of LDP3 Evidence Report Topic Papers, covering the individual subject matters of NPF4’s suite of national planning policies. These papers, which set out the detailed evidence the Council has gathered to help produce our Evidence Report and which we hope to use to help prepare our Proposed Plan, were published on the Council’s Consultation Hub and open for comments for a period of 6 week during July and August 2024. As part of our consultation process for LDP3 Topic Papers we welcomed the views of our key stakeholders (who were contacted specifically via email regarding the consultation exercise) and the public at large, on the sufficiency of the evidence gathered, our interpretation of the implications of that evidence to the Proposed Plan, and on how we intend to use that evidence to develop our LDP3. We also asked respondents to provide links to other sources of available information or data which they felt we had not included, alongside an explanation of why they considered any additional sources of information to be relevant to the preparation of the LDP. In addition to the key agencies prescribed under the Planning Act, the following stakeholders were contacted directly about the Topic Papers: Scottish Agritourism, Association of Scotland’s Self-Caterers, Visit Scotland, and Local Tourism Associations.
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Statements of Agreement/ Dispute 10 responses were received on our Tourism Topic Paper, one of which came from respondents who did not provide their name or contact details. The majority of respondents either agreed with or had no comment to make on the evidence identified through Topic Paper 029, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered and / or highlighted other potential implications for the Proposed Plan. A summary of these comments, their status, and the Council’s response are provided in the table below. One respondent on the Tourism issue wished their comments to be treated as a formal dispute to the Evidence Report. That response has been highlighted in red in the table. Respondent Agree or Dispute Summary of Comments PKC’s Response Nature Scot Not stated List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: It is useful to include all relevant policies as listed under Policy 30 of NPF4. For example, policies such as Climate Change and Biodiversity are important to explore given the potential pressure from tourism. We welcome the consideration of environment and climate change in relation to tourism. Formal Dispute: No Agreed. Full list of policies included. Historic Environment Scotland Agree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: Welcome the recognition of the opportunities to build on heritage, arts and culture tourism. HES’s Responsible Tourism Framework sets out how tourism in the historic environment can contribute to better quality The Historic Environment Scotland Responsible Tourism Framework has been included as evidence to inform the LDP3 Proposed Plan.
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Respondent Agree or Dispute Summary of Comments PKC’s Response of life and meaningful experiences for all, now, and for future generations. The plan is for our organisation, although the principles it contains may be of interest to others. The plan recognises the importance of enabling and promoting low carbon visitor experiences including embedding sustainable and active travel as a core consideration in the development of our investment and management plans. This includes adopting a shared destination approach with partners to develop low carbon travel routes between attractions. There are 33 Properties in Care of Historic Environment Scotland in Perth and Kinross. HES also have a number of commercial developments, enterprises, collaborations or initiatives in Perth and Kinross such as: engagement with Perthshire Tourism Partnership, measures to incentive car-free travel to properties, support learning and inclusion by offering free learning visits, and the facilitation of community events and religious services at HES sites. Formal Dispute: No Tactran Not stated List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): There are problems in relation to active and sustainable transport and the implications both for visitors and hospitality workers. It remains difficult, however, to understand the scale of the problem and the potential impact new development can have on tourism and culture without understanding the baseline data in relation to traffic levels, wider connectivity and origins and destinations of the relevant travel to work areas, for example. Data problems are Tactran highlight specific data problems, and these have been identified as data gaps in the Evidence Report.
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Respondent Agree or Dispute Summary of Comments PKC’s Response (i) origins / destinations / length of stay / purpose of visit, and (ii) origins / destinations of workers. Formal Dispute: No Scottish Water Agree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: Scottish Water is supportive of the need to balance economic benefit with adverse impacts felt from high tourism levels on local communities and infrastructures. The disposal of human waste from campervans and RVs in rural areas can present as a challenge as well as the seasonal spike in water demands within specific areas in Perth and Kinross. Scottish Water would ask for early consultation from Perth and Kinross Council on any proposals for new holiday parks or tourist infrastructure which will bring increased visitors to rural parts of Perth and Kinross. On short term lets, there is a need for guidance on the circumstances where an existing building will require planning permission to change the use to short-term let, holiday homes or non-serviced accommodation. In some circumstances, Scottish Water require to amend the categorisation of such dwellings to non-domestic. In these circumstances, it is requested that the customer is referred to set up a non-domestic account via a licenced provider. Formal Dispute: No Scottish Water’s comments on challenges have been incorporated into the Summary of Evidence. Remaining comments are for the next stage of the plan process or for additional planning guidance.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Earn Community Council Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): No comments Further Comments: Remove section on the Council’s bid to create a new national park for the Tay Forest area. The big challenge is to create sustainable tourism within the framework of NPF4 and the LDP3 to be consistent with Net Zero and nature commitments in all that P&KC offers tourism. Tourism Second Homes is a concern in regard to pressure put on local housing for communities. The section on the Council’s bid to create a new national park has been updated and retained as it is considered to still provide relevant information on key issues identified during the public consultation. Earn Community Council’s remaining comments have helped inform the Summary of Implications section of the Evidence Report. Kenmore Community Council Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Neither agreed nor disagreed. Further Comments: Several key priorities for the area highlighted including: • Number of suggestions to relieve pressure within the village associated with tourism and visitor numbers • Address imbalance between holiday and residential accommodation Formal Dispute: No Kenmore Community Council’s comments have helped inform the Summary of Evidence section of the report. Errol Community Council Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Formal Dispute: No No action required
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Respondent Agree or Dispute Summary of Comments PKC’s Response Savills on behalf of Scone Estate Disagree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: PKC is clearly heavily dependent on tourism as an employment sector and the significance of the tourism sector to PKC must be understood and reflected in planning policy. The attraction of people to Perthshire's more rural areas also indicates that the local authority should be supportive of developments which help to support and regenerate rural areas instead of applying stringent requirements regarding access to public transport. The Topic Paper considered the challenge set by NPF4 of spatially identifying opportunities for tourism development which lie outwith settlements. Tourism development in Perth and Kinross is by its nature, a dispersed activity since people tend to come for the outdoor and scenic experiences offered in this area. This means that significant care will be needed in designating tourism areas of growth potential or restraint without stifling opportunities which arise but cannot be readily planned for. Drawing lines on maps may not be the best way to approach this requirement. Criteria based policies may be more helpful. But all policies must be designed to be positive and supportive towards tourism initiatives given their significance to Perth and Kinross. Formal Dispute: Savills on behalf of Scone Estate wish to formally dispute this issue on the following grounds: The significance of the tourism sector to PKC must be understood and reflected in planning policy. Comments have helped inform the Summary of Implications section of the Evidence Report. In particular, the need to consider the most appropriate approach to the identification of suitable locations for development within rural areas is highlighted. Conclusion on dispute: The grounds of dispute have been incorporated into the Evidence Report. The dispute is therefore considered resolved.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Significant care will be needed in designating tourism areas of growth potential or restraint without stifling opportunities which arise but cannot be readily planned for. Montagu Evans LLP on behalf of Loch Developments Ltd Neither List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Formal Dispute: No No action required Not provided Neither List of Evidence/Datasets: There is updated data available from VisitScotland in relation to Perth & Kinross. This relates to the Scotland Visitor Survey (providing views of visitors who have visited Perth & Kinross) as well as 2023 visitor numbers (GB and international). These will provide post-pandemic insights. Note that the visitor management information was collated in 2020, during the pandemic. This was a period when restricted travel resulted in very high levels of UK visitation to rural areas. Decisions relating to visitor management should consider more recent levels of usage in decision making. Summary of Implications for Proposed Plan (PP): In the Culture and Creativity paper, there is emphasis put on the investment in culture through the Tay Cities Region Deal, in particular the Tourism & Culture Investment Programme. This is not referenced in the Tourism Paper. There has been a significant amount of investment by the public, private and third sectors in tourism which is worth referencing. Formal Dispute: No The Summary of Evidence section of the report has been updated to reflect the more recent Scotland Visitor Survey data, and the Tay City Region Deal. Comments on the need for updated data has helped inform the Summary of Implications section of the Evidence Report.
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1 Issue: Culture and Creativity Corresponding NPF4 Policy/Policies: • National Planning Framework 4, Policy 31: Culture and creativity • Other key NPF4 policy connections - 1: Tackling the climate and nature crises; 2: Climate mitigation and enhancement; 7: Historic assets and places; 9: Brownfield, vacant and derelict land and empty buildings; 12: Zero waste; 13: Sustainable transport; 14: Design, quality and place; 15: Local living and 20 minute neighbourhoods; 20: Blue and green infrastructure; 21: Play, recreation and sport; 23: Health and safety; 24: Digital infrastructure; 25: Community wealth building; 27: City, town, local and commercial centres; 29: Rural development, and 30: Tourism. Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 030: Culture and Creativity (https://consult.pkc.gov.uk/communities/topicpapers/supporting_docume nts/TP030_CultureandCreativity.pdf) Information required by the Act and NPF4 regarding the topic: Section 15(5) of The Town and Country Planning (Scotland) Act 1997, as amended: • The principal cultural, social, and built heritage characteristics of the district, and • The desirability of maintaining an appropriate number and range of cultural venues and facilities (including in particular, but not limited to, live music venues) in the district. NPF4 Policy 31 expects LDPs to ‘recognise and support opportunities for jobs and investment in the creative sector, culture, heritage, and the arts.’ The policy intent for Policy 31 is noted as: • To encourage, promote and facilitate development which reflects our diverse culture and creativity, and to support our culture and creative industries. The policy outcomes for Policy 31 are: • Locally distinctive places reflect the diversity of communities and support regeneration and town centre vibrancy. • Cultural and creative industries are expanded, providing jobs and investment. • Communities have access to cultural and creative activities. The Scottish Government’s Local Development Plan Guidance (May 2023) under it’s ‘Step by step guide’ provides advice on relevant evidence for the NPF4 policy topics to help planning authorities in considering the national planning policies when preparing their Evidence Report. With respect to NPF4 Policy 31, the Guidance advises that planning authorities are expected to take into account opportunities for jobs and investment in the creative sector, culture, heritage and the arts, and cultural offering in a place, for example: museums, galleries, theatres, cinemas, music venues, studios, recording spaces, and space for art/craft activities.
