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Appendix 1 - Table of Changes

Perth and Kinross Council · 10 December 2025
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Table of Reporter’s Recommendations and the Council’s Related Actions 
Key:
Insufficient evidence –maers to be addressed in Evidence Report Resubmission.
A clearer commitment and mescale could usefully be provided in the Evidence Report Resubmission.
Would appear to be available at the me to include in Evidence Report Resubmission.
Opportunity to include further informaon in Evidence Report Resubmission.
Further consideraon to be given in order to inform preparaon of Proposed Plan.
Reference and Issue Important Information
Gaps
Evidence Report (ER) Indicated Timescale for Resolution and/or Reporter’s
Comments and Recommendation(s)
PKC Update or Actions Taken
Annex A - Education
Capacity
Reporter’s Comments:
This section of the evidence report does not present a clear picture of the
existing and projected education capacity in the council area. At page 8 of
Issue 20 it is stated that capacity levels will be set out, but this information
should have been included within the evidence report itself. I would have
expected this analysis to include forecasting of future capacity based on
current demographic trends and committed development. This could most
usefully have been achieved with a clear table setting out which schools
were forecast to have spare capacity, and which were at or approaching
capacity, over the projected plan period. I do not consider that the broad
high level statements that are provided on this topic are sufficient or can be
said to fully or adequately describe the current and projected capacity of
schools in the plan area.
This is an important matter related to a legislative provision. Section 15(5) of
the Act includes the capacity of education services in the district among the
matters that the authority is expected to set out their views in the evidence
report. The fact that the authority commits to carrying out this work going
forward indicates that this is not an excessively onerous or technically
difficult task. No reasons are given as to why this analysis has not already
been done and presented in the report.
This Evidence Report
Resubmission has been amended
accordingly at Chapters 5 and 6,
Issue 020: Education Facilities,
and Appendix D Issue 020:
Education Facilities. 
Appendix D has been updated
with detailed information on the
current position of the School
Estate including tables showing
current and future school rolls
over the projected plan period. 
RAG maps have also been added
to show the information spatially.
An overview of the capacity
situation including the impact of
potential pupils from house
building within each LMG is
provided along with information
on the planned or programmed
improvements to the school

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Particularly in the primary sector, the matter of the capacity and sufficiency
of existing schools is important given the council’s apparent desire to
continue to seek developer contributions to fund new provision. The council
can no longer rely on statutory supplementary guidance to set out the
principles of its policy on developer contributions, and so it is particularly
important that the evidential justification for any such contribution policies
is set out in the preparation of the proposed plan.
Further explanation could also be usefully provided as to how education
colleagues have been involved in the preparation of this part of the evidence
report.
I have carefully considered whether this matter merited the return of the
report.  I am conscious that the volume of new land release in the
forthcoming plan may be modest, and that it may be that education matters
relating to existing strategic releases have been largely resolved.  The gap
may be of less significance in the secondary sector where no developer
contributions are anticipated.  However, I cannot overlook the specific
legislative requirement relating to this matter.  It is also important for me to
avoid sending a signal to other authorities that this detail is a matter
appropriately addressed at a later stage.  That is not the case. 
Conclusion and Recommendations:
For the reasons stated, I find the evidence report to be insufficient with
regard to education capacity.  I recommend that the authority addresses this
matter by: 
 Clearly setting out (perhaps in tabular form) existing and projected
school rolls (taking account of demographic change and committed
development) over the plan period;
 Describing any planned or programmed improvements or changes to
the school estate that could affect capacity;
 Identifying the parts of the plan area likely to be constrained due to
school capacity issues, or where further intervention would be required
to enable growth;
estate. The evidence sources on
which the updated evidence is
based have been identified and
provided.  Updates have been
made to the implications for the
proposed plan. 
Chapters 5 and 6 which
incorporate summary
information from Appendix D
have been updated accordingly.

