Permitted development rights to support the provision of new homes: consultation - summary of responses

Summary of Responses

Permitted Development Rights for Rural Homes

Question 1: Do you consider that the maximum limit in Classes 18B and 22A of five residential units per agricultural unit or forestry building should be changed? If so, in what way? Please explain your answer including (if appropriate) how you consider the limit should change.

There were 333 responses to this question. A breakdown of responses by respondent category is provided in Table 1.

Table 1

Respondent category	Yes	No	Unsure
Individuals	17 (6%)	86 (32%)	169 (62%)
Public bodies: planning authorities and HOPS	0 (0%)	22 (92%)	2 (8%)
Public bodies: other	3 (38%)	1 (13%)	4 (50%)
Land and property development	7 (100%)	0 (0%)	0 (0%)
Land and built environment	2 (33%)	2 (33%)	2 (33%)
Music, events and hospitality	0 (0%)	5 (50%)	5 (50%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	0 (0%)	1 (33%)	2 (67%)
Total	29 (9%)	117 (35%)	187 (56%)

Concerns about increasing the limit centred on potential resultant negative impacts on local infrastructure, rural landscapes, existing communities and environmental sustainability generally. Many respondents emphasised the importance of a plan-led approach, noting that any increase in residential development should be assessed against the development plan, through a planning application, to ensure alignment with National Planning Framework 4 (NPF4).

Several respondents questioned whether changing the unit limit would meaningfully increase housing delivery. They highlighted practical constraints to conversion, including high costs associated with such projects, financing issues, technical and servicing limitations of existing buildings, and the relatively limited take-up of the existing permitted development rights (PDR). However, some noted that in cases involving redundant or disused agricultural buildings, there may be circumstances where a higher unit limit could be appropriate.

A minority of respondents supported changing the limit, with differing views as to whether the limit should be increased or decreased. Some respondents expressed a view that the current limit was unnecessarily restrictive and should be raised or removed. Some made various suggestions with regard to replacing the unit limit, for example by limits linked to the size of the building or landholding, or raising the limit in areas identified as experiencing depopulation. Other respondents suggested reducing the limit, for various reasons including to better protect rural character and the environment and to strengthen a plan-led approach to development.

Question 2: Do you believe the current floor space maximum of 150 square metres in Classes 18B and 22A should be removed or increased? Please explain how and why.

There were 318 responses to this question. A breakdown of responses by respondent category is set out in Table 2.

Table 2

Respondent category	Yes	No	Unsure
Individuals	23 (9%)	65 (25%)	172 (66%)
Public bodies: planning authorities and HOPS	2 (8%)	17 (71%)	5 (21%)
Public bodies: other	2 (33%)	0 (0%)	4 (67%)
Land and property development	3 (50%)	2 (33%)	1 (17%)
Land and built environment	1 (17%)	2 (33%)	3 (50%)
Music, events and hospitality	0 (0%)	5 (50%)	5 (50%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	0 (0%)	0 (0%)	3 (100%)
Total	31 (10%)	91 (29%)	196 (62%)

Those respondents who said that the floor space maximum should not be removed or increased gave various reasons. Some commented that the limit helps to ensure new rural homes remain small-scale and in keeping with local character. Concerns were raised that increasing or removing the limit could lead to the development of high-value and oversized dwellings that may not address local housing needs, and result in additional strain on local infrastructure and services and adverse impacts on landscape character, biodiversity and the historic environment.

A smaller number of respondents expressed support for either removing or increasing the maximum floor space limit. Some of the respondents considered the 150 square metre cap was overly restrictive and constrained the viability of development. Some suggested that an increased limit would better reflect modern family needs, enable more flexible and adaptable design solutions, contribute to increasing the rural housing supply and revitalise rural communities. Some of those supporting an increased limit still emphasised a need for appropriate safeguards, including to prevent overdevelopment and to ensure alignment with rural planning policies.

Question 3: Do you believe that small extensions and/or separate buildings should be allowed as part of the conversion of an agricultural or forestry building to residential use under PDR? Please explain your answer.