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2 Links to Evidence: • Perth and Kinross Council Corporate Plan 2022-2027 • The Scottish Government's Creative Industries Policy • Growth Sector Briefing – Creative Industries, Office of the Chief Economic Adviser, 14 March 2024 • The Scottish Government Growth Sector Statistics, 14 March 2024 • Tay Cities Region Deal • Tay Cities Regional Economic Strategy 2019-2039 • Tay Cities Deal Heads of Terms Agreement • Tay Cities Region Tourism Strategy 2019-2024 • Visit Scotland Insight on Tourism in Perthshire 2023 • Scotland Visitor Survey 2023 - Domestic and International • Perth and Kinross Council Culture Strategy 2023-2028 • Perth and Kinross Council Gaelic Culture and Heritage Webpages • Perth College University of Highlands and Islands • Gaelic Society of Perth • Learn Gaelic in Perth and Kinross Webpage • Scotland’s Creative Learning Plan, Creative Scotland • Perth and Kinross LDP2 Infrastructure Capacity Studies • Historic Environment Scotland, Perth and Kinross LDP3 Evidence [Core Doc Ref: CD40] • Historic Environment Scotland: Responsible Tourism Framework – Transforming Heritage Tourism, 2023 • Your Community PK Website • Perth City and Towns Website • PKC Events in Perth and Kinross Webpage • Perth and Kinross LDP2 Design Charettes • Aberfeldy Square Regeneration Proposal • Meigle and Ardler Community Action Plan • Stanley Community Action Plan • Alyth Community Action Plan • Coupar Angus Community Action Plan • Dunkeld and Birnam Community Action Plan • Crieff Community Action Plan • Blairgowrie and Rattray Community Action Plan • Pitlochry and Moulin Community Action Plan • Muthill and Tullibardine Community Action Plan • Auchterarder and Aberuthven Community Action Plan • St. Fillans Community Action Plan • Perth and Kinross Council LDP3 Big Place Conversation • Perth and Kinross Council Tay Forest National Park Bid • Perth and Kinross Council Tay Forest National Park Bid - Consultation Analysis report • Perth and Kinross LDP3 Evidence Report Topic Papers
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3 Summary of Evidence: Perth and Kinross Council Corporate Plan 2022-2027 Our Local Development Plan 3 (LDP3) will be prepared within the context of the Council’s Corporate Plan, which sets out the Council’s vision for a Perth and Kinross ‘where everyone can live life well, free from poverty and inequality.’ It proposes a number of key priorities for the 5-year period 2022 to 2027. It also reflects the principles of the Perth and Kinross Offer. The Corporate Plan identifies 7 priority areas which the Council feels it can directly influence and have the most impact upon, and those which are most important to delivering the Vision for Perth and Kinross. These priorities are: 1) Working in partnership with communities 2) Tackling poverty 3) Tackling climate change and supporting sustainable places 4) Developing a resilient, stronger, and greener local economy 5) Enabling our children and young people to achieve their full potential 6) Protecting and caring for our most vulnerable people 7) Supporting and promoting physical and mental wellbeing Delivery of the Corporate Plan’s Priorities will be underpinned by a set of Key Principles and delivered through a range of Key Actions. The Scottish Government's Creative Industries Policy This policy provides a definition of the creative industries as being ‘those based on individual creativity, skill and talent, or which have the potential to create wealth and jobs through the development or production of intellectual property.’ It outlines the valuable contribution the Sector makes to the Scottish economy, and that the national economic strategy highlights creative industries as a growth sector where the country can build on its existing advantages to increase growth and productivity. The Policy names the 16 distinct industries that make up the Sector. Growth Sector Briefing – Creative Industries, Office of the Chief Economic Adviser, 14 March 2024 This briefing document provides the most recent key statistics relating to this national growth sector, providing an overview of the economic benefits of the Creative Industries Sector to the Scottish economy in terms of exports (to rest of UK, internationally (both EU and non-EU countries); Gross Value Added (GVA) in the sector; Gross Domestic Product (GDP); numbers of registered businesses, and number of people employed across the sector. This provides an overarching profile of the performance across the Creative Industries Sector and its contribution to the country’s economy. The Scottish Government Growth Sector Statistics, 14 March 2024 The Local Authority Area Statistics provide data on business and employment figures across the various key sectors at a local authority level, taken from the Office for National Statistics (inter Departmental Business Register). In 2023, within the Perth and Kinross Area, there was a total of 335 registered businesses in the Creative Industries (including Digital). The majority of which were in the small enterprises category (0-49 employees).
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4 Figure E6(1) below shows the percentage share of registered businesses across the Scottish Government’s 6 key Growth Sectors within the Perth and Kinross Area. The majority of enterprises are in the Food and Drink sector, followed by Financial and Business Services and Sustainable Tourism. The Creative Industries sector comes in 4th across the different sectors, with a percentage share of 12%. The Scotland figure for this sector is 17.8% of the share. Figure E6(1): % Share of Registered Businesses in Key Growth Sectors In 2022, the total number of people in the Perth and Kinross Area employed in the Creative Industries sector was 1325, which accounts for 5.2% of total number of employees in the 6 key growth sectors in the Council Area (see Figure E6(2)), and 1.5% of the total number of people employed within the sector across the whole of Scotland. Figure E6(2): % Employment Share in Key Growth Sectors – Perth and Kinros In terms of the total turnover in £ millions, in 2021 in the 6 growth sectors within the Perth and Kinross Area, the Scottish Government’s local authority data tells us that the Energy sector had the largest turnover at £2,889.8 million, followed by: the Food and Drink sector with a turnover of £472 million; Sustainable Tourism with £275.3 million; Financial and Business Services with £180.7 million, and the Creative Industries sector with £111.5 million.
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5 Tay Cities Region Deal The brings together public, private, and voluntary organisations in the council areas of Angus, Dundee, Fife, and Perth and Kinross to deliver a smarter and fairer region. The full deal was signed in December 2020. The aim of the Deal is to catalyse inclusive economic growth across the region. The partnership is future focused, with a clear understanding of the action needed to deliver sustainable economic growth. It is about partnership and effective collaboration, as well as new resources. The region faces a number of challenges - its performance is below the Scottish average in several areas including productivity, employment growth and wage levels, and it has pockets of entrenched unemployment. With an economy growing at a slower rate than the Scottish average, the Deal recognises that more needs to be done to reverse these trends. For the economy to thrive, the Deal identifies that the following action is needed: • Grow our base of knowledge-led businesses • Support more businesses to trade internationally • Attract investment • Attract and retain talented people • Improve connectivity to, from and around the Region • Increase economic participation • Reduce inequalities The Deal will support business growth, develop innovative technologies, enhance productivity, develop skills, and create jobs. It will be delivered in the context of the refreshed Tay Cities Region Economic Strategy 2019- 2039. The Strategy has a vision to grow the region’s strong and up-and coming business sectors by building on existing regional skills, innovation, and experience. The Deal investment will, in conjunction with other joint activity by the partnership, help to address the region’s challenges and deliver this vision. With specific reference to the Perth and Kinross Area, the Deal identified the following projects as part of its Regional Culture and Tourism Investment Programme: • Pitlochry Festival Theatre – commitment by the Scottish Government of up to £10 million to support the transformation of the theatre venue and develop the capacity to deliver high quality cultural activities and education opportunities. The theatre’s transformative VISION Capital Project is now underway and being delivered across 3 phases. • Perth Cultural Transformation – commitment by the UK Government of up to £10 million to bring Perth City Hall back to life and transform into a new museum attraction. The new Perth Museum opened to the public 30 March 2024. • Innerpeffray Library, near Crieff – commitment by the UK Government of up to £0.1 million to develop the library to help secure its long-term future by upgrading its education and visitor facilities. The project involves accessibility and capacity infrastructure, along with developments to the natural and historic heritage of asset, such as creation of a heritage trail, and a viewing platform. • Crieff International Highland Centre – commitment by the UK Government of up to £1 million to create a new, purpose-built centre. As a first of its kind in Scotland, it aims to become a world base for Highland sports, dance, and music. To date a feasibility study for the centre has been undertaken.
