Appendix F - Other Comments Received
Perth and Kinross Council · 5 March 2025
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Perth and Kinross LDP3 2027 Draft Evidence Report Appendix F Other Comments Received March 2025
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Issue: Place Comments
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Statements of Agreement/ Dispute Respondent Agree or Dispute Summary of Comments PKC’s Response Kenmore Community Council Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The Community Council indicated that they neither agreed nor disagreed with the sufficiency of the list of evidence/datasets identified and our summary of implications of that evidence for the preparation of the Proposed Plan. Further Comments: The Community Council highlighted a number of key priorities for the area including the intention to prepare a Local Action Plan for the area, in conjunction with the Loch Tay & Glen Lyon community. Key priorities/issues identified by the Community Council included: • Little scope for development in the village • Reaffirmation of community housing to be delivered through allocation H42 • Retention of open spaces between roads and the Loch, and treat land behind new toilets as open space • Number of suggestions to relieve pressure within the village associated with tourism and visitor numbers • Addressing key issues around road infrastructure and safety • Broadband improvements and community benefits • Promote Loch Tay as a ‘quiet loch’ and address biodiversity issues Place-based feedback is noted and will be used alongside other engagement results/feedback and community-led plans to inform the development of the Spatial Strategy. Comments relating to addressing the imbalance between holiday and residential accommodation, and suggestions to relieve pressures are considered under the ‘Tourism’ issue in Appendix E5.
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Respondent Agree or Dispute Summary of Comments PKC’s Response • Address imbalance between holiday and residential accommodation Formal Dispute: Kenmore Community Council do not wish for their response to be treated as a formal dispute. Aberfeldy Community Council Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The Community Council indicated that they generally agreed with the sufficiency of the list of evidence/datasets identified and our summary of implications of that evidence for the preparation of the Proposed Plan. Further Comments: The Community Council highlighted a number of key points around the need for more (affordable) housing in the area including in Aberfeldy and the surrounding settlements. A number of suggestions are put forward including: • Range of additional housing sites to be identified and not relying on current allocated site in Aberfeldy • Loss of residential housing to holiday accommodation therefore suggestion for higher affordable housing % as part of new developments • Greater flexibility in permitted development rights to support multi-generational living • Support conversion of holiday accommodation into full time residential accommodation • Surrounding smaller settlements to support delivery of new affordable housing development to lessen impact on Aberfeldy Place-based feedback is noted and will be used alongside other engagement results/feedback and community-led plans to inform the development of the Spatial Strategy. Comments relating to the range of sites, distribution of new affordable housing development, and suggestion for a higher affordable housing contribution are considered under the ‘Homes’ issue Appendix C1.
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Respondent Agree or Dispute Summary of Comments PKC’s Response The Community Council have also put forward a suggested site for a cemetery in response to the demand/need for further burial provision in the area. Formal Dispute: Kenmore Community Council do not wish for their response to be treated as a formal dispute. Montagu Evans LLP on behalf of Loch Developments Ltd Neither List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): Comment considers that further understanding should be given to the implications of the committed Flood Defence works, such as those in Kinross, which will influence the flood risk data. Loch Developments Ltd have been in dialogue with the Council’s flood team, on the delivery of the flood protection scheme, in line with the redevelopment of the former BCA site at Kinross. As a result of this, some sites including the former BCA Site in Kinross are not expected to be at risk of flooding following the implementation of the flood defence works. Further Comments: Montagu Evans do not wish to make any further comments Formal Dispute: Montagu Evans do not wish for their response to be treated as a formal dispute. This comment is responded to in the Issue B5 Flood Risk and Water management. Montagu Evans LLP on behalf of Loch Developments Ltd Agree List of Evidence/Datasets: No comments Summary of Implications for Proposed Plan (PP): No comments Further Comments (from topic paper 10): The former BCA site is a large are of vacant and derelict land within the settlement of Kinross. This could be sustainably reused to provide a mix of uses including housing, and retail. The former BCA site should be allocated as a mixed use site to promote the redevelopment of this area of vacant and derelict land. Place-based feedback is noted and will be used alongside other engagement results/feedback and community-led plans to inform the development of the Spatial Strategy.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Further Comments (from topic paper 20): The allocation and the subsequent development of the former BCA site in Kinross will contribute to the sustainable delivery of new homes in Kinross. It is considered that there is demand for housing in Kinross, with the majority of previously allocated sites now under construction. Looking to the next ten years there will be a need to allocate more housing land in Kinross. The allocation of the former BCA site, which is an area of brownfield land within the settlement boundary, for a mix of uses including residential will allow Perth and Kinross to provide new housing within Kinross which would comply with a number of other supporting policies including 20 minute neighbourhoods. Formal Dispute: No Not provided Disagree and records a formal dispute List of Evidence/Datasets: There does not appear to be any on the ground assessment of areas impacted / covered by the green belt. This should come before any consideration of the green belt. The settlement of Craigend should be omitted from the green belt and identified as a settlement with a settlement boundary around it. This is a gap / uncertainty within the evidence gathered. Assessment should include consideration of the value of Craigend to the green belt. Summary of Implications for Proposed Plan (PP): Only refers to release of 'large-scale areas of land for planned growth'. It should also refer to small and medium growth and to newly identified settlements and settlement boundaries. This comment is responded to in the Issue A6 Greenbelts. Comments on green belt review have been considered under the Homes for Scotland response within Issue A6. Further detail is provided in this response.