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 It would be helpful if the report could also discuss the interventions
necessary to resolve these constraints (e.g. catchment reviews,
extensions or new schools), though I do not consider this to be
essential;
 Identifying and providing the evidence sources on which this evidence
is based (hyperlinks will suffice); and
 Summarising the implications of this evidence for the proposed plan.
Annex B6 – Issue 002.
Biodiversity and
Natural Places, and
Annex C8 – Issue 002
A review of the Tayside
Biodiversity Partnership
LBAP
Text included in Evidence Report:
Will coincide with the development of the Proposed Plan.
Reporter’s Comments:
I would have expected to have seen some discussion of the council’s
Biodiversity Duty Report.  The council should consider the implications of
this document in the revised report, or as it moves forward to prepare the
proposed plan.
Recommendation:
A clearer commitment and timescale could usefully be provided in the
revised report.
The Biodiversity Duty covers the
three-year period from January
2021 to December 2023. The next
report will cover the period from
January 2024 to December 2026
and will be published in
December 2026. Enhancing
biodiversity - Perth & Kinross
Council.  
Evidence Report Resubmission
has been amended to add a
summary of the Council’s
Biodiversity Duty Report in
Appendix A: Sustainable Places,
Issue 002: Biodiversity and
Natural Places.  The Council will
consider the implications of this
Report in the preparation of our
Proposed Plan.
Review of the Tayside Local
Biodiversity Action Plan 2016-
2026 is underway as of October
2025 and will coincide with the
preparation of the Proposed Plan. 
We will work closely with the

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Tayside Biodiversity Partnership
to ensure the Proposed Plan and
Nature Networks are
complementary to the ambitions
of the forthcoming LBAP.
Evidence Report Resubmission
has been amended accordingly at
Chapter 5: Gaps, Uncertainties
and any Key Issues Raised in
Evidence, and within Appendix A,
Sustainable Places, Issue 002:
Biodiversity and Natural Places
Local Biodiversity Sites
Programme
Text included in Evidence Report:
Will not be complete until mid-2025.
Reporter’s Comments:
Would appear to be available at the time to include in revised report.
Assessment of Local Biodiversity
Sites will be complete by early
2026. Adoption anticipated Q3
2026.
Evidence Report Resubmission
has been amended accordingly at
Chapter 5: Gaps, Uncertainties
and any Key Issues Raised in
Evidence, and within Appendix A,
Sustainable Places, Issue 002:
Biodiversity and Natural Places
Nature Networks Text included in Evidence Report:
Further engagement is ongoing and is likely to run through 2025 for
landscape scale Nature Networks, which will be developed alongside green
infrastructure and green network identification.
Reporter’s Comments:
Would appear to be available at the time to include in revised report.
Identification of draft Nature
Networks will be complete by
early 2026 with further
engagement through 2026
alongside plan preparation.
Evidence Report Resubmission
has been amended accordingly at
Chapter 5: Gaps, Uncertainties
and any Key Issues Raised in

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Evidence, and within Appendix A,
Sustainable Places, Issue 002:
Biodiversity and Natural Places
Annex B6 – Issue 004.
Forestry, Woodland
and Trees
Forestry and Woodland
Strategy (FWS)
Text included in Evidence Report:
Will require a review.
Reporter’s Comments:
A clearer commitment and timescale could usefully be provided in the
revised report.
A draft FWS is under preparation. 
The draft document is
programmed for consideration at
a meeting of the Economy &
Infrastructure Committee in April
2026 Consultation and
engagement to take place during
Spring 2026, with publication of
FWS expected late Summer 2026.
Evidence Report Resubmission
has been amended accordingly at
Chapter 5: Gaps, Uncertainties
and any Key Issues Raised in
Evidence; under the summary
provided in Chapter 5, Issue 004:
Forestry, Woodlands and Trees,
and in Appendix A: Sustainable
Places, Issue 004: Forestry,
Woodland and Trees
Annex B6 – Issue 005.
Historic Assets and
Places
Conservation Area
Appraisals (CAAs)
Text included in Evidence Report:
A rolling review programme in place for reviewing our list of CAAs which is
expected to be completed during 2025-26.
Reporter’s Comments:
Would appear to be available in time to include in revised report.
A rolling programme is in place to
review our Conservation Areas
and the list of Conservation Area
Appraisals.  Our approach to this
will be to group areas by location;
to prioritise areas where the last
appraisal or review was some
considerable time ago; and to
provide an appraisal where none
is currently in place. The first
three reviews (Birnam, Dunkeld,