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6 • Aero Space Kinross (ASK) – commitment by the UK Government of up to £1.6 million to ASK to help towards the construction of a uniquely themed Aviation, Astronomy, and Space Flight Science Centre. To date a pre-application enquiry has been submitted to the Council. Tay Cities Regional Economic Strategy 2019-2039 This Strategy is a review of the 2017 Regional Economic Strategy and its accompanying Tay Cities Deal Proposal. It was developed to update the statistical analysis of the current economic challenges of the Region, and the national and strategic context. It reflects current thinking on regional focus and priorities, and is aligned with the Tay Cities Deal Heads of Terms Agreement. The Vision contained in the Strategy is that: ‘Together, we’re striving to make the Tay Cities Region one of the most exciting, dynamic and desirable areas of Europe in which to live, work, invest and visit…’. Tourism, Food and Drink, and Digital and Creative Industries are three of the seven key business sectors identified in the Strategy which make a significant contribution currently to employment within the Region, and which offer significant opportunities for potential growth in respect of the key objective of increasing numbers of businesses, and providing more, better jobs within the Region. Tay Cities Region Tourism Strategy 2019-2024 This Strategy is the first regional tourism strategy for the Tay Cities Region. It seeks to ensure that the tourism sector is playing its role in delivering the Region’s economic strategy through supporting businesses, generating employment, and capitalising on new developments. The Tourism Strategy highlights the creative industries, food and drink sector, and outdoor adventures as being major strengths for the region and recognises that by building on these assets and enhancing the quality of the offer for visitors under these ‘connector themes’, it will help attract more visitors to the region, realise more extended stays, and increase overall visitor spend. The Strategy’s ‘Strategic Objectives’ are to: 1. Grow the value of overnight stays across the region… 2. Improve the all-round experience for visitors across the region. 3. Address common challenges, such as connectivity, accessibility, seasonality, and productivity. The Tay Cities Region’s ‘vibrant contemporary culture and… rich cultural heritage’ not only contribute to the area’s quality of life, but they also offer a unique experience to visitors who wish to discover that culture, and the Region has the opportunity to ‘excel at offering visitors a chance to immerse themselves in cultural and creative experiences that are hard to find elsewhere.’ A total of £37 million has been designated under the Tay Cities Region Deal funding to support a Regional Culture and Tourism Investment Programme that will invest in key economic assets to expand the international and
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7 national visitor offer of the Region. Those projects of specific relevant to the Perth and Kinross Area have been listed previously under the ‘Tay Cities Deal’ paragraphs. Some of the strengths of the area are identified as being: - Over 6000 years of heritage, showcased through a wide range of museums, cultural attractions and archaeological sites. - Wide range of small and microbusinesses in creative industries such as art, crafts, textiles and ceramics offering visitors the opportunity to see and do across the region. - Diverse programme of cultural events and festivals and a strong network of performing arts organisations. - Higher education network specialised in the arts, as well as high-tech digital creative industries such as gaming and graphic design. The overarching ‘Priorities for Action’ identified in the Strategy include: 1. Improve joint working between cultural and tourism establishments to ensure joined-up experiences for visitors, maximise reach for promotional activities and sharing of best practice in audience development and saleable products. 2. Establish the region’s reputation for creative tourism, building on established events, the profile of iconic cultural venues and the growing network of makers and creators across the region. 3. Encourage small and micro-enterprises in the creative and cultural sectors to engage with the tourism sector and visitors to further strengthen their businesses and demonstrate the rich cultural tradition in the region. 4. Utilise the high profile and international reach of the V&A Dundee to create a strong association of the museum with existing and new cultural attractions in the region. To deliver a great visitor experience, the Tourism Strategy suggests a number of actions for the Culture and Creative Industries sector, including: • Create synergies between our local culture and the creative industries, and other elements of the visitor journey, such as food and drink, accommodation, or business events. • Create products…and itineraries that encourage visitors to explore our cultural heritage assets more widely and easily. • Examine the potential for further assets in the region that would enhance the visitor offer in the field of culture and the creative industries while strengthening the asset base for this sector. • Attract visitors based on our strengths in high-tech creative industries. • Use iconic events related to our culture and creative industries to address challenges such as seasonality. • Support rural economic development by developing creative tourism in small and microenterprises. Visit Scotland Insight on Tourism in Perthshire 2023 and Scotland Visitor Survey 2023 - Domestic and International The Scotland Visitor Survey provides more detail on the reasons why people take a holiday or short break in Scotland, and how they rate their experiences whilst here. This regional insight report for Perthshire provides an insight on tourism in the area from a range of different sources, including tourism monitors, national statistics, and commissioned research. The report highlights key statistics for the area’s tourism sector, including overnight stays, employment and economic performance, and a profile of overnight
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8 visitors. In terms of the Top 5 attractions or activities undertaken or visited in Perthshire participants ranked the following: 1. Shopping (43% of the 159 people surveyed) 2. A castle or fort (35%) 3. A historic house, palace, stately home (34%) 4. Viewed architecture and buildings (32%) 5. Hill walk, mountaineering, hike or ramble – guided or self-guided (30%) Perth and Kinross Council Culture Strategy 2023-2028 The Council’s Culture Strategy explores in detail the cultural context for Perth and Kinross, as well as its people and places. It sets out how culture will contribute to the Corporate Priority to develop a stronger and greener economy, and provides the vision for culture in Perth and Kinross as one where: “We will enable creative communities and outstanding creative work to thrive in Perth and Kinross, through partnership.” In developing its cultural vision, the Council engaged with communities, cultural organisations, Creative Scotland, and Museums Galleries Scotland. Our communities helped to carry out a SWOT analysis looking at the key strengths, weaknesses, opportunities, and threats facing the current and future cultural offer for Perth and Kinross. This information was then used to create the Council’s 9 high-level ‘Cultural Pledges’, each with their own set of actions to help deliver the Vision. The Council’s Cultural Pledges are: 1. We will celebrate our cultural diversity and make culture in Perth and Kinross accessible for everyone. 2. We will ensure culture and heritage are integral to Placemaking decisions. 3. We pledge to make co-creation with local communities central to our cultural programmes. 4. We pledge to develop new partnerships locally, nationally, and internationally and strengthen the ones we have, bringing significant culture and new work to local audiences. 5. We pledge to maximise spaces and places for creative activity across all our localities. 6. We pledge to use data and evidence collaboratively to shape programmes which are well tailored to audiences and increase participation by growing new audiences. 7. We pledge to make culture count in tackling the climate emergency. 8. We pledge to support young people to learn, work and grow skills through culture. 9. We pledge to support and develop our small creative and craft businesses. The Strategy also provides a detailed look at the 7 different localities within the Perth and Kinross Area, including listing their culturally important assets and qualities, to help provide a profile of the Council Area’s principal cultural characteristics. Perth and Kinross Council Gaelic Culture and Heritage Webpages, Perth College University of Highlands and Islands, Gaelic Society of Perth and Learn Gaelic in Perth and Kinross Webpage The area’s Gaelic heritage includes a wealth of stories and songs, traditional Gaelic melodies, and a landscape full of Gaelic place names. The Council’s Gaelic Culture and Heritage pages provide information on
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9 the Gaelic heritage of the area, and signposts to ways of accessing Gaelic education within Perth and Kinross, from early years through to adult learning opportunities. There is Gaelic Medium Education Nursery Provision currently at Breadalbane Academy; two Gaelic Playgroups for children in the 0-5 age group, one in Perth and the other in Aberfeldy; Gaelic secondary level education is available within Perth Academy and Breadalbane Academy, and pupils from all four secondary schools within Perth City have the option to choose Gaelic at National 4 level from S5 as part of the Perth City Campus initiative. The Council also deliver a number of beginners Gaelic classes and conversation classes via the Adult Learning Hub. Perth College University of Highlands and Islands also hold Gaelic language classes as part of their leisure course programme. Libraries across the Council Area hold a wide collection of Gaelic books and music resources for both children and adults. There is a large collection at Breadalbane Community Library, but they can be made available by request at other local libraries throughout Perth and Kinross. AK Bell Library in Perth has a number of vintage Gaelic books and records in their Local Studies Department – a number of these books are held on behalf of the Gaelic Society of Perth. The Council provides links to a number of online courses for Gaelic speakers via our Learn Gaelic in Perth and Kinross page. There is a short film called ‘A Journey of Discovery’ on the main Gaelic Culture and Heritage page of the Council’s website which provides a snapshot of the Gaelic heritage of the area, and pupils from Goodlyburn Gaelic Medium Unit also created the Perth City Centre Heritage Trail. Scotland’s Creative Learning Plan, Creative Scotland The Creative Learning Plan was first published in 2013 and sets out an ambitious shared vision for the importance of creativity in education over the proceeding 10 years. It was produced through collaboration between organisations working in education and creativity across the country and provides a clear statement that Scotland values creativity and recognises the opportunities it brings to individuals and society. The Plan was looked at afresh following the Covid-19 Pandemic, due to the arts and creative sectors, including the learning and skills development element, being significantly impacted. As a result, updated action plans were produced to help realise the original vision within a changed landscape. Perth and Kinross LDP2 Infrastructure Capacity Studies In 2017, to support the development of our LDP2, the Council’s Development Plans Team undertook infrastructure capacity studies for the larger settlements across Perth and Kinross. The studies looked at the number and types of different community facilities and recreational amenities on offer across each of the settlements, including some of which are used for cultural activities and events. Perth and Kinross Local Development Plan - Historic Environment Scotland - Evidence In their response to the consultation exercise on our suite of PKC LDP3 Topic Papers, Historic Environment Scotland (HES) provided a report of
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10 detailed historic environment evidence for the Perth and Kinross Council Area to help inform our LDP3 Evidence Report. Along with highlighting the key national strategies, statements, guides and other resources of relevance to the historic environment, HES also provides detailed information on: designations and casework; Buildings at Risk; live, ongoing and recently completed grants; their work with communities, and the tourism and economy sectors (in terms of HES’s role and responsibilities). Of specific reference to the Culture and Creativity issue of this Evidence Report, HES identify the following commercial developments, enterprises, collaborations and initiatives within the Perth and Kinross Area: • Working with Logiealmond Estate to explore the opportunity at Craiglea slate quarry. The British Geological Survey have produced an assessment of the quarry, and owners are looking at how the quarry can generate income by producing slate products. • Annual financial contribution to RSPB to support the harvesting of thatching reed on the Tay estuary, the only commercial source of reed for thatching in Scotland. Harvesting also supports local biodiversity and habitat creation. • Facilitation of community events and religious services at HES sites. For example, we enable Innerpeffray Library to host events to raise funds at Innerpeffray Chapel free of charge to help improve their resilience. • HES collaborates with other organisations to deliver services and training etc. For example, we recently loaned the Society for the Protection of Ancient Buildings, equipment from Huntingtower Castle when they were delivering a course at nearby Tibbermore Church. • Ongoing support for Crannog Centre in terms of place-based approach, with the aim to create a training hub for traditional skills, combined with accommodation and employment opportunities. • Regular liaison with partners such as Stanley Mills East and Mid Mill Owners Association (whom HES support by enabling them free out of hours use of our Community Room for their AGM) and the Church of Scotland (Dunkeld Cathedral a working church whose building adjoins the Property in Care). In addition, other projects HES have been working on with communities across Perth and Kinross include: • Supporting Dunkeld and Birnam Community, and Network Rail in repurposing and reusing the train station alongside tourism opportunities. • Community Asset Transfer of Pitlochry Town Hall to Pitlochry Community Action Trust to create affordable homes and community space. • Looking into community aspirations regarding the Meigle Pictish stones. Historic Environment Scotland: Responsible Tourism Framework – Transforming Heritage Tourism HES’s Responsible Tourism Framework defines their understanding of, and role in, responsible tourism. It sets out the principles which guide their decision-making and provides a framework for developing actions. The document emphasises the contribution that tourism in the historic environment can make to a better quality of life, and meaningful experiences. Although the Framework has been developed for HES, the principles within it can be of relevance to others.
