Appendix 1 - Table of Changes
Perth and Kinross Council · 10 December 2025
Back to Perth and Kinross Council — 10 December 2025 and its agenda
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1 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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2 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 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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3 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 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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4 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 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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5 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 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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6 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 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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7 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 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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8 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 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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9 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 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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10 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 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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11 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 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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12 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 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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13 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 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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14 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 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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15 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 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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16 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 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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17 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 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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18 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 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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19 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 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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20 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 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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21 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 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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22 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 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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23 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 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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