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and Spittalfield) are to be
considered by Economy and
Infrastructure Committee on 28
January 2026. The next
Conservation Area Appraisal to
being reviewed will be Perth
Central and to be considered by
Economy and Infrastructure
Committee at the end of 2026. 
Annex B6 – Issue 006.
Green Belt and Annex
C9-11
Green Belt Review Text included in Evidence Report:
The timing of the review will be important as it will need to be informed by
other pieces of work, such as the locality profile work, work on 20 minute
neighbourhoods, and the spatial strategy itself.  For this reason, it was not
considered appropriate to carry out the green belt review at Evidence
Report stage.  It will, however, need to be undertaken prior to the site
selection process.
Reporter’s Comments:
As acknowledged in the evidence report, NPF4 expects green belts to be
reviewed as part of the preparation of LDPs. The Local Development
Planning Guidance states that evidence is required to inform detailed green
belt boundaries.
The evidence report commits the council to carry out such a review ahead of
the proposed plan.
I accept that there may be valid reasons to delay the finalisation of any
review until after the evidence report stage so that it can be considered in
parallel with the development of the spatial strategy, and when the scale of
the need for additional land release is better understood. However, it is
disappointing, and a gap in the evidence, not to see some of the building
blocks that will feed into the review more fully presented in the evidence
report. This could have included more work around new development and
development pressures since the last review, the presence of major
businesses and uses, landscape change since the last review, and the
As recommended, some of the
initial components of the Green
Belt review have now been
undertaken including:
 A review of planning
application data to identify
new development and areas
of pressure or change
 The identification of some of
the major land uses and
business within the Green
Belt
 An initial review of the
contribution of different
parts of the Green Belt to
meeting the NPF outcomes.
Evidence Report Resubmission
has been amended accordingly at
Chapter 5, Issue 006: Green Belts
and, Appendix A: Sustainable
Places, Issue 006: Green Belts

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ongoing contribution of different parts of the green belt to the outcomes set
out in NPF4. It is stated that it would have been inappropriate to carry out
the review prior to other pieces of work relating to locality profiling and 20-
minute neighbourhoods being in place, but ideally these exercises would
also have been completed in time to feed into the evidence report. I advise
that work on the green belt review is now advanced timeously with the
involvement of relevant stakeholders.
I note that the key for Figure 2 of Issue 6 appears to mix up the notations for
the proposed and adopted green belt. 
Recommendation:
While some valid reasons have been given for delaying the full review until
closer to the publication of the proposed plan, there may be opportunities
to include various contributory components in any revised report.  These
components could include new development and development pressures
since the last review, the presence of major businesses and uses in the green
belt, landscape change since the last review, and the ongoing contribution of
different parts of the green belt to the outcomes set out in NPF4.
Annex B6 – Issue 007.
Brownfield, Vacant
and Derelict Land,
and Empty Buildings
Register of potential
brownfield regeneration
sites/ urban capacity study
Text included in Evidence Report:
A pilot exercise has so far been undertaken. The process has been reviewed
and refined and will be rolled out across the Perth and
Kinross area.
Reporter’s Comments:
A potentially important piece of work, the outputs of which could have
significant implications for regeneration and land supply. A clearer
commitment and timescale could usefully be provided in the revised report.
Agreed and the Evidence Report
Resubmission has been amended
accordingly at Chapter 5, Issue
007: Brownfield, Vacant and
Derelict Land, and Empty
Buildings, and Appendix A:
Sustainable Places, Issue 007:
Brownfield, Vacant and Derelict
Land, and Empty Buildings
Annex B6 – Issue 008.
Coastal Development
and Aquaculture
Coastal Change Adaptation
Plan
Text included in Evidence Report:
The Council has received funding, and if it is available timeously it will inform
the Proposed Plan.
Reporter’s Comments:
The original plan was to use the
Phase 1 funds to inform a Coastal
Change Adaptation Plan, but
given the short length of PKC
coastline, and limited receptors,
an alternative approach was