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11 The document highlights the importance of facilitating and promoting low carbon visitor experiences in the development of their investment and management plans, which includes a ‘shared destination approach’ with partners in order to develop low carbon, sustainable and active travel routes between attractions. The responsible tourism objectives identified in the Framework are: • Build business resilience and decrease our dependency on a carbon and resource intensive operation model. • Enable community wealth building through participation, inclusion, and sharing our knowledge, leading to greater economic benefits and wellbeing. • Respond to rapidly growing visitor expectation and demand for ethical, low carbon tourism experiences, alongside changing visitor behaviour, and numbers, due to climate change. • Innovate creative ways to welcome visitors, and to communicate environmental stewardship, both physically and virtually. • Unlock local knowledge and narratives to enable enriching experiences and increase sense of place, cultural awareness, identity, and inclusion. • Enhance wellbeing at the community and individual level, taking a more conscientious approach to the potential and value of a place. The three priority areas identified by HES for effective action are: 1. Our responsibility for the historic environment – this covers aspirations to maximise HES’s positive impact on the environment; including, efforts to decarbonise tourism operations, integrate circular business models, and sustainable procurement. It also covers HES’s responsibility to enable and educate visitors to be responsible consumers. 2. Our responsibility for people – this covers aspirations to co-create experiences with wider communities and visitors, including, encouraging meaningful interactions and improving access to our heritage for everyone, with wellbeing at the heart of consideration. 3. Our responsibility for capacity building – this covers aspirations to use HES’s lead position to support others, including demonstrating best-practice, and strengthening skills development and local career pathways in the heritage tourism sector. Your Community PK Website The ‘Your Community PK’ website provides an extensive list of the vast range of services available (including contact information) across Perth and Kinross under the - Advice and Info; Care and Support; Children and Families; Health and Wellbeing, and Things To Do categories. The website also contains an interactive map to help identify the location of these services, of which there are over 1000. Some of the community-led groups and activities listed include those on offer for - veterans, LGBT+ youth groups, youth clubs, religious groups, minorities groups, arts and craft societies and clubs, film societies, gardening groups and horticultural societies, friends networks, local choirs and orchestras, drama/acting/performance clubs and groups, guided walks walking groups, historical groups and societies, the Scottish Women’s Institute, men’s sheds, parent groups, youth rights services, focused groups for people with specific disabilities, language classes (including English for speakers of other languages, and Gaelic), sports clubs, dance classes, civic trusts, scout groups, girl guide groups, landscape partnerships, and carer support groups.
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12 Perth City and Towns Website and PKC Events in Perth and Kinross Webpage This website and the PKC webpage are a useful source of information on the area. The Perth City and Towns Website provides visitor material, including detailed information on each of the localities, accommodation, and sample itineraries. There are also ‘Live Local’, ‘Things to Do’ and ‘Culture’ sections with a wealth of information on shopping, eating and drinking, events, activities, outdoor adventure, and attractions. A Cultural Guide is also available. The attractions section provides information related to ‘Gardens and Grounds’, ‘Distilleries and Breweries’, ‘Historic Attractions’, and ‘Castles’. The PKC Events page has a calendar for events, detailing what’s on during the year and where. Perth and Kinross LDP2 Design Charettes Between 2014 and 2016, Perth and Kinross Council worked in partnership with a number of local Community Councils to undertake a series of community design workshops in key settlements across the area. The objective was to work with local communities and key stakeholders, in identifying a town's strengths, weaknesses, as well as opportunities to help mitigate the social, environmental, and economic challenges towns across Scotland are facing. In total, 5 charettes were undertaken for Aberfeldy, Auchterarder, Bridgend, Blairgowrie, and Crieff. In the Aberfeldy Community Charette, the town’s cultural offer was listed as including: the community run Birks Cinema, the annual Aberfeldy Festival, and a number of cafes, restaurants, and bars. The Square was recognised as the civic, commercial, and cultural heart of the town. Culture was one of the key principles for the town’s future, and the community’s vision was that ‘Aberfeldy will be a creative community, continuing to support and nurture the strong creative talent within the community to provide a cultural focus to the Town Centre. One of the four Priorities identified by participants was to ‘Make more of Aberfeldy’s existing assets: enhance the riverside and make the most of the town’s historic and cultural assets, including Lower Birks.’ The former Co-op building to the east of the Square was also highlighted as a potential opportunity for a cultural or civic centre, or as a small business hub in the heart of the town. As part of the Auchterarder Community Charette process, participants rated the town’s historic buildings and townscape overall as being in their top 5 ‘Community Likes’ and identified ‘Culture’ as being one of the key principles for the future of the town. The community’s vision for culture was that ‘Auchterarder will be a creative community, supporting and nurturing active groups and creative talent within the community to provide a cultural focus to the Town Centre.’ The community wanted to see a flexible, community event space provided in the town and a youth activity hub within Dunlop Park to accommodate informal activities which ‘stimulate creative thinking and cultural identity’. Participants in the Bridgend Community Charette highlighted that poorly maintained, vacant, and derelict buildings within the Conservation Area could benefit from investment to improve the appearance of the buildings and the streetscape overall and help bring buildings back into use and generate more visitors. The Charette also looked at making more of
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13 Bridgend’s location next to the River Tay (which was viewed as an important asset), including exploring its potential for more riverside and on the river activities, and also better connections over the Tay to and from Perth City Centre. The Blairgowrie and Rattray Town Centre Charette used the Place Standard Tool to help build a picture of how the community view their places, in terms of likes and dislikes, and also to identify key issues for future action. Under the ‘Facilities and Amenities’ theme, participants identified a desire for an art and crafts centre or studio space; they wanted a community destination venue with a cultural, museum, and/or cinema offering. The idea of an inter-generational space or place where the community could meet and interact was also raised. A separate session was held with the ‘artist and makers’ community who operate in and around the Blairgowrie Town Centre. The importance of the town’s stART Festival was highlighted and the possibility of making it a calendar ‘anchor’ was also discussed, as too was the idea of creating a street environment for the festival that connects the activity of the festival with the people in the town who hope to benefit the most commercially from it i.e. the artists and makers. The need for a space for tutoring, exhibiting, selling, making, learning, workshops, inspiring, talking, and meeting, was also identified. The possibility of exploring the use of the Police Station as a venue for these activities was looked at. The strength of Crieff’s creative community, and its town heritage were highlighted as being in the top 5 of ‘Community Likes’ as part of the Crieff Community Charette process. Proposals to encourage awareness and appreciation of the area’s heritage through a clearly marked heritage trial throughout the town were discussed. Culture and the town’s environment were identified as some of the key principles for the future of the place. The community’s vision for culture of the town was that ‘Crieff will become a culturally enhanced, creative community, continuing to support and nurture the strong creative talent within the community to provide a cultural focus to the Town Centre.’ Aberfeldy Square Regeneration Proposal The Aberfeldy Square Regeneration Proposal is a collaborative project between Perth and Kinross Council, Aberfeldy Small Business Association, and Aberfeldy Community Council, to regenerate the square in the town, with the overarching aim of helping to support and sustainable local economic growth. Proposals for the Square focus on reducing existing parking provision to create a level, flexible space which can be used to host current and future music and cultural events. The key principles and community priorities identified as part of the Aberfeldy Community Charette process were used to inform the initial ideas for the Square, as well as develop the final proposal. Community Action Plans (CAPs) There are currently 11 Community Action Plans (CAPs) in Rural Perth and Kinross, for Meigle and Ardler, Stanley, Alyth, Coupar Angus, Dunkeld and Birnam, Crieff, Blairgowrie and Rattray, Pitlochry and Moulin, Muthill and Tullibardine, Auchterarder and Aberuthven, and St. Fillans. There is also a CAP development process due to start for Comrie once the necessary
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14 funding has been secured. Community Action Plans are community-led and focus on identifying a common vision, key themes, priorities, and actions needed to enhance a place over the period of the CAP and beyond. Most of the CAPs contain an audit of events and venues, demonstrating the existing culture and creativity offerings in a place. The importance of existing historic assets and characteristics to a place was highlighted across all CAPs, as too was the opportunity to further develop tourism and heritage experiences for the benefit of the local economy, and to raise awareness of an area’s arts, culture, and heritage.
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15 Summary of Implications for the Proposed Plan: Perth and Kinross Council Corporate Plan 2022-2027 Our Local Development Plan 3 should be developed in alignment with National Planning Framework 4, in order help support the delivery of all the Corporate Plan’s Priorities. Implementing NPF4 Policy 31, specifically, should help support the delivery of Priorities 1, 3, and 4. The Scottish Government's Creative Industries Policy Provides a definition to work to, through the development of our Proposed Plan, of what the Creative Industries are and the distinct industries which make up the sector in Scotland. It also highlights the important contribution these industries currently make and can make in the future to the Scottish economy. It is crucial that the development of our LDP3 Spatial Strategy reflects the importance of this sector through protecting existing cultural and creative workspaces and venues/places/spaces and supporting new opportunities, in order to help support the sector’s growth locally, within Perth and Kinross, via the land use planning system. Growth Sector Briefing – Creative Industries, Office of the Chief Economic Adviser, 14 March 2024 and The Scottish Government Growth Sector Statistics, 14 March 2024 Useful key statistics which further highlight the importance of the Creative Industries Sector to both the Scottish and Perth and Kinross economies. As with the Policy above, it is crucial that the development of our LDP3 Spatial Strategy reflects this in order to help support the sector’s growth locally, within Perth and Kinross, via the land use planning system. Gaps, Uncertainties or Key Issues Raised: The Scottish Government’s March 2024 Growth Sector Local Authority Area Statistics for the Perth and Kinross Council Area reports data from 2021, 2022 and 2023 for turnover, employment numbers and registered businesses figures, respectively. More recent data is not yet available, but any updates available at the time of developing our Proposed Plan will be used to inform the Plan. Tay Cities Region Deal, Tay Cities Regional Economic Strategy 2019-2039, and Tay Cities Regional Tourism Strategy 2019-2024 The Tay Cities Region Deal and accompanying strategies on economy and tourism provide the framework for the Region’s economic growth and contain detailed priorities, actions and proposals for programmes and projects in relation to the Tay Cities Deal. The Scottish Government’s data on the performance of the six identified key growth sectors, both across Scotland as a whole, and in the Perth and Kinross Area in particular, provides us with an understanding of how well our Creative Industries sector is performing relative to the other six Tay Cities Region key business sectors. As one of the three ‘connector themes’ identified in the Regional Tourism Strategy, there is recognition of the potential of this sector to grow and realise greater opportunities for the benefit of the region as a whole, not only for the quality of life of residents, but to enhance the tourism offer and increase visitor spend. It is important that in developing our LDP3 Spatial Strategy that we take into consideration and support the Region’s seven key business sectors, including its tourism ‘connector themes’ of Creative Industries, Food and Drink, and Outdoor Adventures, to ensure that land use planning plays its
