Appendix 2 - Reporter's Assessment
Perth and Kinross Council · 10 December 2025
Back to Perth and Kinross Council — 10 December 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
GATE-340-1 1 Planning and Environmental Appeals Division Hadrian House, Callendar Business Park, Falkirk, FK1 1XR E: dpea@gov.scot T: 0300 244 6668 Town and Country Planning (Scotland) Act 1997 Gate Check: Section 16B(10) Assessment Report Decision My assessment is that the evidence report submitted by Perth and Kinross Council contains insufficient information to enable the planning authority to prepare its local development plan. Consequently, the evidence report is returned to the council. This assessment report details the reasons for this decision and sets out my recommendations for improvement. Preliminary matters The Perth and Kinross Evidence Report was submitted to the Scottish Ministers on 27 March 2025. I was appointed to carry out the required Gate Check on 9 April 2025. I have carried out my assessment in the context of the relevant legislative provisions of the Town and Country Planning (Scotland) Act 1997 (‘the Act’). In doing so I have taken account of National Planning Framework 4 (NPF4) and its associated guidance (Guidance on Local Development Planning in Scotland 2023). My assessment relies on the evidence report including its linked documentation. I issued one request for further information to the council, relating to details of the engagement responses received. The council’s response was received on 10 June 2025 and assisted in clarifying the nature and extent of these responses. A copy of this report has been sent to the council and to the Scottish Ministers. Reasons for return under Section 16B (10) of the Act 1. The evidence report collates an impressive amount of information, and appears to be a largely comprehensive overview of the evidence available to the council at this time. However, I find that evidence on some fundamental matters is missing. In particular, I find that the planning authority’s submission does not provide: Decision by Stephen Hall, a Reporter appointed by the Scottish Ministers Evidence Report Reference: GATE-340-1 Perth and Kinross Local Development Plan Evidence Report Gate Check Date of submission to Gate Check: 27 March 2025 Procedure: Further Written Submissions Date of Notice: 08 July 2025
Page 2
GATE-340-1 2 the authority’s view on the capacity of education services in the district, as required by sections 16B(3)(a) and 15(5) of the Act; or sufficient information to enable the planning authority to prepare a local development plan, in particular in respect of the large number of identified gaps relating to emerging reports, strategies and analysis that remained outstanding at the time the evidence report was submitted. 2. In these circumstance, section 16B(10) of the Act requires me to prepare an assessment report setting out my reasons for not being satisfied that the evidence report contains sufficient information to enable the planning authority to prepare a local development plan, and recommendations for improving the evidence report. 3. The assessment schedules included as Annexes A and B to this report set out in detail my specific reasons for return and provide a fuller explanation of the points summarised below. Annex A considers the matter of education capacity, and explains why I consider that the evidence report contains insufficient evidence relating to the capacity of schools in the area. Annex B considers the volume of emerging reports, strategies, audits and studies that remained outstanding at the time the evidence report was written. It explains my conclusion that the volume of this missing information is so extensive that sufficient information could not be said to exist at this time to enable the authority to prepare a local development plan. 4. Some of the individual points raised may not have pointed to an overall insufficiency in themselves. However, the fundamental nature of some of the issues, particularly in relation to education, lead me to conclude that the evidence report is insufficient. The evidence report is intended to be a single and transparent guide to the evidence on which plan preparation is based and the Act does not enable me to make changes without return to the planning authority. 5. Return of the report will enable the planning authority to capture the relevant matters, engaging with others as appropriate. Consequently, I return the evidence report to the council for revision prior to re-submission. 6. The assessment schedule included as Annex C to this report relates to a range of other matters that would not individually have led me to conclude that the report was insufficient, but where I consider that the authority could reflect on potential improvements to the report or further work in advance of the preparation of the proposed plan. Recommendations for improving the evidence report (Section 16B(10) of the Act) 7. The following paragraphs set out recommendations for improving the Evidence Report. Education Capacity 8. Based on my assessment in Annex A, I recommend that the authority addresses the matter of education capacity 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;