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: The respondent wishes their comments to be recorded as a formal dispute on the grounds that Craigend requires to be properly considered on the ground and compared against the other similar settlements around Perth which have been omitted from the green belt. Earn Community Council Agree List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: Whilst not directly related, reference needs to be made to increased traffic in the Perth West boundary area and in particular, the frequent congestion at Broxden. In Scone have reservations about the wisdom of PKC retaining the original North Scone LDP1 boundary and waiting for the CTLR route to be completed which will itself make a permanent boundary. Note absence of Big Place Conversation report which is unfortunate. Formal Dispute: No This comment is responded to in the Issue A6 Greenbelts.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Not provided Disagree and records a formal dispute List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): Disagree and comment highlights concern about Rattray and Blairgowrie in relation to maintenance of streets, housing, green spaces, and vacant sites. Further Comments: Comment highlights concern about Rattray and Blairgowrie in relation to maintenance of streets, housing, green spaces, and vacant sites. Formal Dispute: Yes Place-based feedback is noted and will be used alongside other engagement results/feedback and community-led plans to inform the development of the Spatial Strategy.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Savills on behalf of Scone Estate Not stated List of Evidence/Datasets and summary of Implications for Proposed Plan (PP): No comments Further Comments: Note that work on identifying 20-minute neighbourhoods has not yet commenced. It must be remembered that PKC is predominantly rural, and that work should be done to increase resilience of settlements via innovative means to deliver critical Local Living focused services, as opposed to blanket restrictions on development based on current services. The sustainability of rural areas is dependent on population growth. People will be needed to live on the land managing it for sustainable outcomes. Lack of local housing in rural areas is driven by restrictive planning policies and weak markets with limited housebuilder activity. Planning policies should seek to be supportive of housing in rural areas as the market and availability of builders form their own deterrent to any proliferation of rural housing. Provision of homes is an essential element of Scone Estates business. More can be done, and there is significant demand, but this needs to be balanced with the ability to sell small and medium-scale housing sites to raise revenues for rural businesses which can then be re-invested in the environment and economy of Perth and Kinross. There is good potential for new housing north and northeast of Perth to fully use the CTLR and the active travel connections it brings. There are also opportunities to improve placemaking and resilience of areas such as Stormontfield. Comments relating to planning policy are considered under Rural Development in Appendix E4 and Homes in Appendix C1.
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Respondent Agree or Dispute Summary of Comments PKC’s Response 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.
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Statements of Agreement/ Dispute: 16 responses were received in relation to Topic Paper 001: The Plan Area. Of those 16 responses, 3 respondents agreed with the list of evidence and summary of implications for the Proposed Plan provided under the topic paper; 5 wished for their comments to be registered as a formal dispute to the Evidence Report; 4 disagreed with the evidence and/or summary of implications but did not wish for their comments to be registered as a formal dispute, and 4 neither agreed nor disagreed with the list of evidence and summary of implications. A Perth and Kinross Council (PKC) response to the points raised through each of the responses is provided in the table below. 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): The respondent agrees with the list of evidence provided under Topic Paper 001 and the summary of implications for the Proposed Plan. Further Comments: Under the further comments section of the consultation questionnaire, the respondent made the following points: • Need for greater and more efficient broadband. Would influence Local Living/20 Minute communities, employment and the environment. • “Inclusive Growth” needs to show this will lead to greater equality. • High percentages of the Perth and Kinross Area is rural, leads to many problems in housing, transport, employment, education and environment. • In general Perth and Kinross seem to perform well compared to national figures. However, the areas of psychiatric care and immunisation for MMR are poor. There is a higher percentage of care in the home than nationally. • The preparation of this LDP3 plan is based on the new NPF4 that became active in February 2023. There are a lot of new policies that are woven into the new format of LDPs, therefore a huge amount of cross referencing in developing this plan – could this result PKC welcomes Earn Community Council’s comments on Topic Paper 001, and responds to the points raised within as follows: • Broadband coverage is considered under the Communications and Digital Infrastructure issue of this Evidence Report, and the key NPF4 policy connection between this form of infrastructure supporting local living and a reduced need to travel is highlighted. • A Just Transition is one of the six overarching spatial principles of NPF4. It states that “we will empower people to shape their places and ensure the transition to net zero is fair and inclusive.” PKC will seek to incorporate these spatial principles in the development and implementation of our LDP3 to help support inclusive growth. • Point noted regarding the rural nature of Perth and Kinross and the associated issues related to that. • Point noted regarding health and social care matters. • Point noted regarding the preparation of LDP3 in alignment with National Planning Framework 4, and the interconnected nature of the policies which will require to be