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16 role in facilitating the strengthening of these sectors via protecting existing facilities and venues, identifying and supporting opportunities for new proposals and also the delivery of specific projects and actions identified for them, within the framework of national planning policies and guidance. Visit Scotland Insight on Tourism in Perthshire 2023 and Scotland Visitor Survey 2023 - Domestic and International The Perthshire Insight on Tourism report provides a useful understanding of visitor behaviour and experience in the area post-pandemic. The Top 10 reasons for choosing Scotland identified by the sample of survey participants for Perthshire and also their Top 5 ranking of attractions or activities, highlights how important the unique cultural offering of the area, in terms of the scenery and landscape, history and culture – including architecture, buildings and assets, is to attracting tourists. Our Spatial Strategy, in line with NPF4 policies 4, 7, 10, 14, 29, 30, and 31, in particular, should seek to protect and enhance this unique offer to continue to support growing the tourism sector, but in a way that aligns with a just transition and NPF4 policies in relation to tackling the climate and nature crises, biodiversity, a circular economy, and reaching net zero emissions targets to achieve sustainable tourism. Perth and Kinross Council Culture Strategy 2023 – 2028, Perth and Kinross Council Gaelic Culture and Heritage Webpages, Perth College University of Highlands and Islands, Gaelic Society of Perth and Learn Gaelic in Perth and Kinross Webpage These information sources are important in helping us to understand the cultural context of the different parts of Perth and Kinross so that LDP3’s Spatial Strategy can develop in a manner that will help contribute to the realisation of the vision for culture in Perth and Kinross. They will also help us to identify and support the maintenance of an appropriate number and range of cultural venues and facilities as per Section 15(5) of the Planning Act. Scotland’s Creative Learning Plan, Creative Scotland The plan provides context as to how important creativity is regarded to be to Scotland in terms of the opportunities and experiences arts and culture bring to individuals and society, and the importance of continuing to develop learning and skills through our education. The Spatial Strategy for LDP3 can help support arts and culture through identifying and protecting existing venues, facilities and spaces, and supporting opportunities for new proposals, particularly where communities, through consultation and engagement exercises for LDP3 and other plans and strategies, have identified a need or desire for spaces for arts and culture. Perth and Kinross LDP2 Infrastructure Capacity Studies, LDP2 Design Charettes, Aberfeldy Square Regeneration Proposal, and Community Action Plans (CAPs) The capacity audits, feedback received during engagement events, and our community led documents provide an important source of information about our places, what they offer, and the key priorities and aspirations of our communities for the future of their places. It is important that these characteristics, along with relevant environmental, physical, heritage, and socio-economic characteristics are taken account of and echoed in the development of the Spatial Strategy for LDP3, to help encourage, promote,
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17 and facilitate development which reflects our diverse culture and creativity, and to support our culture and creative industries, in line with the policy intent of NPF4 Policy 31. Gaps, Uncertainties or Key Issues Raised: Despite some time having elapsed since our Design Charette reports were produced, their content still provides a good source of information on the community’s views of their local assets, their aspirations, areas for improvement, and a vision for the future of their place. Any data or statistics contained within them which has since been updated will be reviewed as part of the LDP3 Settlement Audit work. The Audit will also consider if progress has been made against the key issues and actions identified in the charettes, and how those issues and actions compare to the feedback gathered through the Big Place Conversation. Perth and Kinross Local Development Plan - Historic Environment Scotland – Evidence [Core Doc Ref: CD40] The report provided by Historic Environment Scotland to help inform our LDP3 Evidence Report is incredibly useful. The detailed information provided on specific assets and places will be more appropriately taken forward through the Historic Assets and Places, Business and Industry, and Tourism issues in particular, and also through our Settlement Audit work to inform our Spatial Strategy. Historic Environment Scotland: Responsible Tourism Framework – Transforming Heritage Tourism This Framework recognises the value our historic environment has not only in terms of tourism and economy but also in terms of the contribution it can make to community wellbeing and satisfaction, and to a sense of place and cultural identity. It sets out guiding principles and priorities for achieving responsible tourism linked to our heritage assets, to help Scotland in reaching its net zero emissions targets, and to safeguard these assets, and the environment surrounding them, and improve their resilience to the effects of a changing climate. Furthermore, it seeks to enhance visitor experiences, improve access to heritage tourism experiences for all (physically, cognitively and culturally), extend and expand the time spent by visitors at attractions across the year and country, and strengthen the provision of skills development and quality career pathways in the heritage tourism sector. Recognising that there are other partners with responsibility for heritage assets and tourism offerings, HES also want to support other businesses and organisations in their efforts to move to business models that reflect responsible tourism principles. Due to the rich heritage of the Perth and Kinross Area and the Tay Cities Region overall, which is engrained in the culture and identity of our places and people and is a key attraction for visitors coming to the area, there is a strong overlap between NPF4 policy 31 Culture and Creativity and policies 7: Historic Assets and Places, and 30: Tourism. However, in light of the links between our historic environment and the economy and placemaking, and the need to tackle the dual climate and nature crises,
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18 there are a number of other key policy connections, including, but not limited to the following subjects: tackling the climate and nature crises; natural places; soils; forestry, woodland and trees; brownfield and vacant and derelict land and empty buildings; energy; design, quality and place, quality homes and rural homes; blue and green infrastructure; community wealth building, and city, town, local and commercial centres. Each of these individual policy areas will consider the relevant evidence in this Evidence Report for those subjects, taking into account linkages to other policy areas. Your Community PK Website This website is a good source of information on the many groups, societies, clubs and services on offer across the Perth and Kinross Area. There are over 1000 services listed under a number of categories which can be viewed by location on the interactive map provided. The vast range of community-led groups, clubs, societies and events on offer provide a significant contribution to the social, cultural and creative fabric and identity of not only our local communities, but the Perth and Kinross Area. The cultural and creative offerings in a place will be explored in more detail through the Settlement Audit work in relation to identifying local living and 20 minute neighbourhoods under NPF4 Policy 15. Gaps, Uncertainties or Key Issues Raised: There is a note on the website’s homepage to highlight that the site is currently undergoing development. It is difficult to know how up to date the information contained on the site is regarding local groups and services. Perth City and Towns Website and Events in Perth and Kinross Webpage The website and webpage are a useful source of information on the area. They demonstrate the breadth of what is on offer across Perth and Kinross, including culture and creative events and attractions. The Cultural Guide section of the website lists music events, trails, and the new Perth Museum. There are a number of music and other festival events listed, which attract a large number of visitors, some of which travel from outwith the Perth and Kinross Area to attend. In developing our LDP3 Spatial Strategy it is important to understand the cultural and creative offer within Perth and Kinross, to allow us to identify and support the maintenance of an appropriate number and range of cultural venues and facilities as per Section 15(5) of the Planning Act, and recognise and support opportunities for jobs and investment in the creative sector, culture, heritage and the arts for the Perth and Kinross Area and our communities, in line with NPF4 Policy 31: Culture and Creativity. Our LDP3 Settlement Audit work will consider in more detail the venues and facilities available in a place and their role in placemaking, local living, wellbeing, the economy and tourism, if relevant.
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19 Summary of Stakeholder Engagement: Perth and Kinross Council LDP3 Big Place Conversation As previously highlighted elsewhere in this Evidence Report, the Council carried out its Big Place Conversation across Perth and Kinross communities during most of 2023. The Place Standard Tool was used as part of this exercise to capture the views of local communities, young people, service user groups, and minority groups. The Place Standard Tool sessions asked participants to rank their places in terms of 14 themes. The commentary provided and average rankings for the Perth and Kinross Council Area overall, for those themes of relevance to the Culture and Creativity issue of this Evidence Report, are as follows: Streets, Squares and Buildings scored an average of 4.1 out of 7 overall. Participants in general felt that these aspects of their place are in good condition, attractive, and contribute positively to the character of communities. Historic buildings and monuments are viewed as integral to local heritage and add to the character of places. Key community buildings, such as village halls and churches, are highly valued by residents. The repurposing of vacant and derelict sites was highlighted for bringing a range of benefits to local communities, including improved feeling of safety, better aesthetics, and the delivery of new commercial or residential opportunities. Investment to date in retrofit and renovation schemes was also noted as improving the quality of buildings and public spaces. However, there are still concerns remaining across the Council Area regarding existing vacant and derelict sites, which negatively impact on feelings of safety, overall appearance of a place, and the vitality of local communities. High levels of traffic and parking were identified as issues which detract from people’s enjoyment of public spaces, as too was the lack of infrastructure to support disabled people, such as dropped pavements and accessible toilets. Some communities felt that there is a lack of urban greenery and adequate green infrastructure, and the limited availability of seating and sheltered areas in some public spaces was also noted. Some of the suggested improvements under this theme include: improvements to the care and maintenance of the public realm; securing funding for the upkeep and preservation of historic assets; upgrading of public spaces to enhance community benefits through incorporating more blue green infrastructure, public art, street furniture, and sheltered areas; the repurposing of vacant and derelict sites for high-demand uses based on local context, such as for community, commercial or residential purposes, and improvements to direction and informational signage. Natural Spaces scored an average of 5.1 out of 7 for the Council Area overall. Participants commented on how natural heritage is intrinsically linked to local history, identity and character, and that the area’s scenic landscapes are highly valued. The presence of high-quality greenspaces within urban areas was noted as a means of enhancing access to nature for urban communities. Poor or fragmented network connections, limited parking, and poor path conditions were all highlighted as barriers to accessing greenspaces, particularly for those with reduced mobility. Noise