There were 319 responses to this question. A breakdown of responses by respondent category is set out in Table 3.

Table 3

Respondent category	Yes	No	Unsure
Individuals	75 (29%)	46 (18%)	136 (53%)
Public bodies: planning authorities and HOPS	5 (21%)	12 (50%)	7 (29%)
Public bodies: other	5 (63%)	1 (13%)	2 (25%)
Land and property development	6 (86%)	0 (0%)	1 (14%)
Land and built environment	2 (33%)	1 (17%)	3 (50%)
Music, events and hospitality	1 (10%)	4 (40%)	5 (50%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	2 (50%)	0 (0%)	2 (50%)
Total	96 (30%)	64 (20%)	159 (50%)

Those who supported allowing small extensions and separate buildings gave various reasons. These included that it could make conversions more practical and viable; could support energy efficiency measures; and that the acceptability in principle of residential development was already established.

Those respondents who answered ‘no’ gave several reasons including in relation to potential risks related to harm to rural character, cultural heritage, landscape quality, and biodiversity. Other concerns raised included a potential increase in car usage, added pressure on infrastructure and services, and inconsistency with policy objectives set out in National Planning Framework 4.

Question 4: Do you consider that any of the current location-based restrictions in relation to Classes 18B and 22A should be removed and if so, which? Please explain your answer.

There were 310 responses to this question. A breakdown of responses by respondent category is provided in Table 4.

Table 4

Respondent category	Yes	No	Unsure
Individuals	15 (6%)	82 (32%)	156 (62%)
Public bodies: planning authorities and HOPS	1 (4%)	21 (88%)	2 (8%)
Public bodies: other	2 (67%)	1 (33%)	0 (0%)
Land and property development	4 (67%)	1 (17%)	1 (17%)
Land and built environment	0 (0%)	5 (71%)	2 (29%)
Music, events and hospitality	0 (0%)	5 (50%)	5 (50%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	0 (0%)	2 (50%)	2 (50%)
Total	22 (7%)	117 (38%)	171 (55%)

Over half of respondents were ‘unsure’. Many said they were unable to give a definitive view, due to a lack of expertise or because they considered the question was too broad or lacked sufficient detail.

Over a third of respondents answered ‘no’, reflecting a view that none of the current location-based restrictions should be removed. Reasons given included that the existing protections are essential for safeguarding archaeological sites, heritage, sensitive landscapes, croft land, and biodiversity, and for ensuring appropriate oversight through the planning system. Many expressed a view that weakening restrictions could lead to irreversible environmental or heritage harm and conflict with NPF4.

The small proportion of respondents who expressed support for removal of location-based restrictions generally argued that they were overly restrictive. Some called for the removal of all or most restrictions, while others focused specifically on the croft land restriction, stating that it limits rural housing delivery, hinders community revitalisation, and prevents the reuse of redundant buildings. A larger number of respondents questioned the restriction on sites of archaeological interest, suggesting it was too broad and could block otherwise appropriate development. Several argued that archaeological considerations could be more effectively managed through a prior notification or approval process rather than through blanket exclusions. A few respondents suggested that restrictions should be based on the condition and suitability of the building itself rather than its location within any particular designation.

Some respondents considered a clearer definition of “site of archaeological interest” and associated guidance would be beneficial.

Question 5: Do you consider the prior notification and approval mechanism (including the relevant matters and fee) associated with Classes 18B and 22A should be changed? If so, how? Please explain your answer.

There were 308 responses to this question. A breakdown of responses by respondent category is provided in Table 5.