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Respondent Agree or Dispute Summary of Comments PKC’s Response in making the planning process fairer or more contentious? Formal Dispute: Not applicable. reflected in the development of LDP3 and in the decision-making process. Errol Community Council Dispute List of Evidence/Datasets: The respondent disagrees with the “agriculture map” provided under Topic Paper 001, as they are of the opinion that it does not align with the data in the map at National land Capability for Agriculture in Scotland, due to it not showing the Grade 3.1 and 3.2 capability for Errol and surrounding areas, which they believe is further reinforced by the text in Section 2.5 of the Topic Paper, which highlights the Carse of Gowrie as having rich farmland. Summary of Implications for Proposed Plan (PP): The respondent indicated that they neither agree, nor disagree with the summary of implications of the evidence provided under Topic Paper 001. Further Comments: No further comments made. Formal Dispute: The respondent wishes for their comments to be registered as a formal dispute due to the map shown in Figure 7 of Topic Paper 001 not being accurate compared with the information shown on the map at National Land Capability for Agriculture in Scotland. PKC welcomes Errol Community Council’s comments on Topic Paper 001 and responds that having reviewed Figure 7 in Topic Paper 001 based on those comments, the Community Council are correct in noting that some of the distribution of prime agricultural land has been missed off Figure 7. The shapefile used to create Figure 7 is the ‘National Scale Land Capability for Agriculture, 1:250,000’ dataset, downloaded from Scotland’s Environment (SE) Web – Scotland’s Soils Map. However, the map attributes were filtered in ArcGIS to only show Classes 2, 3.1, and 3.2 and unfortunately some of the Classes 2-3.2 data did not fully pull through at the time of the map being created, and this was missed in error. Although more detailed maps were presented under the Soils Topic Paper (006) which do show the distribution of Classes 2 and 3.1 clearly within the Carse of Gowrie area, this was not the case for Topic Paper 001. The full representation of Classes 2, 3.1 and 3.2 within the Perth and Kinross Council Area has now been included in the SEA Environmental Baseline within the Scoping Report. PKC thanks Errol Community Council for bringing this error to our attention. Homes for Scotland Disagree, but does not wish for comments to be List of Evidence/Datasets: The respondent agrees with the list of evidence and datasets provided under Topic Paper 001: The Plan Area. PKC welcomes Homes for Scotland’s comments in response to Topic Paper 001: The Plan Area. As per the response provided to the respondent’s comments under the Soils issue of
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Respondent Agree or Dispute Summary of Comments PKC’s Response registered as a formal dispute. Summary of Implications for Proposed Plan (PP): The respondent indicated that they disagree with the summary of implications of the evidence provided under Topic Paper 001 in respect of prime agricultural land and highlighted that their comments were also made in response to Topic Paper 006: Soils. The respondent notes that the Scottish Government’s 2023 Local Development Planning Guidance does not reference prime agricultural land. Furthermore, NPF4 Policy 5 “clearly outlines circumstances in which prime agricultural land can be development. This includes for “Essential infrastructure and there is a specific locational need and no other suitable site.” It is the respondents view that a site allocated for residential development would clearly meet this description – as in their opinion, housing is essential infrastructure, the site would have been allocated to meet a specific locational need and was considered by the planning authority to be the most suitable site. The respondent continues that NPF4 appears to reduce the capacity for non-allocated prime agricultural land to be consented. However, it does not restrict the capacity of the Council to allocate this land. The respondent continues that as noted in Topic Paper 001, the population of the area is set to increase, and the profile of the population is expected to shift, with a lager proportion being over the age of 75. It is the respondent’s view that these factors will create significant additional need and demand for new homes, which will require to be considered in setting the Local Housing Land Requirement, and establishing the spatial strategy for the next LDP. Further Comments: No further comments made. this Evidence Report in respect of house building and prime agricultural land – it is noted that a balance needs to be struck between these often- conflicting interest for land use. Specifically in relation to NPF4 Policy 5b, it is important to note that NPF4 includes a glossary (page 148) which identifies those developments considered as “essential infrastructure”. Whilst meeting the housing needs of the area is a key component of the next LDP, house building is not included under this definition in terms of NPF4 Policy 5b, which is used for assessing development proposals through the Development Management process. In developing the Spatial Strategy for LDP3, PKC will need to balance the interests of identifying suitable housing land alongside the need to protect prime agricultural land, including using mitigation measures – guided by the SEA process – where sites on undeveloped land are proposed. No action required for this Evidence Report.
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Respondent Agree or Dispute Summary of Comments PKC’s Response Formal Dispute: The respondent does not wish for their comments to be recorded as a formal dispute. Montagu Evans LLP (on behalf of Loch Developments Ltd.) Neither agree nor disagree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The respondent indicated that they neither agreed nor disagreed with the list of evidence provided in Topic Paper 001, and summary of implications of that evidence for the Proposed Plan but did not make any comments in respect of this. Further Comments: No further comments made. Formal Dispute: Not applicable. No action required for this Evidence Report. Private Individual Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The respondent indicated that they agreed with the list of evidence identified under Topic Paper 001 and the summary provided of the implications of that evidence for the Proposed Plan. Further Comments: Under the further comments section of the consultation questionnaire, the respondent noted the absence of the Big Place Conversation report. Formal Dispute: Not applicable. PKC welcomes the respondent’s comments and would like to add that the results of the Big Place Conversation exercise have now been summarised and included as part of this Evidence Report. No action required for this Evidence Report. Private Individual Neither agree nor disagree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The respondent indicated that they neither agree nor disagree with the list of evidence and datasets provided under Topic Paper 001, and the summary of implications of that evidence for the Proposed Plan. Further Comments: No further comments were made. Formal Dispute: Not applicable. No action required for this Evidence Report. Private Individual Disagree, but does not wish for comments to be List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The respondent indicated that they disagree with the list of evidence and datasets No action required for this Evidence Report.