Page 3
GATE-340-1 3 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; 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), but 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. Emerging Reports and Strategies 9. Based on my assessment in Annex B, I recommend that the authority addresses the matter of the volume of emerging reports and strategies that remain outstanding by: Taking advantage of the return of the report to update the text in respect of the range of reports, strategies and other analytical work that has completed since the writing of the original document; Considering the timing of any resubmission with respect to any reports, strategies and other analytical work that is expected to be finalised in the near future; and Where important documents will not be finalised ahead of resubmission, ensuring that the report clearly states the level of commitment to completing this work, the timescale which is anticipated, and the role of relevant stakeholders. Other Advisory Comments 10. Based on my assessment in Annex C, I recommend that the authority takes a view as to whether the range of other matters discussed in this schedule can be addressed through amendments to the evidence report, or otherwise in preparatory work ahead of the proposed plan. Next Steps under Section 16B(11) of the Act 11. The planning authority should now amend its submission and submit a revised evidence report to Scottish Ministers for a subsequent gate check. It would be helpful if this submission included a clear narrative, perhaps in tabular form, setting out how the matters raised in this report have been addressed in the resubmission. For forward planning purposes, the council is requested to keep DPEA informed of the anticipated timeline for resubmission. Stephen Hall Reporter
Page 4
GATE-340-1 4 Annex A - Education Capacity Legislative Context (1997 Act) includes: Section 16B(3)(a) the planning authority to set out its views on the matters listed in section 15(5). Section 15(5) the education needs of the population of the district and the likely effects of development and use of land on those education needs. Section 15(5) the capacity of education services in the district. Section 15(5) the infrastructure of the district (including communications, transport and drainage systems, systems for the supply of water and energy, and health care and education facilities). Section 15(5) how that infrastructure is used. Section 15(5) any change which the planning authority think may occur in relation to any of these matters. Planning Policy and Guidance: NPF4 Policy 18 Infrastructure First Scottish Government Local Development Planning Guidance (2023) Sections of the evidence report: Evidence Report Appendix D Issue 20: Infrastructure – Education Facilities Assessment context A1. My assessment is set in the above context. In particular, section 16(3)(a) of the Act, in combination with section 15(5), requires the authority to set out its view on the education needs of the population, the likely effects of development on those needs and the capacity of education services. Page 67 of NPF4 indicates that LDPs should be based on an integrated infrastructure first approach and be informed by evidence on infrastructure capacity, condition, needs and deliverability. The glossary defines infrastructure first as encompassing education, including early years, primary, secondary, further and higher education services. The plan should set out the infrastructure requirements to deliver the spatial strategy, informed by the evidence base. A2. The LDP Guidance, paragraph 92 states that the evidence report can support an Infrastructure First approach by including an assessment of the capacity of existing infrastructure and services. Pages 67 to 69 set out Scottish Ministers’ advice on how planning authorities can take into account NPF4 national planning policies when preparing their evidence report. It is suggested that the evidence report may include a review of existing infrastructure capacity and condition, as well as identifying planned infrastructure. An assessment of broad areas of infrastructure constraint or capacity can indicate where there is scope for future growth in line with the infrastructure investment hierarchy, or where intervention will be required to support future development. A3. At page 132, the guidance also states that where planning authorities intend to seek developer contributions for delivery of infrastructure, including education infrastructure, the approach to be set out in the LDP may benefit from being developed collaboratively with infrastructure providers.