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A clearer commitment and timescale could usefully be provided in the
revised report.
taken.  Also, it is noted that there
are no areas shown at risk in the
Dynamic Coast webmaps Future
Erosion 2100 High Emissions
scenario. Funds received were
used for alternative coastal wall
repair project as agreed with
Scottish Government. To date
PKC has not received funding
from later phases but if a Coastal
Change Adaptation Plan is
prepared it would inform LDP3
Proposed Plan. 
The Evidence Report
Resubmission has been amended
accordingly under Chapter 5,
Issue 008: Coastal Development
and Aquaculture, and Appendix
A, Sustainable Places, Issue 008.
Annex B6 – Issue 009.
Energy, Heating and
Cooling, and Annex
C12
Formal Designation of Heat
Network Zone (HNZ)
Text included in Evidence Report:
Still to take place. 
Reporter’s Comments:
The council is yet to identify any HNZs as required by the Heat Networks
(Scotland) Act 2021.  I note that designating such a zone is a key action of
the LHEES and a list is provided of potential zones.  However, it would have
been preferable for the evidence report to have also included a clear
commitment and a timescale for this work.
No timescale given.  A clearer commitment and timescale could usefully be
provided in the revised report.
Key considerations are still to be
considered as part of the drafting
of the Heat in Buildings Bill,
including a potential power for
local authorities to require any
building owner to end their use of
polluting heating once they have
the opportunity to connect to a
heat network.  Scottish
Government is currently unable
to provide clarity about the role
of heat network zones, required
connections and planned next
steps in the designation

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process. Given these
uncertainties a clear commitment
and timescale s not possible at
this point. 
Perth HNZ has progressed the
furthest, but further work is
required to refine and develop
the Strategic Outline
Case/Outline Business Case and
financial model. There is also
parallel work being progressed to
bundle the Perth Strategic Heat
Network alongside other low
carbon energy projects to
procure a Strategic Energy
Partner (SEP).  A SEP will likely
carry out their own technical and
commercial feasibility work. Both
workstreams may impact the
proposed Perth HNZ boundary
and the latter may also help
define other HNZs.
To allow HNZ boundaries to be
defined at the appropriate stage,
and be supported by the LDP, it is
envisaged that LDP3 will have a
heat network policy which will
signpost to a separate designated
heat network zones
document/web map.  This
approach also aligns with Fife
Council and will allow PKC to

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identify and update HNZs as
required. 
This Evidence Report
Resubmission has been amended
accordingly under Chapter 5,
Gaps, Uncertainties and any Key
Issues Arising in Evidence, Issue
009: Energy, Heating and Cooling,
and within Appendix A,
Sustainable Places, Issue 009. 
Renewable Energy
Guidance
Text included in Evidence Report:
Programmed to be updated in 2025.
Reporter’s Comments:
Would appear to be available in time to include in revised report.
A draft of the Council’s
Renewable and Low Carbon
Energy Guidance was published
for a period of consultation from
5 September until 17 October
2025.  The comments received to
the draft document are currently
being reviewed and will be used
to inform the drafting of the final
version of the guidance which will
be taken to committee for
approval prior to publication
during Spring 2026. 
This Evidence Report
Resubmission has been amended
accordingly under Chapter 5,
Issue 009: Energy, Heating and
Cooling, and Appendix A,
Sustainable Places, Issue 009. 
Annex B6 – Issue 010.
Zero Waste, and
Annex C13
Waste Management Plan Text included in Evidence Report:
Covers the period 2010-2025 but is likely to be updated.
PKC has begun the process of
developing a Circular Waste Plan,
which will incorporate a Waste

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Reporter’s Comments:
I note the statement at pg6 of Issue 10 that ‘recent information on waste
sites and capacities, together with recent data on how household waste is
handled show that sufficient capacity exists’.  This information and data
does not seem to have been presented in the evidence report.  It is
therefore hard to judge the accuracy of this statement.  Possibly the new
facility at Glenfarg will provide all the necessary capacity, but this is not
explicitly stated.  I advise that these matters are clarified.aNo timescale
given.  If replacement plan still not available to describe in the revised
report, a clear commitment and timescale could usefully be provided.
Management Plan.  It is in the
early stages of development, with
an expected timeframe for
delivery of an approved plan in
2029. 
In terms of the recent
information on waste sites and
capacities, this information was
provided in the original Evidence
Report submission, in both the
’Table of household waste data
(percent) 2019-2023’ and the
‘Table of all waste – sites and
capacity – Perth and Kinross –
2019-2023’ on page 4 of Core
Document CD067 Appendix A,
Sustainable Places, Issue 010:
Zero Waste.  The text on page 6
of Issue 010 in Appendix A has
been updated to clarify this is
what the paragraph is referring to
whenever it notes sufficient
capacity exists. 
Annex B6 – Issue 013.
Blue and Green
Infrastructure (BGI),
and Annex C14
Open Space Audit Text included in Evidence Report:
Not expected until Summer 2025.
Reporter’s Comments:
Would appear to be available in time to include in revised report. 
The Open Space Audit is
progressing, with all LDP2
designated open spaces having
been audited. The engagement
has flagged over 100 smaller
greenspaces valued by
communities that still require site
visits.  While an initial desk-based
assessment of environmental
quality has been carried out, the