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Respondent Agree or Dispute Summary of Comments PKC’s Response registered as a formal dispute. provided under Topic Paper 001: The Plan Area, and the summary of implications of that evidence for the Proposed Plan but have not provided any comments in support of that position. Further Comments: No further comments made. Formal Dispute: The respondent does not wish for their response to be registered as a formal dispute. Private Individual Dispute List of Evidence/Datasets: The respondent disagrees with the evidence provided under Topic Paper 001: The Plan Area because the maps in the report are unreadable online. Summary of Implications for Proposed Plan (PP): The respondent indicated that they neither agree nor disagree with the summary of implications of the evidence for the Proposed Plan, but did not provide any comments in respect of this. Further Comments: No further comments made. Formal Dispute: The respondent wishes for their response to be registered as a formal dispute as in their view “to carry out a consultation where the evidence is not readable is not consultation.” PKC welcomes the respondent’s comments, and with regard to the issue raised relating the legibility of the maps included within Topic Paper 001 would respond that it is recognised that the scale of the maps presented as images embedded in the topic paper is not ideal. However, the purpose of providing the maps was to demonstrate that we have access to the relevant datasets in a spatial format, which were reviewed and summarised as part of the topic paper and this Evidence Report, rather than to invite analysis of them at a granular level for the purposes of location specific comments, at this stage in the LDP3 preparation process. However, where available, hyperlinks were provided throughout Topic Paper 001 and other policy specific LDP3 topic papers to online interactive versions of the maps which have zoom functionality to allow closer scrutiny of the evidence if desired by consultees. No further action required for this Evidence Report. Nature Scot Neither agree nor disagree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The respondent comments that Topic Paper 001 is a useful paper for setting the context PKC welcomes Nature Scot’s comments on Topic Paper 001: The Plan Area and responds that it was PKC’s intention to utilise relevant evidence
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Respondent Agree or Dispute Summary of Comments PKC’s Response for PKC within Scotland. They continue that it could also be useful to provide a context within the UK and recommend further exploring cross-boundary links across Tayside. Further Comments: The respondent further comments, that whilst they understand the need to be proportionate, they note that some topics have been explored in more detail in Topic Paper 001. As such, they suggest providing more natural environment context, for example, protected area cover/condition, native woodland cover/condition etc. Figure 1 could also include more on nature. This topic paper seems to summarise environmental data and could be beneficial to the preparation of the SEA and can perhaps feed into the environmental baseline of the SEA given the topics that have been used. Formal Dispute: Not applicable. contained within it to form part of the environmental baseline for the SEA of our LDP3. That environmental baseline included in our SEA Scoping Report also brings together other sources of environmental data/evidence considered under several of the LDP3 Topic Papers, including those which provide more natural environment context. The SEA will also explore where relevant cross-boundary links/issues. Public Health Scotland Place Team Disagree, but does not wish for comments to be registered as a formal dispute. List of Evidence/Datasets: The respondent welcomes the focus on population, health and wellbeing under Topic Paper 001: The Plan Area, such as the inclusion of relevant data from ScotPHO and the recognition of land use planning ‘to help reduce health and wellbeing inequalities across our communities.’ To more fully embed health and wellbeing into the LDP3 Evidence Report, the respondent provides further supporting information which should be considered in terms of implications for LDP3: • The right health for all, meeting the varying needs of different population groups and considering implications across wider social determinants of health and health outcomes. Source: PKC welcomes the comments submitted by Public Health Scotland’s Place Team, particularly the list of additional sources of information/evidence provided. PKC considers the best approach to embedding the contents of these sources of information into our LDP3 is via the SEA process. These sources have been added to the analysis of relevant plans, programmes and strategies under the Population and Human Health topics of our SEA Scoping Report, to ensure their key outcomes are considered in the assessment of our developing Plan. No action required for this Evidence Report.
