LDP3 Evidence Report Board Report
Renfrewshire Council · 25 September 2025
Back to Council — 25 September 2025 and its agenda
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___________________________________________________________________ To: Council On: 25th September 2025 ___________________________________________________________________ Report by: Chief Executive ___________________________________________________________________ Heading: Renfrewshire Local Development Plan 3 – Evidence Report ___________________________________________________________________ 1. Summary 1.1 The purpose of this report is to seek approval of the Renfrewshire Local Development Plan 3 (LDP3) Evidence Report and authorise its submission to the Scottish Ministers for the ‘Gate Check’ review process when an independent assessment of the evidence will be carried out by a Reporter appointed by the Scottish Ministers. 1.2 The Evidence Report is the first key stage in the preparation of the new Local Development Plan and provides a body of evidence that will inform the content of the plan. ___________________________________________________________________ 2. Recommendations 2.1 It is recommended that Council: 1) Approve the Local Development Plan Evidence Report as contained in Appendix 1, with delegated authority provided to the Head of Economy and Development to make amendments to the Evidence Report format as required to meet the Scottish Government Directorate of Planning and Environmental Appeals submission requirements; and,
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2) Note that following approval by Council, and any necessary reformatting, officers will submit the Evidence Report to Scottish Ministers for the Gate Check review process. _________________________________________________________ 3. Background 3.1 A new Renfrewshire Local Development Plan (LDP3) is currently being prepared which will set out a 10+ year vision and spatial strategy for Renfrewshire and guide future land use and development over the plan period to 2038. 3.2 LDP3 is being prepared under a new statutory process for development planning introduced by the Planning (Scotland) Act 2019 and Development Planning Regulations 2023. A key change is the requirement to prepare an Evidence Report, with its approval reserved to Council. 3.3 The Evidence Report provides a robust evidence base to inform the preparation of the new Local Development Plan and to consider the implications of this evidence on the emerging spatial strategy of the new plan. 3.4 Following approval of the Evidence Report, the Council is required to submit the report to Scottish Ministers for the Gate Check review process. Scottish Ministers will appoint an independent Reporter to review the evidence and assess whether the report includes a sufficient evidence base to inform the preparation of the new Local Development Plan. 3.5 Further information on the LDP3 preparation process, including the Evidence Report and Gate Check stage, is included in the Renfrewshire Development Plan Scheme 2024 which was approved by the Planning and Climate Change Policy Board on 5th November 2024. 4. Evidence Report 4.1 The Evidence Report is considered to provide a robust evidence base to prepare the new Local Development Plan. The Evidence Report submission includes several documents: • Evidence Report - Sets out the evidence base that has been gathered to inform the preparation of the Proposed Plan. It is structured around 28 topics which are aligned with the policy themes of National Planning Framework 4 (Appendix 1). • Position Statement – Provides a summary of the scope of each evidence topic and identifies any evidence gaps or disputes
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raised by stakeholders on the sufficiency of evidence (Appendix 2). • Consultation and Engagement Report - Statement to explain how the Council has sought stakeholder views in line with legislative requirements (Appendix 3). • LDP2 Review – A review of LDP2 policies and delivery to inform preparation of LDP3 (Appendix 4). • Strategic Environmental Assessment (SEA) Scoping Report – The SEA is an integral part of the plan preparation process and ensures environmental considerations are taken into account at an early stage. The Scoping Report is the first key stage of the SEA and defines the scope and level of environmental detail to be covered in the Environmental Report for the Proposed Plan (Appendix 5). 4.2 To inform the preparation of the Evidence Report, extensive consultation and engagement has taken place with a wide range of stakeholders including residents, young people, community councils, Key Agencies, local businesses and developers, Council services, OneRen and HSCP. 4.3 The approach to consultation and engagement is set out in the Consultation and Engagement Report prepared alongside the Evidence Report. This report also includes the Council’s approach to support communities prepare Local Place Plans for their area. 4.4 The Evidence Report also includes a ‘Summary of stakeholder engagement and Council response to representations’ section for each evidence topic. This includes a summary of each representation received and how these have been taken into account in finalising the Evidence Report. Structure and Content 4.5 The structure and content of the Evidence Report is informed by legislation, Local Development Plan Guidance (2023) and feedback received during early consultation and engagement. The Evidence Report is topic based and structured around the three policy themes of National Planning Framework 4 – Sustainable Places, Liveable Places and Productive Places. 4.6 The wide range of evidence topics included under each theme is set out below: Sustainable Places • Topic 1 – Climate Change and Adaptation • Topic 2 – Biodiversity and Natural Places • Topic 3 – Soils • Topic 4 – Forestry, Woodland and Trees • Topic 5 – Historic Assets and Places