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remaining site visits will depend
on resource availability.
Tiered settlements are projected
to be complete by the end of
2026, with the remaining smaller
settlements to be completed by
the end of Q1 in 2026..
This Evidence Report
Resubmission has been amended
accordingly in Chapter 5 under
the Gaps, Uncertainties and any
Key Issues Raised in Evidence
section, and Issues 013: Blue and
Green Infrastructure and 014:
Play, Recreation and Sport. 
Updates have also been made to
Appendix B, Liveable Places,
Issues 013: Blue and Green
Infrastructure and 014: Play,
Recreation and Sport. 
Open Space Strategy Text included in Evidence Report:
To follow at the end of 2025.
Reporter’s Comments:
Would appear to be available in time to include in revised report.
The Open Space Strategy is
programmed to go to Committee
in August 2026.
A policy scoping exercise was
completed in Q3 2025, and a
draft policy framework will be
ready for internal review by the
end of the year.
Open Space Audits are being
completed alongside the Locality
Profile exercise, with tiered
settlements being prioritised.

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The audit has flagged locations
where interventions are required.
We have determined that the
settlement strategies to be
included in the OSS will be more
effective to develop alongside
LDP3. This enables us to consider
where growth will be directed
and where we can leverage on-
site or off-site contributions to
deliver requirements identified in
the audit. This Evidence Report
Resubmission has been amended
accordingly in Chapter 5 under
the Gaps, Uncertainties and any
Key Issues Raised in Evidence
section, and Issues 013: Blue and
Green Infrastructure and 014:
Play, Recreation and Sport. 
Updates have also been made to
Appendix B, Liveable Places,
Issues 013: Blue and Green
Infrastructure and 014: Play,
Recreation and Sport.
BG Infrastructure – General Reporter’s Comments:
While issue 13 highlights the various items of available evidence on this
topic, little strong sense emerges from the evidence report itself of the
nature and qualities of the BGN in the area, or of the threats and
opportunities affecting it that could potentially be addressed in the
forthcoming plan.  The authority should consider these matters further.
We have produced an internal
blue-green network (BGN) map
that is being used to inform
locality profiling work. The
profiles include narrative on the
BGN qualities, threats and
opportunities at a local level. This
will inform the development of
the Proposed Plan at these

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locations. These in depth analysis
will help to create a PKC-wide
summary in the forthcoming OSS.
Annex C15 – Issue
014. Play, Recreation
and Sport
Open Space Audit and
Strategy Reporter’s Comments:
The open space audit and open space strategy will be key evidence sources
for the forthcoming plan that may have a cross-cutting impact across a
range of policy areas. While it is welcome that these exercises are underway
and due to report soon, it is therefore disappointing that they were not
ready in time to be presented in the evidence report where their
implications could be considered in the round. It is to be hoped that these
exercises are now either complete or nearing completion in order to allow
their implications to be assessed in the revised evidence report and in the
preparation of the proposed plan.
The Open Space Audit is
progressing, with all LDP2
designated open spaces having
been audited. The engagement
has flagged over 100 smaller
greenspaces valued by
communities that still require site
visits. While an initial desk-based
assessment of environmental
quality has been carried out, the
remaining site visits will depend
on resource availability.
Tiered settlements are projected
to be complete by the end of
2026, with the remaining smaller
settlements to be completed by
the end of Q1 in 2026.
The Open Space Strategy is now
expected to go to committee in
August 2026.
A policy scoping exercise was
completed in Q3 2025 and a draft
policy framework will be ready
for internal review by the end of
the year.
Open Space Audits are being
completed alongside the Locality
Profile exercise, with tiered
settlements being prioritised.