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Respondent Agree or Dispute Summary of Comments PKC’s Response o https://www.publichealthscotland.scot/our- areas-of-work/equity-and-justice/the-right-to- health/overview/ • Maximising health and wellbeing benefits; reducing harms to health and inequalities. Sources: o https://publichealthscotland.scot/media/14809/ evidence-behind-the-place-standard-tool-and- the-place-and-wellbeing-outcomes-briefing.pdf and o https://publichealthscotland.scot/our-areas-of- work/equity-and-justice/health- inequalities/how-large-are-health-inequalities- in-scotland/ • The evidence behind the Place and Wellbeing Outcomes and Place Standard Tool; the Place and Well Being Outcomes and (quantitative) indicators; Place Standard Tool results, (qualitative) evidence on lived experience. Sources: o https://www.improvementservice.org.uk/produc ts-and-services/planning-and-place-based- approaches/planning-for-place- programme/place-and-wellbeing-outcomes o A set of quantitative indicators that can be measured and reviewed over time to assess the contribution to the delivery of the place and wellbeing outcomes locally can be accessed at: https://www.improvementservice.org.uk/__data/ assets/excel_doc/0020/46145/Place-and- Wellbeing-Outcomes-Indicators-Early-release- updateJuly2024.xlsx. o See Place and Wellbeing Outcomes briefing: https://www.improvementservice.org.uk/product
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Respondent Agree or Dispute Summary of Comments PKC’s Response s-and-services/planning-and-place-based- approaches/planning-for-place- programme/place-and-wellbeing-outcomes o LDP guidance sets out that ‘qualitative evidence on the lived experience of those who live and work in a place is important and can be gained through meaningful engagement’. To further support a place-based approach and draw on local knowledge, it would be useful for the Evidence Report to include results of Place Standard Tool engagement and the priorities identified for action. • Climate resilient, healthy and equitable places, including understanding direct and indirect health impacts and social vulnerability. The LDP3 Spatial Strategy provides the opportunity to take account of a preventative approach to building climate resilience in a way that also benefits health and equity. A supporting briefing provides further information: https://publichealthscotland.scot/media/21005/work ing-together-to-build-climate-resilient-healthy-and- equitable-places-a-briefing-for-local-government-and- partners-english-july2023.pdf • Health in All Policies (HiAP) and Health Impact Assessment (HIA). o HiAP is an established approach to improving health and health equity through cross-sector action on the wider determinants of health: the social, environmental, economic and commercial conditions in which people live. o HIA is a key tool through which to apply HiAP and consider the potential, and sometimes unintended, effects a policy, strategy or service
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Respondent Agree or Dispute Summary of Comments PKC’s Response plan may have on the health of a population. It is particularly useful for considering effects on vulnerable or disadvantaged groups. HIA considers the socioeconomic determinants of health and the pathways through which they influence health outcomes. See: https://publichealthscotland.scot/services/health- impact-assessment-hia/what-is-health-impact- assessment/health-in-all-policies/ • For further guidance, the briefing paper ‘Place and Wellbeing: integrating land use planning and public health in Scotland’ provides practical guidance for land use planners, public health practitioners and policymakers to work together, using a whole systems approach to improve health and wellbeing and reduce health inequalities. Page 20, Figure 7 summarises relevant evidence: local health and wellbeing needs; place-based information; and access to/demand for health facilities. See: https://www.improvementservice.org.uk/__data/ass ets/pdf_file/0029/26876/place-and-wellbeing- integrating-land-use-planning-v3-apr2024.pdf. Summary of Implications for Proposed Plan (PP): The respondent disagrees with the summary of implications of the evidence provided under Topic Paper 001 for the Proposed Plan. They comment that Box 20: Summary of Importance of Evidence to LDP3 in Topic Paper 001 notes ‘access’ to key facilities and services. They continue that to support the right to health, services should also be accessible, available, appropriate, and high quality. As highlighted under the ‘List of Evidence/Datasets’ section of the consultation questionnaire, the respondent comments that additional implications for LDP3 include
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Respondent Agree or Dispute Summary of Comments PKC’s Response taking further account of and embedding – the right to health for all; maximising health and wellbeing benefits; reducing harms to health and inequalities; the evidence behind the Place and Wellbeing Outcomes and the Place Standard Tool; the Place and Wellbeing Outcomes and (quantitative) indicators; Place Standard Tool results (qualitative), evidence on lived experience; climate resilient, healthy and equitable places, including understanding direct and indirect health impacts and social vulnerability; HiAP, and HIA. Further Comments: No further comments made. Formal Dispute: The respondent does not wish for their response to be registered as a formal dispute. Ristol Planning Consultants and Land Agents Disagree, but does not wish for comments to be registered as a formal dispute. List of Evidence/Datasets: The respondent indicated that they agree with the list of evidence and datasets provided under Topic Paper 001: The Plan Area. Summary of Implications for Proposed Plan (PP): The respondent indicates that they disagree with the summary of implications for the Proposed Plan provided under Topic Paper 001. They comment that the historical information provided in Topic Paper 001 is extremely comprehensive and very helpful in understanding the social, demographic, environmental and historical characteristics of Perthshire, and how these will inform a future spatial plan. However, they continue that “innovations, particularly technically and digitally have the potential to disrupt [and] transform communities.” The respondent further comments that they present opportunities to deal with a number of challenges, including climate change, energy, transport, housing, and economic growth through new approaches, which may run counter to previous policy approaches, often as a PKC welcomes Ristol Planning Consultants and Land Agents response to Topic Paper 001: The Plan Area. As outlined under paragraphs 1.1- 1.4 of the topic paper, the information provided in the paper was intended to set out the key information about the Perth and Kinross Area as required under Section 15(5) of the Planning Act, in respect of the principal physical, cultural, economic, social, built heritage, and environmental characteristics of the area. In essence this is the baseline for the Perth and Kinross Area and provides some context within which our LDP3 should be prepared. As acknowledged by the respondent through their comments, other policy specific LDP3 Topic Papers explore available data and information relating to policy drivers and corresponding existing programmes or proposed opportunities for future growth and development.