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• Topic 6 – Greenbelt and Landscape Character • Topic 7 – Brownfield, Vacant and Derelict Land and Empty Buildings • Topic 8 – Coastal Development • Topic 9 – Energy • Topic 10 – Zero Waste • Topic 11 – Sustainable Transport Liveable Places • Topic 12 – Design, Quality, Place and Local Living • Topic 13 – Site Assessment Methodology • Topic 14 – Demographic Profile and Quality Homes • Topic 15 – Education • Topic 16 – Cemeteries and Crematoria • Topic 17 – Heat and Cooling • Topic 18 – Open Space and Play, Recreation and Sport • Topic 19 – Flood Risk • Topic 20 – Water Management • Topic 21 – Health and Safety • Topic 22 – Major Accident Hazard Sites and Pipeline • Topic 23 – Digital Infrastructure Evidence Report Theme – Productive Places • Topic 24 – Business and Industry • Topic 25 – Glasgow Airport • Topic 26 – Centres and Retail • Topic 27 – Tourism, Culture and Creativity • Topic 28 – Minerals 4.7 The evidence for each topic is included in the Evidence Report attached at Appendix 1. Areas of Agreement / Dispute 4.8 In preparing the Evidence Report the Council is required to identify areas where key stakeholders agree with the evidence presented and areas where the evidence is disputed. The Position Statement (Appendix 2) highlights the areas where the evidence is disputed or there is uncertainty over the evidence presented. The areas of dispute are likely to be the focus of the Gate Check process. 4.9 Overall it is considered that there is broad agreement with key stakeholders on most of evidence presented. There are a small number of disputes over the sufficiency of the evidence which were identified during the extensive consultation and engagement undertaken to prepare the Evidence Report. Officers sought to resolve any evidence dispute through further engagement but in some instances, it was not possible to address these in finalising the Evidence Report.
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4.10 The areas of significant dispute mainly relate to the housing and the setting of the 10-year housing land requirement (Topic 14), the Council’s approach to education analysis and addressing capacity constraints (Topic 15) and the potential for development contributions to be required for health care infrastructure (Topic 21). The disputes have generally been raised by Homes for Scotland and supported by their individual members. Housing Land 4.11 The Council are required to set a Local Housing Land Requirement in the Evidence Report. This is the amount of land required for housing during the 10-year period of the Local Development Plan. National Planning Framework 4 (NPF4) sets an expectation that the Local Housing Land Requirement should exceed the 10-year Minimum All- Tenure Housing Land Requirement set out in NPF4. For Renfrewshire the Minimum All-Tenure Housing Land Requirement is set at 4,900 homes. 4.12 The Evidence Report sets the Local Housing Land Requirement at 5,750 homes over the 10-year period of the Local Development Plan (2028-2038). This is considered to be the amount of housing land needed to meet housing need and demand across Renfrewshire during that period. The process and evidence used to set this land requirement is set out in Topic 14 of the Evidence Report. 4.13 Homes for Scotland and individual housebuilders dispute some of the evidence used in the Evidence Report to set the Local Housing Land Requirement. This primarily relates to the level of housing need across Renfrewshire which they identify as being much higher than the levels evidenced in two referenced evidence documents, the regional Housing Need and Demand Assessment 3 and the Renfrewshire Housing Need and Demand Study (2023). These assessments were prepared in support of the approved Renfrewshire Local Housing strategy 2023- 2028 and are therefore considered to be robust sources of evidence for setting the Local Housing Land Requirement. 4.14 Homes for Scotland and individual housebuilders identify that the proposed Local Housing Land Requirement (5,750 homes) is insufficient to meet recent demand in Renfrewshire based on past housing completions and propose a higher requirement of 7,500 homes for the 10-year period of the Plan. However, no changes have been made to the Local Housing Land Requirement in response to the received representations, and as per above, based on the Council’s evidence, the Evidence Report suggests it be set at 5,750 homes.
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Education 4.15 Education facilities are identified as an infrastructure within the context of the National Planning Framework’s (NPF4) infrastructure first approach. This means that capacity must exist within Council educational facilities to accommodate pupils arising from housing allocations identified in the Local Development Plan. 4.16 The Planning Service has engaged with Children’s Services regarding school capacity projections and alignment with the Council’s Learning Estate Strategy. Although not yet available, school roll projections will be updated to cover the full plan period (i.e. to 2038), and to take account of the preferred spatial strategy of the proposed Local Development Plan i.e. housing land allocations. This should identify where investment in additional school capacity is required to accommodate new housing development. 4.17 Representations from the development industry have expressed concern about how the need for additional school capacity and associated developer contributions will be calculated. Some of these concerns are associated with the requirements set out in the Developer Contributions (Education) Planning Guidance associated with the current Local Development Plan (LDP2) and how the approach set out in that document will influence the approach set out in the new Local Development Plan. Health 4.18 Health and social care services are identified as an infrastructure within the context of the National Planning Framework’s (NPF4) infrastructure first approach. This means that capacity must exist within health facilities to accommodate patients arising from new housing allocations identified in the Local Development Plan. 4.19 The Planning Service has engaged with Renfrewshire HSCP and Greater Glasgow and Clyde NHS regarding patient capacity in primary care facilities, and particularly GP surgeries. While patient numbers are available, information is not available on operating capacities of GP surgeries, and the potential for GP surgeries to expand to accommodate new development. This is considered an evidence gap and availability of capacity within GP surgeries will be a consideration in the assessment of possible housing allocations. 4.20 Homes for Scotland dispute the requirement for the housebuilding industry to contribute towards primary care facilities such as GP surgeries. It is the Council’s view, however, that developer contributions should be sought to address any deficit in primary care facilities to accommodate new development, where the evidence is available to show that a new or expanded facility is required to accommodate new development.