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The audit has flagged locations
where interventions are required.
We have determined that the
settlement strategies to be
included in the OSS will be more
effective to develop alongside
LDP3. This enables us to consider
where growth will be directed
and where we can leverage on-
site or off-site contributions to
deliver requirements identified in
the audit. 
Furthermore, this enables us to
address in the OSS the
implications for PKC’s Community
Greenspace service regarding
adoption and maintenance
requirements arising from
LDP3.This Evidence Report
Resubmission has been amended
accordingly in Chapter 5 under
the Gaps, Uncertainties and any
Key Issues Raised in Evidence
section, and Issues 013: Blue and
Green Infrastructure and 014:
Play, Recreation and Sport. 
Updates have also been made to
Appendix B, Liveable Places,
Issues 013: Blue and Green
Infrastructure and 014: Play,
Recreation and Sport.

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Annex B6 – Issue 015.
Flood Risk and Water
Management
Surface Water
Management Plans
(SWMP)
Text included in Evidence Report:
A surface water management plan is currently being prepared for several
communities. The initial phase of the Perth Surface Water Management Plan
is estimated to complete in Spring 2025.
Reporter’s Comments:
Would appear to be available in time to include in revised report.
The Perth SWMP is subject to
public consultation and will likely
be considered at the Council’s
Climate Change and Sustainability
Committee 27th May 2026. 
Unfortunately, the work is
unlikely to recommend any
feasible schemes. However, two
sites at Whitefriars and Dewars
have provisionally been
identified, and LDP3 will consider
the opportunity to help deliver
site improvements. Likely
mechanisms would be through
site specific developer
requirements associated to
development allocation/s and
through Green Blue Network
mapping and guidance.
This Evidence Report
Resubmission has been updated
to take account of the above
information under  Appendix B,
Liveable Places, Issue 015: Flood
Risk and Water Management
(Including Drainage and Water
Supply Systems). 
SEPA Future Flood Maps Text included in Evidence Report:
Will be updated to reflect the UK 2018 Climate Change Projections.
Reporter’s Comments:
If now available, should be referred in the revised report.
This is not available for all local
authorities in Scotland at the
moment, with exception of
coastal maps for Outer Hebrides
and a delivery timeline for its
preparation is unavailable.  For

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further information it is noted
that SEPA have produced an
Explanatory note on the
difference between our planning
guidance and the Future Flood
Maps. However we have since
our original Evidence Report
submission published our online
SFRA (Perth and Kinross Strategic
Flood Risk Assessment Map) and
are committed to using the most
up to date flood risk mapping at
time of assessment of potential
allocations for the Proposed Plan.
The most recent SEPA Future
Flood Maps v3.0 2025 includes
surface water and small
watercourses flood maps which
takes account of UK2018 Climate
Change projections, but the River
and the Coastal maps are
generally still based on UK2009
Climate Change data.  
This Evidence Report
Resubmission has been updated
to take account of the above
information under Chapter 5 and
Appendix B, Liveable Places, Issue
015: Flood Risk and Water
Management (Including Drainage
and Water Supply Systems).
An updated needs
assessment on the
Text included in Evidence Report:
Will need to be carried out.
The Council has appointed a
consultant, to undertake the

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Annex B6 – Issue 017.
Homes, and Annex
C16-19
accommodation needs of
Gypsy/Travellers and
Travelling Show People
Reporter’s Comments:
A clearer commitment and timescale could usefully be provided in the
revised report.
assessment.  Delivery of the
assessment is expected March
2026.
Evidence Report Resubmission
has been amended accordingly at
Chapter 5, Issue 017: Homes and
Appendix C: Homes, Issue 017:
Homes
Indicative Local Housing
Land Requirement (IHLR)
Reporter’s Comments and Recommendations:
I am content that a sound and evidenced explanation has been given for the
selection of the indicative local housing land requirement (ILHLR)…
As regards the increased allowance proposed to be made for custom/self-
build capacity, it does appear that the council has arrived at a more
sophisticated quantification of this segment of demand.  Going forward, it
may be advisable for the council to give further thought, and provide further
clarification, as to whether the increased allowance for households
achieving their needs through custom/ self-build may feed through into
marginally
lower demand in other segments of supply. 
I note that a proportion of the affordable housing supply is anticipated to
comprise buybacks. I agree it may be reasonable to include at least some of
these as additions to the affordable stock, but the council could also give
some thought and consideration to the extent to which this measure would
produce a loss of supply in the market sector. Buybacks would not appear to
produce any increase in the overall housing supply, and this should be
acknowledged when considering the required land supply for the 
roposed plan.
I also note that the Report identifies some gaps in evidence in relation to
housing and commits the council to addressing these ahead of the proposed
plan. These include information around brownfield/ urban capacity, and a
Comments in relation to custom /
self-build and buybacks will be
taken into account in the
considering the required land
supply for the proposed plan as
suggested.
Evidence gaps in relation to
brownfield / urban capacity, and
gypsy / travellers and travelling
showpeople are addressed under
the relevant issue headings.