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Respondent Agree or Dispute Summary of Comments PKC’s Response result of locational considerations, and enable positive change in line with NPF4’s spatial principles and strategy - they cite the potential for elevated buildings within floodplains, mobility hubs in a green belt or rural affordable housing in sensitive landscapes as examples of how conflicts through a sole reliance on previous data and trends could be positively addressed. The respondent then continues that the “innovation agenda”, which they acknowledge is captured through many of the topic papers through reference to specific projects, like Binn Eco Park, the Perth Innovation Highway, or Perth West, and programmes including Perth Smart Energy City and the Circular Economy Strategy, have the potential to be transformative for Perthshire. They highlight the opportunity through the LDP review to connect these spatially, and through delivery plans and bespoke programmes, support their delivery over the 10 year plan period. Further Comments: No further comments made. Formal Dispute: The respondent does not wish for their comments to be registered as a dispute. No action required for this Evidence Report. Savills (on behalf of Dupplin Estate) Dispute List of Evidence/Datasets: The respondent indicated that they disagree with the list of evidence and datasets provided under Topic Paper 001: The Plan Area due to the datasets taking averages across the region, which in their opinion masks the disparity within the region and risks failing to tackle a lack of skills innovation and employment for a younger workforce. The respondent does not provide or suggest any other sources of available data or information alongside their comments. Summary of Implications for Proposed Plan (PP): The respondent neither agrees nor disagrees with the PKC welcomes Savills submission on behalf of Dupplin Estate and responds to the points raised within it as follows: • The data reported under Topic Paper 001: The Plan Area uses the same indicators as those used in the Tay Cities Regional Economic Strategy and come from reliable national sources which allow for the comparison of how Perth and Kinross compares within the Tay Cities Region and Scotland, across employment-related statistics. The data sources which underpin
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Respondent Agree or Dispute Summary of Comments PKC’s Response summary of implications of the evidence for the Proposed Plan provided under Topic Paper 001. Further Comments: Under the further comments section of the consultation questionnaire, the respondent raised the following points: • Perth and Kinross has an active landowning sector which provides significant economic benefits, drives environmental initiatives, and has huge potential to help deliver sustainable, liveable and productive places as per NPF4. • Landowner involvement is critical to ensure a robust LDP in relation to delivery. • Promotion of integrated land management options via LDP3 should be core to the future spatial strategy. • Throughout the topic papers it is not clear that the landowning and managing sector has been specifically consulted or considered as a key delivery partner in achieving the new LDP requirements – the land managing sectors is key to tackling the twin climate and nature crises and the housing crisis. Engagement with this sector and its knowledge base is essential for a robust Evidence Report and subsequent LDP. • PKC Planning Department has been asked to form a ‘Landowners Planning Forum’ where information can be shared and partnerships forged to tackle these challenges in a unified and effective manner. Partnerships with Perth and Kinross landowners will be critical to achieving strategic scale environmental benefits that achieve LDP aims. • Land owning estates are increasingly focused on integrated land management approaches to benefit the environment and increase delivery of social value. each indicator are all reported at a local authority level, except for the National Records for Scotland (NRS) Mid-Year Population Estimates 2022, Office for National Statistics (ONS) Business Register and Employment Survey (BRES) 2022, Skills Development Scotland (SDS) Annual Participation Measure for 16-19 Year Olds in Scotland 2023, and Claimant Count (NOMIS), which are also available at the Scottish 2011 Data Zone level. Some of the data sources are available at a Scottish Parliamentary Constituency and Electoral Ward level too. As the Claimant Count figures from NOMIS are reported at a Scottish Data Zone level they reflect the differences in unemployment levels across the 186 data zones covering Perth and Kinross and show us the rankings for those data zones from highest proportion of the population who are claimants down to the lowest. An approximate number of claimants for a range of age groups, associated with each data zone is also shown. This finer grain data has been used in this Evidence Report under the ‘Economic Characteristics of the Plan Area’ section. SIMD data has been used to inform other issues for this Evidence Report, for example, identifying our most vulnerable communities to the impacts of a changing climate. However, this data source also includes deprivation rankings for Education/Skills and Employment domains across each of the
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Respondent Agree or Dispute Summary of Comments PKC’s Response Dupplin Estate is already delivering on all these fronts (examples provided of how). • The Plan Area covers the region which averages down a number of competing priorities. There appears to be insufficient recognition of the strategic role that Perth and Kinross (and specifically Perth) play in a wider Scottish context. It is not clear how key infrastructure priorities are supported through the review process. Growth around the main urban centres of Perth and Kinross (i.e. Perth, Kinross, Blairgowrie, Coupar Angus) gives an opportunity to dissipate some of the strong (and constrictive) growth in the Edinburgh-Glasgow corridor. Perth is at the heart of the Scottish trunk road network and yet the main development in the past 10 years has been the Cross Tay Link Road to divert traffic away from Perth. The LDP should focus infrastructure to attract investment into the region (focussed around the larger urban areas). The demographic of the region is 45-60 and reflects a lack of past focus on skills innovation and employment opportunities. Perth is at the centre of the power distribution network and the LDP should focus on delivering jobs in renewables and smart logistics sectors. Formal Dispute: The respondent wishes their comments to be registered as a formal dispute due to “the datasets…taking averages across the region. This masks the disparity within the region and risks failing to tackle a lack of skills innovation and employment for the younger workforce.” Scottish Data Zone levels, which allows us to look closer at how each of those zones are performing in terms of these indictors. SIMD data for the Education/Skills and Employment indicators have now been included in the ‘Economic Characteristics of the Plan Area’ section of this Evidence Report. • Similar to PKC responses to comments by Savills on other LDP Topic Papers, the Council’s Development Plan Scheme and Participation Statement highlights landowners and developers as entities which the Council will seek to engage with during the various stages in the preparation of our LDP3, and although they are not a prescribed key stakeholder, they are widely recognised as being an integral part of the development planning process, through the identification and implementation of deliverable development opportunities which can contribute to the achievement of multiple benefits and wider outcomes for places, communities and nature. Our LDP3 development process will therefore seek to continue to work with key stakeholders across the Perth and Kinross Area, including landowners and their agents, to deliver sustainable, liveable and productive places for now and the future, as per our Development Plan Scheme and Participation Statement. • LDP3 will promote integrated land management in line with NPF4 National
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Respondent Agree or Dispute Summary of Comments PKC’s Response Planning Policies, and Spatial Principles, and our Spatial Strategy will be developed in alignment. • PKC acknowledges Savills request to establish a ‘Landowners Planning Forum’ and notes that there have been previous discussions between representatives of Savills and PKC on the matter which will be explored further in due course. It is also worth noting that our Perthshire Nature Connection Partnership already works with landowners and managers in identifying and delivering landscape scale change within Highland Perthshire, and the consultation and engagement exercise for the Tay Forest National Park bid included a specific session for land managers (estates and farmers) in that area. • PKC understands that the respondent may feel that the competing priorities of the Plan Area have not been sufficiently recognised within Topic Paper 001: The Plan Area, but would respond that the purpose of this topic paper was to provide an overview of the key characteristics of the area, and the policy specific topic papers within the LDP3 Topic Papers suite looked in detail at the area’s infrastructure, housing, business and industry and retail profile and opportunities, and renewables and transportation and logistics. In terms of their comments around the focus of future growth and investment, the purpose of this Evidence Report is to review
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Respondent Agree or Dispute Summary of Comments PKC’s Response the data and information relevant to the Plan Area and provide a summary of the likely implications of that evidence to the Proposed Plan. This Evidence Report and the background topic papers which were consulted on, do not seek to identify the LDP3 Spatial Strategy at this stage, this will be developed following this Report passing the Gate Check. Savills (on behalf of Scone Estate) Dispute List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): No comments provided under these sections of the consultation questionnaire. Further Comments: Under the further comments section, the respondent states that at a general level, they consider that it should be referenced that Perth and Kinross has an active landowning sector which provides significant economic benefits, drives environmental initiatives, and has huge potential to help deliver the sustainable, liveable and productive places NPF4 intends to generate. They continue that if a plan is to be robust in relation to delivery, the landowner agreement on place creation/environmental benefit is critical. Promotion of integrated land management options via the next LDP3 should be front and centre of the future spatial strategy. 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. PKC welcomes Savills submission on behalf of Scone Estate and responds to the points raised within as follows: • Reference made within LDP3 to benefits provided by landowning sector, and agreement of landowners on place creation/environmental benefit – As per PKC’s response to similar comments made by Savills on other topic paper subject matters, we will develop our LDP3 Spatial Strategy in line with NPF4 and other legislative requirements as set out in this Evidence Report. The development of the Spatial Strategy and the narrative contained within the Plan (both discussing the overall strategy and location specific matters) will recognise the need to follow the Scottish Government’s ‘Creating Places’ and ‘Designing Streets’ policy statements, and the Scottish Government and COSLA’s ‘Place Principle’ to promote and develop a shared understanding of place, and the need or communities, public organisations, businesses and other key stakeholders, including landowners, to
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Respondent Agree or Dispute Summary of Comments PKC’s Response 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 respondent comments that 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/are as/councilareas.html is suggested as a source of information on population densities. The respondent continues that 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.” Finally, the respondent reflects on the subject of tourism, and the reliance on this sector within the Perth and Kinross Area. They highlight the data in Table 7 of Topic Paper 001 which shows tourism as the area’s biggest employer. It is their view that planning policies must be geared towards supporting tourism businesses, such as Scone Estate, to survive and expand. They continue that Box 10 of Topic Paper 001 however, only states that LDP3’s Spatial Strategy “should support through the protection of existing and identification of new business, industrial and employment land proposals to allow for the growth of our strongest sectors and facilitate the growth especially of the Tay Cities Region Key Business Sectors.” The respondent considers that the significance work together to achieve high quality successful places, and better outcomes for people, communities and nature. Nationally land use recognises the importance of working collaboratively across all users and sectors to create sustainable and successful places. Although landowners are not a legislatively prescribed key stakeholder, they are widely recognised as being an integral part of the development planning process, through the identification and implementation of deliverable development opportunities which can contribute to the achievement of multiple benefits and wider outcomes for places, communities and nature. Our LDP3 development process will seek to continue to work with key stakeholders across the Perth and Kinross Area, including landowners and their agents, to deliver sustainable, liveable and productive places for now and the future, as per our Development Plan Scheme and Participation Statement. • Promotion of integrated land management – Our LDP3 will refer to, promote, and encourage the principle of integrated and sustainable land management and the wider benefits which can be achieved across a number of policy areas in line with NPF4 and Scotland’s Third Land Use Strategy. • Population densities data and revival/ repopulation of rural settlements – This comment has been dealt with under the