Table 5

Respondent category	Yes	No	Unsure
Individuals	27 (11%)	60 (24%)	160 (65%)
Public bodies: planning authorities and HOPS	15 (63%)	9 (38%)	0 (0%)
Public bodies: other	4 (57%)	0 (0%)	3 (43%)
Land and property development	4 (67%)	0 (0%)	2 (33%)
Land and built environment	3 (50%)	1 (17%)	2 (33%)
Music, events and hospitality	0 (0%)	4 (40%)	6 (60%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	1 (20%)	3 (60%)	1 (20%)
Total	54 (18%)	77 (25%)	177 (57%)

Points made in support of changing the mechanism included that the current process was regarded as overly complex, time-consuming, resource-intensive and having limited added value compared with the planning application process. Some respondents favoured a simpler, single-stage process to improve clarity, certainty and consistency, supported by clearer guidance and proportionate fees linked to the scale or number of dwellings. Some considered that simplification would encourage the use of the PDR and speed up rural housing delivery. Some suggested changes to the list of prior approval matters (for example, adding design and impacts on protected species). Others suggested removing the mechanism entirely, with some considering that conversions should instead be the subject of a full planning application.

Reasons given for opposing changes to the prior notification and approval mechanism included that the current process was important for planning oversight and transparency. Concerns were raised that changes to the mechanism could increase risks of harm to amenity, environmental protection, existing businesses, croft land and in relation to flooding. The prevailing view expressed was that altering the prior notification and approval mechanism would reduce scrutiny and could lead to poorer-quality development, increase burdens on authorities and fail to increase housing delivery.

Some respondents supported higher fees, or a fee structure based on the number of dwellings being proposed.

Question 6: Do you consider that PDR should allow the change of use of any other buildings or agricultural/forestry land to residential? If so, to which type(s) of building should the PDR be extended, and why?

There were 305 responses to this question. A breakdown of responses by respondent category is provided in Table 6.

Table 6

Respondent category	Yes	No	Unsure
Individuals	26 (11%)	71 (29%)	150 (61%)
Public bodies: planning authorities and HOPS	2 (8%)	19 (79%)	3 (13%)
Public bodies: other	3 (50%)	1 (17%)	2 (33%)
Land and property development	4 (67%)	0 (0%)	2 (33%)
Land and built environment	1 (17%)	1 (17%)	4 (67%)
Music, events and hospitality	0 (0%)	5 (50%)	5 (50%)
Energy, renewables and utilities	0 (0%)	0 (0%)	2 (100%)
Other	0 (0%)	1 (25%)	3 (75%)
Total	36 (12%)	98 (32%)	171 (56%)

Of those respondents who answered ‘yes’, some commented that the PDR should be extended to other types of buildings without specifying what types. Others suggested specific types of buildings which could be suitable for conversion, including stables, workshops, estate buildings, former schools, churches, village halls and other rural commercial buildings. Reasons for extending the PDR to such buildings included that it would be a sustainable means of reducing dereliction and supporting rural regeneration/repopulation, although some respondents highlighted a need for safeguards on design quality, heritage and archaeology.

Of the respondents that answered ‘no’, various reasons were given. These included concerns about unsustainable development, loss of agricultural land and woodland, impacts on rural character and harm to biodiversity and heritage assets. Other reasons given included that broader PDR would reduce planning oversight, undermine the plan-led system and local democracy, and create unintended consequences such as infrastructure pressures, conflicts with existing businesses, and dispersed car-dependent housing contrary to NPF4 policies.

Question 7: Do you consider that the PDR under Classes 18B and 22A should be expanded or revised in any other way? Please explain your answer.

There were 302 responses to this question. A breakdown of responses by respondent category is provided in Table 7.

Table 7

Respondent category	Yes	No	Unsure
Individuals	8 (3%)	63 (26%)	175 (71%)
Public bodies: planning authorities and HOPS	6 (25%)	17 (71%)	1 (4%)
Public bodies: other	1 (25%)	2 (50%)	1 (25%)
Land and property development	3 (50%)	2 (33%)	1 (17%)
Land and built environment	2 (33%)	1 (17%)	3 (50%)
Music, events and hospitality	0 (0%)	5 (50%)	5 (50%)
Energy, renewables and utilities	0 (0%)	0 (0%)	2 (100%)
Other	0 (0%)	1 (25%)	3 (75%)
Total	20 (7%)	91 (30%)	191 (63%)

Almost a third of respondents to this question answered ‘no’, reflecting an opinion that the PDR should not be expanded or changed in any other way. Those respondents generally cautioned that expansion could weaken planning oversight, undermine the plan-led system, and harm communities, infrastructure and green spaces, while delivering limited benefits. Some commented that prior approval or full planning applications remained necessary to ensure sustainable development and manage cumulative impacts.