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more up-to-date understanding of housing need in the gypsy/ traveller/
travelling showpeople communities. I advise this work is expedited either to
include in the revised evidence report or to otherwise ensure that it can
properly inform the preparation of the plan.
Annex C20 – Issue
021. Health Care
Facilities
Developer Contributions
and Health Care
Reporter’s Comments and Recommendation:
The Primary Care Premises Strategy 2023-2028 (CD:D21-14) appears to be
useful but to assume that new housebuilding will translate directly into
increased population. While housebuilding may certainly affect population
distribution this assumption could benefit from further scrutiny.  There is
also some apparent uncertainty as to whether existing GP surgeries are at or
nearing capacity (pg 17 of Issue 21 refers to ‘RAG’ capacity data not being
available and that all practices are routinely accepting new patients).  The
council will need to carefully consider if sufficient information is currently
available should the emerging LDP seek to justify the extension of developer
contributions to healthcare.
The Council notes the Reporter’s
comments regarding making an
assumed correlation between
new housebuilding and an
increase in population and will
give further consideration in the
development of the Proposed
Plan.
The Perth and Kinross Health and
Social Care Partnership’s GP
surgeries RAG capacity data is a
work in progress (as of 1
December 2025) and still contains
practice sensitive data so it can’t
be included as evidence at this
point in time. Our most up-to-
date evidence in this respect
remains the Primary Care
Premises Strategy (Core Doc Ref:
D021_CD015). We remain in
dialogue with colleagues in the
Health and Social Care
Partnership with a view to
improving our knowledge of
capacities at GP surgeries and it is
expected that data will become
available in due course in a form
that can be published. We will
use this data to carefully consider

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whether there is sufficient
evidence and justification to
support an extension of
developer contributions for
primary health care.
We will continue to meet
regularly with colleagues within
NHS Tayside throughout the
development of the Proposed
Plan to ensure our knowledge
and understanding of status of
health care facilities and services
within the area remains up to
date. 
Annex B6 – Issue 022.
Transportation
Public transport route and
passenger data
Text included in Evidence Report:
Being collated by the Public Transport Team at the time of writing [the
evidence report].
Reporter’s Comments:
If now available, could usefully be provided in the revised report.
The Public Transport Team is still
developing a platform for the
collection of passenger data for
subsidised bus services. Outputs
are not yet available, so the
identified gap remains.
We are not expecting to have
access to passenger data for non-
subsidised services.
Annex B6 – Issue 025.
Business and Industry
Economic Action Plan Text included in Evidence Report:
Will be available end of 2024.
Reporter’s Comments:
This would appear to be a significant potential input into the spatial strategy
of the forthcoming plan.  Would appear to be available in time to include in
revised report. 
Perth and Kinross Economic
Strategy and Action Plan (2025-
2030) has been approved, and
replaces previous 2021 approved
Action plan  Perth and Kinross
Economic Wellbeing Plan 2020-
2028 in the revised Evidence
Report.