Page 5
GATE-340-1 5 Treatment of Education in the Evidence Report A4. The most detailed information in relation to education infrastructure is presented at Issue 20 in Appendix D. This summarises the Learning Estate Strategy, demographic changes in Perth and Kinross, and describes the existing learning estate. The locations of nurseries and schools are mapped. Some information is provided regarding the condition and suitability of the school estate. A5. As regards primary school capacity, it is stated that capacity levels will be set out, but this is not done within the evidence report or, it would appear, in any supplied background document. It is noted that certain primary schools have low pupil numbers while others are operating at 90 to 100% capacity, but these are not named or spatially identified. The council apparently monitors pupil rolls in relation to housing development using information provided in the housing land audit, but this analysis is not presented. A6. A case is made that interventions such as extensions and replacement schools may be required, and that the funding for this may, in part, be recouped through developer contributions. Elsewhere it is said that new school sites may be required as part of site allocations. But there is no indication as to in which parts of the authority’s area either of these approaches may be needed. A7. As regards secondary school capacity, a general statement is included to the effect that it is anticipated that existing secondary school infrastructure can accommodate pupil projections, calculated on the basis of population changes and housebuilding activity. No need for developer contributions is anticipated. A8. The summary of implications for the proposed plan does not draw any spatial conclusions, for instance about which parts of the plan area have spare existing schools capacity and which areas are constrained. In terms of gaps and uncertainties, it is stated that ‘additional school roll capacity needed to accommodate new development proposals for LDP3 will be assessed by the Council by reviewing individual primary catchment areas and capacity’. It is clear that this exercise has not been undertaken to date, and so has not fed in to the content of the evidence report. Discussion A9. 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. A10. 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
Page 6
GATE-340-1 6 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. A11. 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. A12. Further explanation could also usefully be provided as to how education colleagues have been involved in the preparation of this part of the evidence report. A13. 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 any signal to other authorities that this detail is a matter appropriately addressed at a later stage. That is not the case. Conclusion and Recommendation A14. 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; 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.
Page 7
GATE-340-1 7 Annex B - Emerging Reports and Strategies Legislative Context (1997 Act) includes: Section 16B(3)(a) the planning authority to set out its views on the matters listed in section 15(5) Section 15(8) the appointed person to assess whether the report contains sufficient information to enable the planning authority to prepare a LDP Planning Policy and Guidance: NPF4 Scottish Government Local Development Planning Guidance (2023) Sections of the evidence report: Evidence Report Issue 2 - Biodiversity and Natural Places Evidence Report Issue 4 - Forestry, Woodland and Trees Evidence Report Issue 5 - Historic Assets and Places Evidence Report Issue 6 – Green Belt Evidence Report Issue 7 - Brownfield, Vacant and Derelict Land, and Empty Buildings Evidence Report Issue 8 - Coastal Development and Aquaculture Evidence Report Issue 9 - Energy, Heating and Cooling Evidence Report Issue 10 - Zero Waste Evidence Report Issue 13 - Blue and Green Infrastructure Evidence Report Issue 15 – Flood Risk and Water Management Evidence Report Issue 17 - Homes Evidence Report Issue 22 - Transportation Evidence Report Issue 25 - Business and Industry Evidence Report Issue 28: Tourism Assessment context B1. My assessment is set in the above context. It is clear from section 16B(8) of the Act that evidence reports need to contain sufficient information to enable the planning authority to prepare its LDP. Paragraph 79 of the LDP Guidance states that the aim of the evidence report is to front-load the work and use the evidence to clearly inform what to plan for before the proposed plan looks at where development should take place. Paragraph 84 emphasises that taking time to get this stage of development planning right is important. Evidence Report B2. Within the various topics discussed in the evidence report, the authority frequently acknowledged that contributory reports, strategies and other analytic work was currently missing or out-of-date. In many cases work to fill these gaps was stated to be underway, or was planned to take place ahead of the publication of the proposed plan. The most significant examples are listed in the table below, including a note of what the evidence report says about the timescale for addressing each gap.