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Respondent Agree or Dispute Summary of Comments PKC’s Response of the tourism sector to PKC must be understood and reflected in planning policy. Furthermore, they comment that 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. Formal Dispute: The respondent wishes for their comments to be registered as a formal dispute on the basis of population density. They consider that the Council must consider data sources regarding population density and use this to seek a more balanced spread of the population to support growth in rural settlements and housing clusters to revitalise rural areas with supportive planning policies and generous housing allocations. Furthermore, planning policies must be geared towards supporting tourism businesses, such as Scone Estate, to survive and expand. They highlight again the summary of the importance of the evidence provided in Box 10 of Topic Paper 001 and state that they consider that the significance of the tourism sector to PKC must be understood and reflected in planning policy. ‘Rural Development and Homes’ issue of this Evidence Report as it was viewed as more relevant to the considerations under that issue. • Significance of tourism sector to the Perth and Kinross Area – The Tourism subject was explored in detail under Topic Paper 029. Both Topic Papers 001 and 029 recognised the importance of tourism to the Perth and Kinross and Tay Cities Region economies. The importance of tourism and its key connections with historical and cultural assets is also highlighted under the Culture and Creativity issue of this Evidence Report, and related Topic Paper. Topic Paper 001, under the summary of relevant Tay Cities Deal documents, and the ‘Principal Economic Characteristics’ section highlight Tourism and Culture as one of the Key Business Sectors for the area, and acknowledges that the Tourism sector, along with Health and Social Care, Retail, and Food and Drink sectors have the largest share of jobs across Perth and Kinross. Our LDP3 Spatial Strategy will be developed in line with NPF4 and its suite of National Planning Policies, including Policy 30: Tourism, and the important role that tourism plays to the Perth and Kinross Area reflected within the Plan’s strategy and narrative. Scottish Water Agree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The respondent indicated that they agree with the list of evidence provided under Topic PKC welcomes Scottish Water’s note of agreement with the evidence provided under Topic Paper 001: The Plan Area and the summary
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Respondent Agree or Dispute Summary of Comments PKC’s Response Paper 001 and the summary of implications of that evidence for the Proposed Plan. Further Comments: The respondent acknowledged the contents of Topic Paper 001 and had no additional comments to make regarding it. Formal Dispute: Not applicable. of implications of that evidence for the Proposed Plan. No action required for this Evidence Report. Scottish Environment Protection Agency Dispute but could be removed if written confirmation of most recent data being used to inform the environmental baseline is provided. List of Evidence/Datasets: The respondent indicated that they agree with the list of evidence and datasets provided under Topic Paper 001: The Plan Area but highlighted that whilst the topic paper refers to data on the water environment from 2020, the 2022 data is available from the water classification hub (https://www.sepa.org.uk/data-visualisation/water- classification-hub/). They also commented that Table A5 in the topic paper should include Water Environment Hub as the pressures and actions data from the River Basin Management Plan should be used to inform the environmental baseline. Finally, they note that the finalised Strategic Flood Risk Assessment (SFRA) would be the most appropriate and comprehensive evidence source regarding flood risk. Summary of Implications for Proposed Plan (PP): The respondent indicated that they agreed with the summary of implications of the evidence for the Proposed Plan as provided under Topic Paper 001. Further Comments: No further comments made. Formal Dispute: The respondent indicated that they wish for their comments to be registered as a formal dispute. They comment that the Scottish Government’s LDP Guidance paragraph 83 states that the Evidence Report (ER) should include a proportionate summary of the baseline data and information, and that the ER is PKC welcomes SEPA’s comments on Topic Paper 001 and can confirm that the most recent River Basin Management Plan Water Classification Hub data (2022) will be used to inform the environmental baseline for the Perth and Kinross Council Area. The reported 2020 data under Topic Paper 001 was taken from an environmental baseline collated for a recent Strategic Environmental Assessment for another Council strategy, but it is recognised that that data has now been superseded. Our LDP3 SEA Scoping Report uses the 2022 data included in the Water Classification Hub and RBMP key pressures and actions available via the Water Environment Hub, and the Flood Risk and Water Management issue of this Evidence Report also incorporates both sources of evidence.
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Respondent Agree or Dispute Summary of Comments PKC’s Response expected to include spatial information, such as baseline mapping which supports an understanding of the place(s), its characteristics and needs. Furthermore, they highlight that Regulation 9 of the 2023 Development Planning Regulations states that planning authorities should have regard to any River Basin Management Plan in preparing the LDP, and that data on key pressures available from the Water Environment Hub should inform the environmental baseline of the ER along with the most recent water classification data available from Water Classification Hub. They comment that the Water Environment Hub data may highlight pressures in the water environment which the LDP could help address through identification of opportunities to improve the water environment in nature network/blue green infrastructure mapping or in proposed development. The respondent’s position could be reviewed if written confirmation is received that the most recent RBMP data from Water Classification Hub will be used to inform the environmental baseline prior to submission to the Gate Check. SSEN Transmission Neither agree nor disagree List of Evidence/Datasets and Summary of Implications for Proposed Plan (PP): The respondent indicated that they neither agree nor disagree with the list of evidence and the summary of implications of that evidence for the Proposed Plan provided under Topic Paper 001 and make no comments in support of that. Further Comments: No further comments made. Formal Dispute: Not applicable. No action required for this Evidence Report.