A small percentage of respondents answered ‘yes’. Some argued that Classes 18B and 22A should be clearer, simpler and more effective. Suggestions included removing subjective wording and the prior notification/approval process, which some saw as leading to inconsistent decisions and low uptake. Some respondents suggested allowing conversion of a wider range of rural buildings and greater flexibility in remote rural areas and for community-led housing. It was also suggested that conversion of non-residential to holiday letting accommodation should be permitted, to meet the demands of tourism and for rural diversification. Some emphasised a need to balance increased flexibility with safeguards for water supply, infrastructure, woodland, green belt land, housing quality, and alignment with NPF4 to support sustainable rural economies.

The majority were ‘unsure’ and raised mixed considerations. Some respondents felt that, with national guidance and a strong focus on permanent residential use, limited revisions could be beneficial. Some expressed concern that expansion could encourage short-term holiday lets in areas already encountering overtourism and lack of affordable housing. Conversely, others suggested that PDR for the conversion of rural buildings to holiday lets would be beneficial, to help meet tourism demand without the need to repurpose existing permanent housing.

Question 8: Do you believe that there should be new PDR for the replacement of agricultural and forestry buildings with new-build homes in particular circumstances? If so, in what circumstances? Please explain your answer.

There were 307 responses to this question. A breakdown of responses by respondent category is provided in Table 8.

Table 8

Respondent category	Yes	No	Unsure
Individuals	30 (12%)	62 (25%)	152 (62%)
Public bodies: planning authorities and HOPS	0 (0%)	23 (100%)	0 (0%)
Public bodies: other	2 (33%)	2 (33%)	2 (33%)
Land and property development	6 (100%)	0 (0%)	0 (0%)
Land and built environment	0 (0%)	4 (57%)	3 (43%)
Music, events and hospitality	0 (0%)	4 (40%)	6 (60%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	2 (40%)	1 (20%)	2 (40%)
Total	40 (13%)	96 (32%)	168 (55%)

Those answering ‘no’ to this question generally did not provide any reasons. Where reasons were given, these generally noted a need for various limits and controls over such PDR, including in some cases a requirement for justification as to why a building cannot be converted. Various concerns regarding such PDR were raised, including potential negative impacts on infrastructure, public scrutiny, heritage, landscape, biodiversity, noise pollution, climate and food security.

Those respondents answering ‘yes’ gave various reasons. These mainly focused on addressing rural housing shortages where existing agricultural or forestry buildings are genuinely redundant and unsuitable for conversion. Some suggested various limitations and exclusions to such PDR. Suggestions included ensuring replacement is within the footprint, excluding certain protected or designated areas, and needing to address factors such as building height, curtilage, design, occupancy, and environmental factors. Comments also referred to new build being more economically viable compared to conversion.

Question 9: Do you believe that there should be new PDR for new-build homes in any particular types of rural areas in particular circumstances? If so, in what type of rural areas and in what circumstances? Please explain your answer.

There were 316 responses to this question. A breakdown of responses by respondent category is provided in Table 9.

Table 9

Respondent category	Yes	No	Unsure
Individuals	19 (8%)	83 (33%)	151 (60%)
Public bodies: planning authorities and HOPS	0 (0%)	24 (100%)	0 (0%)
Public bodies: other	2 (22%)	5 (56%)	2 (22%)
Land and property development	2 (40%)	0 (0%)	3 (60%)
Land and built environment	0 (0%)	4 (57%)	3 (43%)
Music, events and hospitality	0 (0%)	4 (40%)	6 (60%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	2 (40%)	2 (40%)	1 (20%)
Total	25 (8%)	122 (39%)	169 (53%)

A small number of respondents answered ‘yes’ to this question. Some supported PDR for small-scale new-build housing developments to address shortages, affordability, and depopulation. Support generally focused on sites adjacent to settlements, farms, in clusters, on garden ground, brownfield land and high-tourism areas. Respondents typically favoured one-off or small numbers of homes linked to rural businesses, self-build, community-led, affordable, social, or key-worker housing. Some suggested safeguards including requiring alignment with local development plans, planning authority oversight, and national design guidance.