Page 8
GATE-340-1 8 Discussion B3. The Local Development Planning Guidance recognises that there may potentially be gaps in the evidence, and the council is to be commended on clearly and straightforwardly acknowledging those gaps that it has identified. However a stronger narrative on the concrete actions the council intends to take to address the identified gaps, and the timescales for these, is sometimes missing. B4. The overall impression is of a document conscientiously and comprehensively collated from the information available at this time, but that suffers from the amount of reports, strategies and analytical work that remains outstanding. Several important data sources are either missing or relatively dated. Those that I consider to be most significant are listed below. B5. In the main, these gaps are acknowledged in the report and some commitment exists to complete these work streams in relatively short order. I acknowledge that the completion of all this work is not necessarily in the council’s gift, and that a perfect co-ordination of the wide range of reports, studies and strategies across multiple agencies and sectors will never be possible. But given the volume of activity that appeared to be underway or anticipated on many of these items when the evidence report was written, the council could potentially have considered delaying the evidence report until a more complete suite of up-to-date information was available. B6. Below I have set out the missing items that I consider to be of most importance. All these gaps are acknowledged in the evidence report and I have also referenced what the evidence report says regarding the timescale for carrying out this work. In many cases it is clear that the relevant report, analysis or strategy is likely to now be complete. In other cases the work is expected to be complete in relatively short order. In the final column I have included my inferences and recommendations on each item. Issue Important Information Gaps Timescale for resolution as stated in the Evidence Report Reporter’s Comments and Recommendations 2 - Biodiversity and Natural Places A review of the Tayside Biodiversity Partnership Local Biodiversity Action Plan Will coincide with the development of the Proposed Plan A clearer commitment and timescale could usefully be provided in the revised report Local Biodiversity Sites programme Will not be complete until mid- 2025 Would appear to be available in time to include in revised report Nature networks Further engagement is ongoing, and is likely to run through 2025 for landscape scale Nature Networks, which will be Would appear to be available in time to include in revised report
Page 9
GATE-340-1 9 developed alongside green infrastructure and green network identification. 4 - Forestry, Woodland and Trees Forestry and Woodland Strategy Will require a review A clearer commitment and timescale could usefully be provided in the revised report 5 - Historic Assets and Places Conservation Area Appraisals A rolling review programme in place for reviewing our list of Conservation Areas which is expected to be completed during 2025-2026. Would appear to be available in time to include in revised report 6 – Green Belt Green Belt Review 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. 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. 7 - Brownfield, Vacant and Derelict Land, and Empty Buildings Register of potential brownfield regeneration sites/ urban capacity study 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 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
Page 10
GATE-340-1 10 be provided in the revised report. 8 - Coastal Development and Aquaculture Coastal Change Adaption Plan The Council has received funding, and if it is available timeously it will inform the Proposed Plan. A clearer commitment and timescale could usefully be provided in the revised report 9 - Energy, Heating and Cooling Formal Designation of Heat Network Zones Still to take place No timescale given. A clearer commitment and timescale could usefully be provided in the revised report. Renewable Energy guidance Programmed to be updated in 2025 Would appear to be available in time to include in revised report 10 - Zero Waste Waste Management Plan Covers the period 2010-2025 but is likely to be updated No timescale given. If replacement plan still not available to describe in the revised report, a clear commitment and timescale could usefully be provided. 13 - Blue and Green Infrastructure Open Space Quality Audit Not expected until summer 2025 Would appear to be available in time to include in revised report Open Space Strategy To follow at the end of 2025 Would appear to be available in time to include in revised report 15 – Flood Risk and Water Management Surface Water Management Plans 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 Would appear to be available in time to include in revised report. SEPA future flood maps Will be updated to reflect the UK 2018 climate change projections If now available, should be referred to in the revised report. 17 - Homes An updated needs assessment on the accommodation Will need to be carried out A clearer commitment and timescale could usefully be provided in the revised report
Page 11
GATE-340-1 11 needs of Gypsy/ Travellers and Travelling Show people 22 - Transportation Public transport route and passenger data Being collated by the Public Transport team at the time of writing If now available, could usefully be provided in the revised report 25 - Business and Industry Economic Action Plan Will be available by end of 2024 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. 28: Tourism Tay Cities Region Tourism Strategy 2019-2024 and Perthshire Tourism Action Plan 2021-2025 A new economic plan for Perth and Kinross is currently being developed 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. General Locality Profile exercise 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. B7. I recognise that the existing LDP was adopted in 2019, and that there is some urgency in expediting the LDP timetable. However, I do not consider that the return of the evidence report on the basis of the volume of contributary information that remains outstanding need cause excessive delay. The council has largely acknowledged the gaps and expects many of them to be filled ahead of the publication of the proposed plan. The proposed plan cannot practically be prepared until many of these workstreams are complete in any event. In order for the spatial