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4.21 The Evidence Report includes detailed responses to the disputes and the Council’s evidence to support the position set out in the report. Both the Council’s evidence and the representations received will be assessed by the Reporter during the Gate Check process. 5. Next Steps 5.1 Once approved, the Evidence Report will be submitted to the Scottish Ministers for the Gate Check review process. It is anticipated that the Gate Check review will take approximately 3 months to conclude. 5.2 The appointed Reporter can conclude that the information is sufficient and that the Council can proceed with the preparation of the new plan, request further information, or deem that the evidence is insufficient. If insufficient, the Reporter will provide a Gate Check assessment report which outlines reasons for their conclusions and any recommendations for improvement. A copy of the assessment report will be sent to the Council and the Scottish Ministers. Where an assessment report is issued, the Council will require to address the areas of improvement and resubmit the Evidence Report to the Gate Check. The outcome of the Gate Check will be reported back to Council. 5.3 The Evidence Report is a snapshot in time and parts of the evidence may change between the time the Evidence Report is agreed by Council and during the preparation of the Proposed Plan. The Proposed Plan will be based on the most up-to-date evidence at the time. The Place Strategy team will ensure the evidence remains up to date throughout the plan preparation process. ___________________________________________________________________ Implications of the Report 1. Financial – Approving the Evidence Report for submission to the Scottish Ministers will result in the assessment and administrative fees associated with the Gate Check review process. The exacts costs will depend on the duration of the Gate Check process, however, it is anticipated that the cost will be approximately £20,000. The Reporter can return the Evidence Report as insufficient and this would require a further Gate Check process which would generate additional costs. 2. HR & Organisational Development – None. 3. Community/Council Planning – The Evidence Report will support the preparation of the Local Development Plan which is a wide-ranging document and is considered to support the priorities of the Renfrewshire Community Plan and the Council’s strategic outcomes.
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4. Legal – The preparation of a Local Development Plan is a statutory requirement for planning authorities. The Council is following statutory procedures in preparing the plan. The approval of the LDP3 Evidence Report is reserved to Council under Section 16B of the Town and Country Planning Act (Scotland) 1997. 5. Property/Assets – None. 6. Information Technology – None. 7. Equality & Human Rights - The recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. The impact assessment has highlighted the need to ensure that certain groups with protected characteristics and from areas of socio-economic disadvantage are involved in the Local Development Plan process. Equalities monitoring of the Local Development Plan participant database and engagement processes will continue to be undertaken to monitor and highlight groups or areas where targeted consultation may be required. A full copy of the Equality Impact Assessment undertaken is available from the report author. Following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored. The results of the assessment will be published on the Council’s website. 8. Health & Safety - None. 9. Procurement – None. 10. Risk - There is a risk that the Council’s Evidence Report may be found to be insufficient at the Gate Check stage. To mitigate this risk, officers have engaged with stakeholders throughout the preparation process and have reviewed the findings of Gate Checks completed for other Council’s across Scotland to ensure a robust evidence base is presented. 11. Privacy Impact – None. 12. Climate Risk – The Evidence Report includes an evidence base on climate related factors and risks. The Local Development Plan will have regard to and support the implementation of the Council’s Plan for Net Zero. 13. Children’s Rights – Through engagement with children and young people, the approach being taken by the Council demonstrates compliance with Article 12 ‘Respect for Children’s Views. 14. Cosla Policy Position – None.
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_______________________________________________________ List of Background Papers (a) The Evidence Report is supported by a range of Background Papers which are available to view via links embedded in the Evidence Report (Appendix 1). Appendices Appendix 1 – Renfrewshire LDP3 Evidence Report Appendix 2 – Position Statement Appendix 3 – Consultation and Engagement Report Appendix 4 – Local Development Plan 2 Review Appendix 5 – Strategic Environmental Assessment Scoping Report ___________________________________________________________________ Author: Alan Williamson, Strategy & Place Manager, alan.williamson@renfrewshire.gov.uk, 07811 053968