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20 pollution, a lack of sufficient seating and sheltered areas were also noted as having a negative impact on people’s ability to enjoy natural spaces. Some of the suggested solutions to issues raised under this theme include: enhancing biodiversity and naturalness in both rural and urban areas e.g. through tree planting and well-designed blue green infrastructure; improving the overall quality, connectivity, and promotion of the path network linking settlements with natural spaces; ensuring development contributes to creating or enhancing greenspaces and path connections; promotion of natural attractions more effectively; increasing opportunities around prominent natural assets, such as the River Tay; increasing parking, seating and shelter provision at key natural spaces, and providing more opportunities for community growing. Play and Recreation scored an average of 3.9 out of 7. Overall, there was a lot of positive feedback across the area regarding the level and variety of formal and informal indoor and outdoor play, leisure and sport opportunities, particularly in larger settlements. However, it was felt that Children and older adults have the most opportunities, and that the spaces and activities on offer to girls, older children and young people (age 12+) and people with disabilities are insufficient. A limited number of facilities (particularly indoor) and organised activities in rural areas meant that people need to travel by car to access formal opportunities, and issues with active travel and public transport further hinder accessibility. The hiring of venues and participating in activities can be cost-prohibitive, and many facilities are viewed as being outdated or in poor condition, requiring maintenance and upgrades. The key role local volunteer groups play in supporting a variety of opportunities for all age groups was recognised. Some suggested solutions by participants included: • Improving public transport connections to key facilities. • Improving accessibility and making better use of existing indoor venues, like church and village halls and schools. • Development of more adaptable multi-use facilities (both indoor and outdoor). • Creation of central online platform for sharing information about groups, activities and events. Facilities and Services scored an average of 4.1 out of 7 in relation to how people view their places are like for accessing services they need. There were mixed views as to whether local shops and services in rural areas met people’s needs, some areas were content with existing provision, but some noted the need to travel to access shops and services. Many of the rural communities mentioned the value of mobile services, including libraries. Improvements to high-speed broadband access, particularly in rural areas was suggested as a solution to some of the issues experienced. Work and Local Economy scored an average of 3.7 out of 7 in response to the question whether there are opportunities for people to work, train or volunteer locally. Some areas felt that there is a good range of employment opportunities, including part-time and local options. Nearly every area commented on the need to commute for work purposes, with local jobs being limited in roles, and professional employment options requiring travel. Many areas mentioned that the local economy is
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21 dominated by a few sectors e.g. tourism, agriculture and retail, which can limit job opportunities, especially for young people. In terms of solutions to issues raised, many communities suggested providing greater support to small businesses, including affordable premises, and some suggested improving the promotion of the tourism sector. Social Interaction scored an average of 4.2 out of 7 across Perth and Kinross. Feedback received from communities demonstrated strong evidence of good opportunities across the Council Area for social interaction, and the range of indoor and outdoor venues and events/activities/clubs/groups were identified as important in helping to foster social interaction. Although, an over-reliance on volunteers to run events and activities was noted. A lack of opportunities for disabled and young people to meet up was also raised in most places, and rural areas and smaller settlements highlighted that there are fewer venues for them to meet up at. The loss of community facilities and assets, and often the high cost of hiring venues were flagged as issues. Identity and Belonging scored an average of 4.9 out of 7. Whilst a strong sense of community came across in most places, and people feel proud of their place overall, it was felt that community cohesion could be improved in some areas, particularly to welcome new residents, and some areas felt that their identity has been eroded over time, especially with the growth of towns and villages. Participants suggested solutions, which included – more local events and celebrations to help promote identity; greater access to and promotion of local heritage to foster pride; improvements to the care and maintenance of some areas to help support identity and belonging, and some felt that more is needed to engage young people. Care and Maintenance scored an average of 3.8 out of 7. BPC participants were asked if there are spaces or buildings that need cleaning up or fixing in their area. Feedback was that ‘In Bloom’ groups and other volunteers do a great job, and some local communities take pride in their place organising litter picks and the maintenance of public spaces. Overall parks and public spaces were thought to be generally well maintained, but the ‘No Mow’ grassland management approach changes resulted in spaces being viewed as unkempt/poorly maintained, and some historic buildings were noted as needing better maintenance. Suggested solutions from our local communities included – improved funding for local groups; better and more collaboration between the Council and community groups; improvements to shop frontages; a coordinated approach to town centre management; stronger enforcement of building maintenance requirements; redevelopment of key vacant and derelict sites, and designated spaces for young people to practice street art. Perth and Kinross Council Tay Forest National Park Bid and Consultation Analysis report Consultation events were carried out as part of the development of Perth and Kinross Council’s Tay Forest National Park bid. A Consultation Analysis report was produced by Land Use Consultants (LUC). Some of the points
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22 identified by respondents for consideration in the bid preparation highlighted cultural activities (music, art, events) as a key feature of the area. The preservation and celebration of local landscapes and cultural heritage were also recognised as being important to people. Finally, some participants commented that the Highland Boundary Fault is not just a geological divide, but also a cultural one, as it marks a difference in what grows and how communities have settled in the area. It was regarded as a special quality of the area, but not a well understood one. Perth and Kinross 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 Local Development Plan. The comments received on Topic Paper 030: Culture and Creativity, and how the Council has taken those responses into account in the production of this Evidence Report are set out in the ‘Statements of Agreement/Dispute’ section to follow. How the views expressed have been taken account of in the Evidence Report? The Big Place Consultation exercise has given us an up-to-date awareness of the primary concerns of our communities about their places, and by bringing the results of the Place Standard sessions together we have a better understanding not just about issues within specific settlements, or localities, but a holistic overview of the Perth and Kinross Area as a whole. It has also helped to ensure that across the various policy issues included within this Evidence Report the available evidence we have gathered is appropriate and relevant to the concerns raised by our communities, which in turn will ensure that the development of our Spatial Strategy considers those concerns. The main overall concerns of relevance to the Culture and Creativity issue centre around the desire to protect and enhance existing built and natural heritage assets, which are regarded as making a great contribution towards sense of place, identity and belonging, alongside improved levels of care and maintenance of the public realm; better connection to greenspaces and natural places, squares, and heritage assets, and improvements to the number and cost of venues and facilities for use by communities, particularly in more rural areas, as well as upgrades to their condition and standard. Traffic and parking came out as a primary concern
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23 in general across Perth and Kinross, and traffic noise levels were thought to detract from people’s enjoyment of public spaces. Better transport connections to key locations, whether by public transport or active travel, or car parking at these places to make them more accessible, was highlighted as important to communities, as too was the provision of more seating and sheltered areas to aid enjoyment of places and spaces. It is considered that those issues raised by communities and potential solutions suggested would be most appropriately looked at in more detail through our Settlement Audit exercise, which will follow on from this Evidence Report production, to ensure our LDP3 Spatial Strategy reflects not only the needs and concerns of individual local communities, but that any specific solutions identified through the Plan have been developed taking account of all relevant policy areas and potential new site proposals, to deliver multiple benefits for our people, places and nature. Although the Tay Forest National Park bid was not successful, the associated consultation and engagement undertaken provides us with a better insight into the concerns and priorities of the people who live and work in that area, but also those qualities which they value the most, and the improvements that they would like to see. Cultural activities (music, art, events) are regarded as a key feature of the area, and the preservation and celebration of local landscapes and cultural heritage were also recognised as being important to people. Participants wished to see a wider range of business, services and employment opportunities which are not concentrated in the main population centres, and more play and recreation opportunities (both indoor and outdoor) for different age groups which are inclusive. These key issues raised correspond with NPF4 National Planning Policies (Culture and Creativity, Natural Places, Historic Assets and Places, Infrastructure, Blue and Green Infrastructure, Community Wealth Building, Business and Industry, Retail, City, Town and Commercial Centre, Rural Development, and Tourism) and have been considered in turn under the relevant issues of this Evidence Report in terms of relevant sources of evidence and the likely implications of that evidence to the development of our Proposed LDP3.
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24 Statements of Agreement/ Dispute: 8 responses were received on our Culture and Creativity Topic Paper, 2 of which came from respondents who did not provide their name or contact details. Most respondents (6 out of 8) either agreed with or had no comment to make on the evidence identified through Topic Paper 030, and the summary of the implications of that evidence for the Proposed Plan provided by the Council. A number offered examples of additional sources of information which they felt should be considered. A summary of these comments, their status, and the Council’s response are provided in the table below. There were 2 responses on the Culture and Creativity 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 Errol Community Council Neither List of Evidence/Datasets: Disagree with evidence and datasets identified under Topic Paper 030. Comments that there is not enough evidence of community based cultural activity, such as informal adult classes, voluntary and youth groups and how these can be supported and connected to the larger vision of cultural activity and growth in Perth and Kinross. Summary of Implications for Proposed Plan (PP): Neither agree nor disagree. Further Comments: No further comments made. Formal Dispute: Errol Community Council does not wish their response to be treated as a formal dispute. PKC welcomes the comments made by Errol Community Council regarding the light touch reference to community based cultural activity and recognition of this be connected to the larger vision of cultural activity and growth across the Council Area. The ‘Cultural Strategy Locality Profiles’ section of Topic Paper 030 (pages 17 to 18) does refer to various community-led events and activities happening across Perth and Kinross which were identified through the work on producing the Cultural Strategy, but it does not drill down into a list of specific informal community based activities currently on offer. Topic Paper 019: Local Living and 20 Minute Neighbourhoods does provide a link (on page 27) to the ‘Your Community PK’ website, under the ‘Social Interaction, and Support and Advice Services’ section, which provides an extensive list and map of services available under a number of categories. Reference to this website and the activities on offer, as well as the contribution they make to the cultural and creative offering across the Perth and Kinross Area has now been included under the Culture and Creativity
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25 Respondent Agree or Dispute Summary of Comments PKC’s Response issue for this Evidence Report. A summary of implications of this evidence for the development of the Proposed Plan has also been provided. The cultural and creative offerings in a place will be explored in more detail through the Settlement Audit work in relation to identifying local living and 20 minute neighbourhoods under NPF4 Policy 15. No further action required for this Evidence Report. Historic Environment Scotland (HES) Agree List of Evidence/Datasets: Agree Summary of Implications for Proposed Plan (PP): Agree Further Comments: HES welcome the recognition given in Topic Paper 030 to the key contribution of the historic environment in this area. HES provided a report alongside their response which includes information on relevant cultural work and initiatives they are working on with partners in the area. Formal Dispute: Not applicable. PKC welcomes Historic Environment Scotland’s comments on Topic Paper 030: Culture and Creativity. The list of relevant evidence and datasets for this issue referred to in the report provided by HES has been included for the Culture and Creativity issue of this Evidence Report. Much of the detailed information on specific assets and places provided by HES in their response will more appropriately be taken forward through the Historic Assets and Places, Business and Industry, and Tourism issues in particular, and also through our Settlement Audit work to inform our Spatial Strategy. No further action required for this Evidence Report. Montagu Evans LLP on behalf of Loch Developments Ltd. Neither List of Evidence/Datasets: Montagu Evans LLP (on behalf of Loch Developments Ltd.) indicated in their response to Topic Paper 030 that they neither agree nor disagree with the list of evidence and datasets identified under the topic. Summary of Implications for Proposed Plan (PP): Neither agree nor disagree with the summary of implications of the evidence for the Proposed Plan No response necessary and no further action required for this Evidence Report.