Page 12
GATE-340-1 12 strategy and site selection process of the emerging plan to be fully and properly informed, it is necessary for many of these reports and strategies to be in place. B8. There is no expectation that each and every item I have listed above will necessarily need to be completed ahead of any resubmission. However, where this is not possible, the report should include a clear statement as to the level of commitment to this work, its timing and the role of relevant stakeholders. B9. I acknowledge that some gaps are likely to remain, as will be the case for most evidence reports, and as the Local Development Planning Guidance acknowledges. But it is to be hoped that the number of such gaps can be reduced to a level that will allow me to conclude that sufficient up-to-date information is now available to properly inform the preparation of the local development plan. The focus of this reason for return is not on any expectation that the council need necessarily devote additional resource to preparing any further reports, studies or analysis than it has already committed to. Rather, the focus is on the timing of this work in relation to the finalisation of the evidence report, and on ensuring that the evidence report can take account of the outputs of workstreams that already appear to be underway. B10. The council should also consider the best timing for the publication of the proposed plan to ensure that as much of this information as possible is in place in time to inform it. B11. This schedule and the insufficiency it describes relates to the volume of reports and strategies that remain outstanding across the evidence report, and not to the detailed treatment of individual topics. Where I have particular comments to make on the policy issues affected, these are included as advisories in Annex C to this report. Conclusion and Recommendation B12. For the reasons stated, I find the evidence report to be insufficient with regard to the volume of emerging reports, strategies and analysis that remains outstanding. I recommend that the authority addresses this matter by: Taking advantage of the return of the report to update the text in respect of the range of reports, strategies and other analytical work that has completed since the writing of the original document; Considering the timing of any resubmission with respect to any reports, strategies and other analytical work that is expected to be finalised in the near future; and Where important documents will not be finalised ahead of resubmission, ensuring that the report clearly states the level of commitment to completing this work, the timescale which is anticipated, and the role of relevant stakeholders.
Page 13
GATE-340-1 13 Annex C - Other Matters (Advisories) Legislative Context (1997 Act) includes: Section 16B(3)(a) the planning authority to set out its views on the matters listed in section 15(5) Section 15(8) the appointed person to assess whether the report contains sufficient information to enable the planning authority to prepare a LDP Planning Policy and Guidance: NPF4 Scottish Government Local Development Planning Guidance (2023) Sections of the evidence report: All Assessment context C1. My assessment is set in the above context. Section 16B(10) of the Act only requires assessment reports to set out reasons why the appointed person is not satisfied that the evidence report contains sufficient information, and recommendations for improvement. However, reporters have found it useful, both in cases where evidence reports have been found to be sufficient and insufficient, to also include advisory comments. These have included noting examples of good practice as well as highlighting areas that, though not pointing to an overall insufficiency, would nevertheless benefit from being given further consideration by the planning authority. C2. In carrying out my assessment of this evidence report, I noted a number of such other matters, some of which apply across various topics and some which are topic specific. In general terms, these largely relate to the expectations of NPF4 and to government guidance rather than being directly attributed to the requirements of the Act under section 15(5). However, in some cases legislative provisions are relevant, and moving forward there is a requirement to take NPF4 into account. These other matters would not individually have led me to conclude that the report was insufficient, but are included below for the authority’s consideration in revising the report and, in due course, preparing its proposed LDP. Advisory Comments on the Evidence Report General Comments C3. The evidence report collates an impressive amount of information, and appears to be a largely comprehensive overview of the evidence available to the council at this time. The discussion of the individual issues in the report broadly follows the template suggested at Figure 7 of the Local Development Planning Guidance. This will have assisted the council to brigade the necessary information. Generally I found that the report did a good job of summarising the suite of individual relevant reports and strategies (insofar as these were available at the time), the implications for the proposed plan and any gaps or disputes. But it was occasionally somewhat weaker in capturing an overall narrative as to the main spatial issues affecting particular topics in the plan area, for instance in providing an overview of shopping patterns, green networks or mineral reserves in Perth and Kinross.
