Democracy Spraffa

Appendix E - Productive Places

Perth and Kinross Council · 5 March 2025
Back to Perth and Kinross Council — 5 March 2025 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

Original council PDF · Download plain text

Some pages contain no extractable text. They may be blank, graphics or scanned pages. OCR has not been applied.

Page 1

Perth and Kinross LDP3 2027
Draft Evidence Report Appendix  E Productive Places 
March 2025

Page 2

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

Page 3

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

Page 4

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.

Page 5

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.

Page 6

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.

Page 7

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.

Page 8

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

Page 9

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.

Page 10

• 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

Page 11

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

Page 12

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

Page 13

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

Page 14

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.

Page 15

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

Page 16

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)

Page 17

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:

Page 18

• 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

Page 19

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.

Page 20

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

Page 21

• 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.

Page 22

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.

Page 23

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.

Page 24

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

Page 25

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

Page 26

- 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

Page 27

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

Page 28

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.

Page 29

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.

Page 30

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

Page 31

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.

Page 32

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

Page 33

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

Page 34

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.

Page 35

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.

Page 36

No embedded text on this page.

Page 37

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.

Page 38

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

Page 39

• 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

Page 40

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

Page 41

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

Page 42

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

Page 43

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)

Page 44

• - 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

Page 45

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:

Page 46

• 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.

Page 47

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.

Page 48

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

Page 49

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

Page 50

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.

Page 51

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.

Page 52

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.

Page 53

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

Page 54

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,

Page 55

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).

Page 56

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

Page 57

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

Page 58

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.’

Page 59

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

Page 60

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.’

Page 61

No embedded text on this page.

Page 62

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:

Page 63

• 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.

Page 64

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

Page 65

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

Page 66

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.

Page 67

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.

Page 68

ACCESSIBLE SMALL TOWNS 
Auchterarder  New Scone 
Kinross

Page 69

REMOTE SMALL TOWNS 
Blairgowrie  Crieff

Page 70

OTHER TOWNS IN THE REMOTE RURAL AREAS 
Aberfeldy  Dunkeld and Birnam 
Pitlochry

Page 71

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 ©

Page 72

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

Page 73

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.

Page 74

• 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

Page 75

• 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

Page 76

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.

Page 77

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

Page 78

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

Page 79

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.

Page 80

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.

Page 81

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.

Page 82

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

Page 83

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

Page 84

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

Page 85

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.

Page 86

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

Page 87

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

Page 88

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

Page 89

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.

Page 90

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.

Page 91

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

Page 92

• 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%)

Page 93

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

Page 94

LDP2 Tourism sites 
LDP2 identifies those areas which are currently in tourism use. 
© Crown copyright [and database rights] 2024 OS AC0000805756.

Page 95

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.

Page 96

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.

Page 97

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

Page 98

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:

Page 99

• 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.

Page 100

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

Page 101

• 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.

Page 102

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

Page 103

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,

Page 104

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.

Page 105

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.

Page 106

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.

Page 107

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.

Page 108

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

Page 109

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.

Page 110

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.

Page 111

No embedded text on this page.

Page 112

No embedded text on this page.

Page 113

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.

Page 114

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

Page 115

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).

Page 116

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.

Page 117

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.

Page 118

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

Page 119

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

Page 120

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

Page 121

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

Page 122

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.

Page 123

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.

Page 124

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

Page 125

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

Page 126

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.

Page 127

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

Page 128

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,

Page 129

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,

Page 130

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.

Page 131

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

Page 132

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

Page 133

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

Page 134

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

Page 135

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.

Page 136

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

Page 137

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.

Page 138

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

Page 139

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

Page 140

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

Page 141

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

Page 142

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.

Page 143

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.

Page 144

32

Page 145

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

Page 146

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

Page 147

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.

Page 148

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.

Page 149

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,

Page 150

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.

Page 151

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