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This Evidence Report
Resubmission has been updated
to take account of the above
information under Chapter 5, and
Issue 025, and Appendix E,
Productive Places, Issue 025:
Business and Industry.
Annex C21-22 – Issue
026. Retail, City, Town
and Commercial
Centres AND 29.
Culture and Creativity
Reporter’s Comments and Recommendation:
The evidence report does a reasonable job of summarising the various
reports and strategies pertinent to these subjects but is less successful in
drawing on these to provide a straightforward narrative describing the retail
and cultural characteristics of the area.  There is no real overview of the
retail pattern across the council area and the role of different centres
beyond Figure 1 illustrating tiers of settlement.  I acknowledge that much of
this information is contained in the TC Retail Study, but this could have
usefully been set out in the report itself.  There is little information on the
existence and role of commercial centres beyond the city and town centres.
The LDP Guidance suggests authorities should use TC audits to inform TC
strategies for each centre.  The intention is clearly that the spatial aspects of
these may in turn inform LDPs.  The report does not use this terminology,
and while aspects of the TC Retail Study and the Locality Profiling work may
cover this ground, the council should consider the preparation of such
audits/strategies or otherwise satisfy itself that equivalent evidence is in
place before proceeding to prepare to the proposed plan.
Note that the Evidence Report
did rely too heavily on the Retail
Study providing additional
information on role and health of
our retail centres. This
information along with other
evidence, will be brought forward
in our Locality Profiles to inform
the Proposed Plan. The Locality
profiles are estimated for
completion by end of 2025 and
will provide a more
comprehensive consideration of
all our centres (including
neighbourhood and commercial
centres. In the meantime, the
Evidence Report has been
updated to provide more
narrative on Perth city and the
town centres.  This Evidence
Report Resubmission has been
updated to take account of the
above information within Chapter
5 and Appendix E, Productive
Places, Issue 026: Retail, City,
Town and Commercial Centre.

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Annex C23 – Issue
027. Rural
Development
Potential for resettlement
of previously inhabited
areas
Reporter’s Comments and Recommendation:
The evidence report may be being overly pessimistic about the potential for
resettlement of previously inhabited areas, especially given that significant
historic population declines are noted in some areas.  The Rural Homes
section of NPF4 states that suitable areas should be identified in the spatial
strategy.  The mixed success of the previous ‘development zone’ approach is
noted, but there may be other approaches.  The fact that some previously
settled areas are remote may not rule out the application of this concept.
Note the recommendation that a
less pessimistic approach is taken
to the potential for resettlement
of previous inhabited areas.
Evidence Report Resubmission
has been amended accordingly at
Chapter 5, Issue 027: Rural
Development and Appendix E:
Productive Places, Issue 027:
Rural Development
Annex B6 – Issue 028.
Tourism
Tay Cities Region Tourism
Strategy 2019-2024 and
Perthshire Tourism Action
Plan 2021-2025
Text included in Evidence Report:
A new economic plan for Perth and Kinross is currently being developed.
Reporter’s Comments:
These reports appear to have now expired.  Some clearer explanation as to
whether they are to be replaced individually, or whether the new economic
plan will perform this role, and in what timescale, should be provided.
The Tay Cities Region Tourism
Strategy 2019-2024, the Perth
and Kinross Economic Wellbeing
Plan 2020-2028, and the
Perthshire Tourism Action Plan
2021-2025 have all been replaced
by more up-to-date documents.
Evidence Report Resubmission
has been amended accordingly at
Chapter 5, Issue 028: Tourism and
Appendix E: Productive Places,
Issue 028: Tourism
Annex C24 – Issue
030. Minerals
Spatial distribution of
workable mineral
resources, and 10-year
landbank of construction
aggregates 
Reporter’s Comments and Recommendation:
Information on this topic was rather sparse.  In particular a stronger
narrative and mapping of the spatial distribution of workable mineral
resources would have been helpful.  The report acknowledges some ongoing
uncertainty regarding the existence of a 10-year landbank of construction
aggregates and commits to closing this evidence gap through engagement
with the minerals industry.  It would have been preferable for this to have
taken place ahead of the evidence report so that the policy implications of
this matter could have been straightforwardly set out.
Due to resources engagement
with the minerals industry to
ascertain the status of a 10-year
landbank of construction
aggregates has not taken place to
date.  It is our intention to issue a
survey to operators at the end of
2025 to allow us to analyse the
scale and distribution of workable
resources, the outputs of which

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will be used to inform the
Proposed Plan.   
A map showing the current
spatial distribution of mineral
operations across the Perth and
Kinross Area has been provided
under Appendix E, Issue 030:
Minerals.
Annex B6 - General Locality Profile Exercise Reporter’s Comments and Recommendation:
Would seem to be an important part of the evidence base for the
forthcoming plan, with the potential to inform thinking on issues including
20-minute neighbourhoods, placemaking and local infrastructure capacity. 
If outputs still not available to describe in the revised report, a clear
commitment and timescale could usefully be provided.
The Locality Profile exercise for
the LDP3 is currently underway
and outputs are expected to be
available late December 2025,
early January 2026.

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