Page 14
GATE-340-1 14 C4. With an overall length of over 1,200 pages, I consider the scale of the document to be excessive. The splitting of the discussion of topics between the main report and appendices necessitated a great deal of repetition that I did not find helpful. However, I did find that the tables of gaps and disputes in the main report facilitated my identification of the main matters of potential concern. C5. I am satisfied that the council took the views of most relevant parties into account in the preparation of the final evidence report. However, I note that some parties I would have expected to be involved appear not to have been, including neighbouring roads authorities and public transport service providers. C6. Consultation was focussed around topic papers, which is a reasonable approach. But in some cases, particularly where changes were made to the report in response to comments, some follow-up correspondence would have been useful to secure confirmation that the relevant party was content with changes made. This appears to have happened in some cases (for instance with Transport Scotland), but not consistently. C7. The use of online forms to gather responses may have merit, but the outputs of such an exercise need to be presented in a way that is transparent and easy to follow. A clear and full paper trail of parties’ responses was not submitted to the gate check which necessitated a request for further information to satisfy myself that parties’ views were properly taken into account. Issue 2: Biodiversity and Natural Places C8. 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. Issue 6: Green Belts C9. 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. C10. 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 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 in to the evidence report. I advise that work on the green belt review is now advanced timeously with the involvement of relevant stakeholders.
Page 15
GATE-340-1 15 C11. I note that the key for Figure 2 of Issue 6 appears to mix up the notations for the proposed and adopted green belt. Issue 9: Energy, Heating and Cooling C12. The council is yet to identify any Heat Network Zones as required by the Heat Networks (Scotland) Act 2021. I note that designating such a zone is a key action of the Local Heat and Energy Efficiency Strategy 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. Issue 10: Zero Waste C13. I note the statement at page 6 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. Issue 13: Blue and Green Infrastructure C14. 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 blue and green network 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. Issue 14: Play, Recreation and Sport C15. 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. Issue 17: Homes C16. I am content that a sound and evidenced explanation has been given for the selection of the indicative local housing land requirement (ILHLR), the main elements of this being that: the council has systematically addressed the factors that informed the minimum all-tenure housing land requirement (MATHLR) set out in NPF4, and found these largely unchanged (but acknowledges the possible need for further changes ahead of the proposed plan stage, for instance in response to the release of the results of the 2022 census); an adjustment to the data that informed the MATHLR has been made where justified by improved information on custom/ self-build;
Page 16
GATE-340-1 16 other evidence, including the report ‘Existing Housing Need in Perth and Kinross’, commissioned by Homes for Scotland, has been appropriately considered; the MATHLR itself was in this case already notably ambitious being based on growth aspirations beyond the high migration scenario of the Housing Need and Demand Assessment (HNDA); the HNDA remains current, having been published in November 2022 and confirmed as being robust and credible by the Scottish Government’s Centre for Housing Market Analysis in May 2023; and the ILHLR is greater than the MATHLR, as is expected by NPF4, albeit by only 200 houses (2.4%). C17. As regards the increased allowance proposed to be made for custom/ self- build housing, 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 the supply. C18. 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 proposed plan. C19. 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 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. Issue 21 - Health Care Facilities C20. 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 (page 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. Issue 26 – Retail, City, Town and Commercial Centres and Issue 29 – Culture and Creativity C21. 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
Page 17
GATE-340-1 17 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 different tiers of settlement. I acknowledge that much of this information is contained in the Town Centre 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. C22. The LDP Guidance suggests authorities should use town centre audits to inform town centre 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 Town Centre 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 the proposed plan. Issue 27 – Rural Development C23. 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. Issue 30 – Minerals C24. 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. Conclusion and Recommendation C25. I do not consider that the matters discussed in this schedule amount to such insufficiencies as would, on their own, have caused me to return the report. Nevertheless, I recommend that the authority considers the matters raised and takes a view as to whether they can be addressed through amendments to the evidence report, or otherwise in preparatory work ahead of the proposed plan.