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26 Respondent Agree or Dispute Summary of Comments PKC’s Response as provided in Topic Paper 030: Culture and Creativity. Further Comments: No further comments made. Formal Dispute: Not applicable. Private Individual Dispute List of Evidence/Datasets: Respondent disagrees with evidence and datasets provided in Topic Paper 030: Culture and Creativity, specifically paragraph 2.21 of the paper. They comment that the employment data provided at this paragraph fails to delineate between seasonal and full time employment, and also transient employment; citing an example as the renewable energy sector which will have significant employment during the building phase of a project, but when completed the employment will be minimal with most sites run unattended with a ‘flying squad’ sent for routine work and maintenance. Furthermore, the hospitality industry will peak in the summer months and fall in the winter months. Summary of Implications for Proposed Plan (PP): Respondent disagrees with the summary of implications because of the employment data being misrepresented, as outlined above. Further Comments: No further comments made. Formal Dispute: Respondent wishes their dispute to be registered as a formal dispute due to the implications of the misrepresented employment data. Paragraph 2.21 of Topic Paper 030 summarises the total number of people in the Perth and Kinross Area employed in the Creative Industries sector in 2022, according to the Scottish Government’s March 2024 Growth Sector Local Authority Area Statistics data. This is reported for the purpose of highlighting the valuable contribution this sector makes to the Perth and Kinross Area and the Tay Cities Region. This Scottish Government data source does not provide detailed employment make up of the various sectors i.e. in terms of seasonal and full time employees etc. The percentage share data for other sectors has been provided purely for comparative reasons to give an overview of how the Creative Industries are performing relative to the other key growth sectors for the Tay Cities Region. The further inclusion of summaries of other relevant strategies for the Tay Cities Region is for the purpose of confirming the importance given to the Creative Industries in the future growth of the Region and as a priority for action. NPF4 Policy 31 states that LDPs should recognise and support opportunities for jobs and investment in the creative sector, culture, heritage and the arts. Through its Spatial Strategy and any local policies, LDP3 will be concerned with supporting the delivery of those Cultural
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27 Respondent Agree or Dispute Summary of Comments PKC’s Response and Creative projects, objectives, visions, priorities and actions contained within the Tay Cities Deal, the regional and local economic strategies, and Tay Cities Region Tourism Strategy, to help the future growth of this key sector. NPF4 does not make a distinction between full time, seasonal or transient employment opportunities for this issue; the policy intent is ‘to encourage, promote and facilitate development which reflects our diverse culture and creativity, and to support our culture and creative industries.’ No further action required for this Evidence Report. Savills on behalf of Scone Estate Dispute List of Evidence/Datasets: No comments made. Summary of Implications for Proposed Plan (PP): No comments made. Further Comments: Respondent on behalf of Scone Estate comments that there is a lack of data included in Topic Paper 030: Culture and Creativity on the contribution of estates and significant historic and cultural locations, such as Scone Palace and grounds to the cultural life of Perth and Kinross. The cultural and creative events and fairs run by Scone draw significant numbers to the area and play a huge role in nurturing the cultural sector in Perth and Kinross. Formal Dispute: Respondent wishes their response to be registered as a formal dispute for the reason outlined above under the ‘Further Comments’ section. Topic Paper 030 does highlight the importance of our heritage assets and landscapes to the culture and quality of life of the people of Perth and Kinross, and also the unique experience they provide to visitors, through the ‘Culture and Creativity – Perth and Kinross’ section of the Topic Paper (paragraphs 2.6 to 2.13) and also in the summaries for the Perth and Kinross Cultural Strategy (paragraphs 2.38 to 2.57), the Tay Cities Region Tourism Strategy (paragraphs 2.32 to 2.37) and the various Design Charettes (paragraphs 2.68 to 2.75) and Community Action Plans (paragraphs 2.77 and 2.78). However, it is acknowledged that specific reference to estates, like Scone Palace, and the events held at these locations and the contribution those events make, has not been made within the Topic Paper. As such, rather than name all of the specific venues, facilities and events, as much of this will be more appropriate to the Proposed Plan stage of LDP3’s production, the summary of the Tay Cities Region
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28 Respondent Agree or Dispute Summary of Comments PKC’s Response Tourism Strategy in this Evidence Report has been updated to bring out the references included in that document to the heritage assets of the region being one of our strengths, along with the diverse programme of cultural events and festivals, and a strong network of performing arts organisations. Historic Environment Scotland’s Responsible Tourism Framework, and the Perth City and Town website and PKC Events webpage, which provide information on the various cultural events on offer across the Council Area and where, have also been included. This is for the purposes of highlighting the breadth of the cultural and creative offer within Perth and Kinross, and demonstrating the important role venues and facilities, including historic environment assets, play in the provision of that offer. No further action required for this Evidence Report. Scottish Water Neither List of Evidence/Datasets: Neither agree nor disagree. Summary of Implications for Proposed Plan (PP): Neither agree nor disagree. Further Comments: Scottish Water acknowledge the contents of Topic Paper 030 but have no further comments to make. Formal Dispute: Not applicable. No action required for this Evidence Report. Anonymous Neither List of Evidence/Datasets: Neither agree nor disagree. Respondent highlights that there is updated data available from Visit Scotland in relation to Perth and Kinross. It relates to the Scotland Visitor Survey as well as visitor numbers. These will provide post-pandemic insights. Welcomes respondent flagging the updated data available from Visit Scotland for the Perth and Kinross Area. The subject of tourism was raised in relation to the issue of Culture and Creativity as the strong connection between the cultural and creativity offering in a place and attracting tourism and investment is
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29 Respondent Agree or Dispute Summary of Comments PKC’s Response Respondent also comments that the Culture and Creativity Topic Paper 030 places emphasis on the investment in culture through the Tay Cities Region Deal, in particular the Tourism and Culture Investment Programme, but it is not referenced in the Tourism Topic Paper 029. They continue that it is worth referencing as there has been a significant amount of investment by the public, private and third sectors in tourism. Summary of Implications for Proposed Plan (PP): Agree with the summary of implications of the evidence and datasets for the Culture and Creativity issue as provided in Topic Paper 030. Further Comments: No further comments. Formal Dispute: Not applicable. recognised. It is considered that the updated Visit Scotland data would be best referenced under the Tourism issue in this Evidence Report, and reference to the Tay Cities Deal Tourism and Culture Investment Programme also. However, a brief reference to some relevant statistics from that survey report has been included in the Culture and Creativity issue of this evidence report. No further action required for this Evidence Report. Anonymous Neither List of Evidence/Datasets: Strongly agree. Summary of Implications for Proposed Plan (PP): Neither agree nor disagree with summary provided in Topic Paper 030: Culture and Creativity. Further Comments: Respondent comments that if, as they have heard, that schools are cutting back on music and art, they think it is imperative that we can provide other resources outside of schools to promote, educate and give opportunities for young people in the community. Formal Dispute: Not applicable. Section 15(5) of the Town and Country Planning (Scotland) Act 1997, as amended by the Planning (Scotland) Act 2019 states that a local development plan is a plan in which is set out, for the land in the part of the district to which it relates: (a) A spatial strategy, being a detailed statement of the planning authority’s policies and proposals as to the development and use of land, taking account of the matters mentioned in subsection (5), which includes the desirability of maintaining an appropriate number and range of cultural venues and facilities (including in particular, but not limited to, live music venues) in the district. The policy intent of NPF4 Policy 31 is ‘to encourage, promote and facilitate development which reflects our
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30 Respondent Agree or Dispute Summary of Comments PKC’s Response diverse culture and creativity, and to support our culture and creative industries.’ And one of the three policy outcomes is that ‘communities have access to cultural and creative activities.’ The Perth and Kinross Cultural Strategy includes a pledge to support young people to learn, work and grow skills through culture. Our LDP3 Spatial Strategy will be developed in alignment with our Cultural Strategy, and the intent, outcomes and requirements of NPF4 policy. As part of the LDP3 Settlement Audit work investigate the existing number and range of cultural venues and facilities offered across the Council Area, with a view to safeguarding existing venues/facilities and encouraging, promoting and facilitating new development opportunities to support culture and creative industries, including those for the arts and music.
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31 Number and Range of Venues and Facilities Part 2, Section 16(B)(3) and Section 15(5)(ch) of the Planning Act (2019) requires that, as part of the preparation of their Evidence Report, that planning authorities set out their views on the desirability of maintaining an appropriate number and range of cultural venues and facilities (including in particular, but not limited to, live music venues). Within the Perth and Kinross Area there are examples where support has been shown to support cultural venues and facilities most notable the Perth and Kinross Culture Strategy 2023-2028 which includes support for maintaining venues, supporting festivals and local culture across the area. The venues are across Perth and Kinross with some having international status include Perth Theatre and Concert Hall, Perth Museum and Pitlochry Festival Theatre. The Perth Museum is an example of direct support from the Council, opening in 2024 and housing the Stone of Destiny and supporting revitalisation of the city centre. There is also support for those wanting to enter the cultural environment, with Perth College (part of the University of the Highlands and Islands (UHI)) having 650 culture and creative industry students. In light of the specific requirement in the Act the Proposed Plan will need to consider what can be put in place to support the Council’s desire to support culture and creativity. Gaps, Uncertainties or Key Issues Raised: It is planned as part of the Settlement Audit work for LDP3 to develop a Localities Profile template which will set out those factors which officers need to take account of in developing their understanding of each place and its needs to satisfy the requirements of the Planning Act, Regulations, LDP Guidance and NPF4 policies. This should allow for an up-to-date GIS based audit of existing cultural offering in a place and highlight where there is a known demand for additional or improved opportunities and facilities. The template has yet to be developed but will be in place prior to work beginning on the Proposed Plan.