A greater number of respondents answered ‘no’ to this question. Those that gave an explanation generally considered that new-build rural housing should remain the subject of planning applications, including to maintain a plan-led system, allow each proposal to be assessed on its own merits, and help to better protect landscape, biodiversity, heritage, prime agricultural land and consider and address infrastructure issues. Other concerns raised related to risks of speculative or second-home development, unsustainable growth, and impacts on communities, businesses, and cultural venues. Some respondents emphasised that rural areas are diverse and site-specific, and that existing mechanisms (including Masterplan Consent Areas) already provide appropriate routes for the provision of sustainable housing.

Those ‘unsure’ gave mixed views. Some expressed cautious support for PDR permitting targeted development, including brownfield, infill, or replacement housing in depopulating areas or where demand is clear. Some highlighted a need for safeguards to address matters such as flood risk, infrastructure, environmental impacts and design. Some warned that widespread and unrestricted PDR could lead to unsustainable development and unintended harm to the environment or communities.

Permitted Development Rights for Town Centre Living

Question 10: Do you consider that proposals to convert the ground floor or entirety of buildings in town and city centres to residential use should benefit from PDR? Please explain your answer.

There were 874 responses to this question. A breakdown of responses by respondent category is provided in Table 10.

Table 10

Respondent category	Yes	No	Unsure
Individuals	9 (1%)	777 (98%)	3 (0%)
Public bodies: planning authorities and HOPS	1 (4%)	23 (96%)	0 (0%)
Public bodies: other	3 (38%)	4 (50%)	1 (13%)
Land and property development	3 (60%)	1 (20%)	1 (20%)
Land and built environment	0 (0%)	3 (43%)	4 (57%)
Music, events and hospitality	1 (3%)	29 (94%)	1 (3%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	1 (14%)	2 (29%)	4 (57%)
Total	18 (2%)	839 (96%)	17 (2%)

The vast majority of respondents answered ‘no’ to this question. Of those, many explained that they opposed such PDR due to the significant risk of noise nuisance complaints from new residents of the converted buildings, threatening the viability of music venues, pubs and clubs in town and city centres. Respondents stated that to protect these cultural institutions, all proposed changes of use to living accommodation in town and city centres should require a full planning application with adequate noise mitigation and be subject to appropriate consultation with venues and the public.

A very small percentage of respondents answered ‘yes’ to this question, supporting the prospect of PDR for the conversion of ground floors or entire buildings in town and city centres to residential use. Various reasons were given by the respondents. These included that such PDR would be a positive response to changing retail patterns, vacant properties and the housing emergency. It was also highlighted that conversions would likely help to improve natural surveillance, support local businesses, and encourage sustainable travel by locating residents close to services, jobs and public transport. However, some respondents highlighted the importance of controls and safeguards on such PDR and expressed some reservations. For example, in relation to impacts on infrastructure and services, loss of ground floor frontages, and protection of existing businesses (including hospitality and entertainment) from potential noise complaints.

Some of those respondents who answered ‘unsure’ expressed support in principle for such PDR but expressed some concerns about potential impacts on active frontages, the mixture of land uses, retail vitality and existing night-time and cultural uses. Some highlighted a need for location-specific controls, prior approval, application of the Agent of Change principle, and careful consideration of matters such as design, amenity, access, fire safety, parking and flood risk.

Question 11: Do you consider that there should be PDR for the change of use properties above Use Class 1A premises to residential use? Please explain your answer.

There were 872 responses to this question. A breakdown of responses by respondent category is provided in Table 11.