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Issue: Minerals Corresponding NPF4 Policy/Policies: National Planning Framework 4, Policy 33 Minerals Other key NPF4 policy connections – 1: Tackling the climate and nature crises; 3: Biodiversity; 4: Natural Places; 7: Historic assets and places; 12: Zero waste; 18: Infrastructure first; and 23: Health and safety. Corresponding Perth and Kinross LDP3 Topic Paper: Topic Paper 031: Minerals https://consult.pkc.gov.uk/communities/copy-of- topicpapers2/supporting_documents/TP031%20Minerals.pdf Information required by the Act and NPF4 regarding the topic: Section 15(5) of the Town and Country Planning (Scotland) Act 1997, as amended: • The principal economic and environmental characteristics of the district in relation to minerals NPF4 Policy 33 expects LDP to ‘…support a landbank of construction aggregates of at least 10-years at all times in the relevant market areas.’ The policy intent for Policy 33 is noted as: • To support the sustainable management of resources and minimise the impacts of the extraction of minerals on communities and the environment The policy outcomes for Policy 33 are: • Sufficient resources are available to meet industry demands, making an essential contribution to the Scottish economy. • Important raw materials for manufacturing, construction agriculture, and other industries are available. • Important workable mineral resources are protected from sterilisation by other developments. • Communities and the environment are protected from the impacts of mineral extraction. The Scottish Government’s Local Development Plan Guidance (May 2023) under its ‘step by step guide’ provides advice on relevant evidence for the NPF4 policy topics to help planning authorities in considering the national planning policies when preparing their Evidence Report. With respect to NPF4 Policy 33, the guidance advises that planning authorities may include information that can demonstrate if the planning authority is capable of meeting at least a 10-year landbank of construction aggregate in relevant market areas. The types of information that may be relevant include: • information on existing permitted minerals reserves within the plan area; • any relevant elements from the latest Aggregates Survey around usage trends. This information can help inform whether there is
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sufficient supply of minerals or whether it is expected that further releases are required; and • the guidance advises that where appropriate a local aggregates survey may be undertaken with local operators to better understand demand and reserves. Links to Evidence: Results of the 2019 Aggregate Minerals Survey for Scotland (September 2023) A preliminary geological assessment of Craiglea Quarry, Logiealmond, Perthshire (2022): Decarbonisation & Resource Management Programme Open Report OR/22/042 - https://nora.nerc.ac.uk/id/eprint/535694/1/OR22042_BGS_report_Craigle a_Quarry_Slate.pdf Summary of Evidence: Minerals in Perth and Kinross Perth and Kinross has the following active minerals sites: • Collace Quarry, Perth: crushed rock • Balado Quarry, Balado: sand and gravel • Loanleven Quarry, Almondbank: sand and gravel • Marlee Quarry, Essendy: sand and gravel • Shierglas Quarry, Pitlochry: crushed rock It also has dormant sand and gravel and crushed rock sites across the Local Development Plan area, as well as significant barite reserves at Duntanlich. The 2019 Aggregate Minerals Survey for Scotland The Scottish Government’s Aggregate Minerals Survey provides comprehensive data for monitoring aggregates provision at both local and regional levels and its outputs are used to inform the development of minerals policy. The study uses new geographical areas for collating returns. These areas aim to support development planning policy while also recognising the difficulties of defining market areas in a country like Scotland with considerable variation in population density and geology. This means that Perth and Kinross is not a stand-alone geographic area but forms part of the Tay area of the study, which comprises Angus Council, Dundee City Council and Perth and Kinross Council. For the purposes of the Scottish Aggregates Survey, results from Perth and Kinross are therefore collated together with those from Angus and Dundee. The study outlines that Tay area has reserves of crushed rock, and sand and gravel: • in the Tay area, the study includes results from nine minerals sites, six of which are for crushed rock, and three of which are for sand and gravel • the Tay area also includes Forth Valley sand and gravel The Aggregate Minerals Survey published data tables setting out sales and permitted reserves allowing a rough calculation to be made of estimated years supply based on 2019 sales. The survey reports that the choice of gathering data based on 2019 sales and reserves was chosen to avoid calendar years 2020 and 2021, where
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quarries and their customers were operating under varying degrees of COVID-19 pandemic restrictions. For crushed rock, the survey reports the following sales, reserves and estimated years supply: Sales Estimated permitted reserves Maximum supply at 2019 sales levels in years Estimated permitted reserves in active sites at end 2019 Maximum supply from active sites at 2019 sales levels in years Tay 434,000 13,039,000 30 10,360,000 24 For sand and gravel, the survey reports the following sales, reserves and estimated years supply: Sales Estimated permitted reserves Maximum supply at 2019 sales levels in years Estimated permitted reserves in active sites at end 2019 Maximum supply from active sites at 2019 sales levels in years Tay 441,000 2,650,000 9 2,650,000 9 The tables give an indicative length of available supply, based on the sales from sites in the year 2019. The tables suggest that in the Tay area, there are sufficient permitted reserves for crushed rock but that there may not be sufficient reserves of sand and gravel to meet the demand for a 10-year landbank, as required by NPF4. It is recognised that several years will have elapsed between completion of the survey and publication of the Proposed Plan. Turning to inter-regional product flows, the Tay area, of which Perth and Kinross is a part, is both an exporter and importer of sand and gravel, mainly to the Forth Valley, Fife and West Central Scotland areas. The amount of sand and gravel exported and imported to the area in 2019 was 194,000 tonnes exported, and 240,000 tonnes imported.
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The Tay area is both an importer and exporter of crushed rock to the Fife area, and an exporter of crushed rock to the Highland area. The amount of crushed rock exported and imported to the area in 2019 was 83,000 tonnes exported, and 164,000 tonnes imported. Coal extraction and unconventional oil and gas extraction • There are no areas where coal extraction is taking place. • The effective Scottish Government moratorium on unconventional oil and gas remains in place. Summary of Implications for the Proposed Plan: NPF4 sets out a requirement that the Local Development Plan should support a landbank of construction aggregates of at least 10-years at all times in the relevant market areas. The Proposed Plan will need to identify this 10-year landbank requirement, and updated survey results will be used to prepare the plan. Specifically, the 2023 Scottish Aggregate Minerals Survey results are expected to become available shortly to assist. The Proposed Plan will not be able to precisely calculate whether a 10-year landbank exists without improved data on demand and product flows. • There are questions about how to define a minerals market area, since some minerals products are transported longer distances than others because they are of higher value or are specialist products • NPF4 policy 12 Zero Waste requires more use to be made of recycled materials, which will affect the amount of virgin material required to be quarried. However, this policy requirement must be balanced against the economic and environmental impact of transporting in recycled material to locations where the material may be quarried more locally • NPF4 also directs more reuse of existing buildings over demolition and redevelopment • There is a question over whether a 10-year landbank should take account of day-to-day requirements or should make provision to include major projects to take place in the period of the Proposed Plan • A methodology for calculating the 10-year landbank might be produced to improve consistency across Local Development Plans in Scotland It is likely that a local aggregates survey undertaken with local site owners and operators will be necessary. While good data exists in respect of permitted reserves and previous rates of extraction, there are likely to be data gaps around predicting future demand for minerals, and understanding planned future operations at minerals sites, including any sites that are currently dormant. Turning to other minerals policy matters, the adopted Local Development Plan did not identify minerals areas of search, instead a policy-based approach was employed. The Proposed Plan will need to consider to what extent it continues to rely on this policy framework (taking into account the newer NPF4 Policy 33 Minerals) or whether it should have additional policy criteria against which applications for minerals permissions will be assessed.
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The Proposed Plan will need to continue to prioritise the safeguarding of important workable mineral resources from sterilisation by other developments. We will need to consider whether the content of the Financial Guarantees for Minerals Development Supplementary Guidance will need to be integrated into the Proposed Plan, or alternatively be retained as guidance. Coal extraction and unconventional oil and gas extraction • There is no need to consider areas of search for coal extraction. • Unconventional oil and gas extraction is not supported in NPF4. Gaps, Uncertainties or Key Issues Raised: Crushed rock and sand and gravel In the absence of data on predicted demand for minerals, a 10-year landbank cannot be accurately calculated. The evidence suggests that in the Tay area, there are sufficient permitted reserves for crushed rock but that there may not be sufficient reserves of sand and gravel to meet the demand for a 10-year landbank, as required by NPF4. It is proposed to close this evidence gap by carrying out more engagement with the minerals industry, including industry bodies and active operators. This will allow us to state with more confidence whether a 10-year landbank exists. This may entail examining annual sales and minerals reserves at each site in Perth and Kinross, and discussing future operations including potential expansion plans. A local aggregates survey aimed at understanding reserves and predicting demand is likely to be necessary. Other materials - slate Following information provided by Historic Environment Scotland, the owner of Craiglea Slate Quarry will be contacted to establish further evidence on the proposed production of slate from the site. Summary of Stakeholder Engagement: Big Place Conversation The Council carried out its ‘Big Place Conversation’ exercise to kick start the LDP3 process across Perth and Kinross communities during most of 2023. This was a substantial exercise involving over 100 events throughout the Council area. The events ranged from drop-in information sessions, meetings, and online surveys to workshops and online sessions using the Place Standard Tool to capture the views of local communities about different aspects of their places. The results of the BPC are summarised as part of a separate report on the outcomes and findings across the different locality areas. LDP3 Evidence Report Topic Papers The Council produced a series of LDP3 Evidence Report Topic Papers, covering the individual subject matters of NPF4’s suite of national planning policies. These papers, which set out the detailed evidence the Council has gathered to help produce our Evidence Report and which we hope to use to help prepare our Proposed Plan, were published on the Council’s Consultation Hub and open for comments for a period of 6 week during July and August 2024. As part of our consultation process for LDP3 Topic Papers we welcomed the views of our key stakeholders (who were contacted specifically via email regarding the consultation exercise) and the public at large, on the sufficiency of the evidence gathered, our interpretation of the implications of that evidence to the Proposed Plan,
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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. Coal extraction and unconventional oil and gas extraction Due to the policy position of NPF4, the Council has not engaged with fossil fuel operators, nor onshore oil and gas operators. This is not considered a data gap Statements of Agreement/ Dispute Three responses were received on our Minerals topic paper, one of which was anonymous. Historic Environment Scotland offered an additional source of information that we will consider when preparing the Proposed Plan. The two remaining responses offered no comment on the evidence identified through the topic paper, but did encourage the use of the latest available Aggregates Mineral Survey results when preparing the Proposed Plan. The Council agrees. A summary of these comments, their status, and the Council’s response is provided in the following table. There were no responses on Minerals that the respondents wished to be treated as a formal dispute to the evidence report.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Historic Environment Scotland Agree List of Evidence/Datasets: Agree Summary of Implications for the Proposed Plan: None Further Comments: To note, Historic Environment Scotland have been working with the Logiealmond Estate to explore opportunities for Craiglea slate quarry. The British Geological Survey have produced an assessment on the quarry and the owners are looking at how the quarry can generate income by producing slate products (roofing slate, building stone, monumental as well as any geotoursim opportunity etc). https://nora.nerc.ac.uk/id/eprint/535694/1/OR22042_BGS_report_Craiglea_Quarry_Slate.pdf Formal Dispute: No. Historic Environment Scotland’s comment on opportunities for Craiglea slate quarry is noted and will be used in the Preparation of the Proposed Plan Anonymous Agree List of Evidence/Datasets: Agree Summary of Implications for the Proposed Plan: None Further Comments: Delay in publication of Aggregates Mineral Survey Results is regrettable Formal Dispute: No. The Council will use the latest available Aggregates Mineral Survey results when preparing the Proposed Plan Earn Community Council Agree List of Evidence/Datasets: Agree Summary of Implications for the Proposed Plan: Further Comments: The absence of the Aggregates Mineral Survey Results for 2020-23 means that the LDP may need to be adjusted at a later point in order to match the NPF4 Policy Formal Dispute: No The Council will use the latest available Aggregates Mineral Survey results when preparing the Proposed Plan