Table 11

Respondent category	Yes	No	Unsure
Individuals	16 (2%)	769 (97%)	4 (1%)
Public bodies: planning authorities and HOPS	5 (21%)	15 (63%)	4 (17%)
Public bodies: other	5 (71%)	1 (14%)	1 (14%)
Land and property development	4 (80%)	0 (0%)	1 (20%)
Land and built environment	3 (50%)	1 (17%)	2 (33%)
Music, events and hospitality	1 (3%)	29 (94%)	1 (3%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	2 (29%)	1 (14%)	4 (57%)
Total	36 (4%)	816 (94%)	20 (2%)

Respondents who answered ‘yes’ generally noted the potential PDR as being a positive measure to bring vacant or underused space back into productive use, address housing shortages, and support town and city centre regeneration, vitality, and local living objectives. Support was often qualified by the need for safeguards: protecting the continued operation and licensing of existing ground-floor businesses (reflecting the agent of change principle), ensuring high-quality and healthy living standards (daylight, ventilation, noise insulation, energy efficiency), providing safe and independent access, and managing impacts such as noise, odour, parking, flood risk, heritage, and conservation considerations. Many favoured a PDR with prior approval to allow local authority oversight of design, amenity, infrastructure capacity, and cumulative impacts, ensuring conversions enhance places while safeguarding businesses, residents and townscape character.

Respondents who were opposed or unsure about introducing PDR for residential use above Use Class 1A premises highlighted a range of uncertainties and risks. Key concerns included potential financial impacts on councils through the loss of developer contributions to support infrastructure; a need to address flood risk; and risk of undermining the viability and future flexibility of ground-floor commercial uses. Several noted that Class 1A premises can change to other uses without planning control, creating uncertainty over how conflicts with residential use above would be managed and whether safeguards could be secured without full planning control. There was also concern about the potential for substandard housing, amenity issues (noise, odour, servicing, waste, parking), enforcement under PDR, and impacts on heritage and conservation areas. Some respondents questioned whether PDR would meaningfully reduce barriers compared to planning permission and suggested that place-based tools such as masterplan consent areas, clearer guidance, and strong prior notification or safeguards should be considered.

Question 12: Do you have any comments about the prospect that the PDR would allow a change of use to residential from any existing use? Please explain your answer.

There were 866 responses to this question. A breakdown of responses by respondent category is provided in Table 12.

Table 12

Respondent category	Yes	No	Unsure
Individuals	55 (7%)	42 (5%)	690 (88%)
Public bodies: planning authorities and HOPS	20 (83%)	4 (17%)	0 (0%)
Public bodies: other	4 (67%)	1 (17%)	1 (17%)
Land and property development	3 (75%)	0 (0%)	1 (25%)
Land and built environment	5 (83%)	0 (0%)	1 (17%)
Music, events and hospitality	7 (23%)	5 (17%)	18 (60%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	2 (33%)	0 (0%)	4 (67%)
Total	96 (11%)	52 (6%)	718 (83%)

A large number of respondents stated that they believe all changes of use to living accommodation in town and city centres should be the subject of a full application for planning permission and be subject to appropriate consultation and publicity.

Some respondents supported allowing conversions to reuse vacant or underused space—especially on upper floors above retail space—but often commented that blanket PDR allowing the conversion of any use to residential would be inappropriate. Some considered planning oversight should be maintained in order to manage noise, amenity, and infrastructure impacts.

Some respondents expressed concern that such PDR could result in reduced commercial activity, harm to nightlife, cultural and hospitality venues, noise and amenity conflicts, licensing issues, and reduced vitality and economic sustainability of town and city centres. Many commented that the “Agent of Change” principle would be difficult to apply through PDR, and that planning applications are essential in order to assess impacts, ensure consultation, protect services, and secure developer contributions.

Question 13: Do you think PDR for the change of use of properties above Use Class 1A premises to residential use should include any limits on the minimum or maximum floorspace, size and/or number of residential units that can be formed? Please explain your answer and describe what you think the limits should be, if any.

There were 858 responses to this question. A breakdown of responses by respondent category is provided in Table 13.

Table 13

Respondent category	Yes	No	Unsure
Individuals	33 (4%)	36 (5%)	714 (91%)
Public bodies: planning authorities and HOPS	11 (46%)	7 (29%)	6 (25%)
Public bodies: other	4 (80%)	0 (0%)	1 (20%)
Land and property development	2 (50%)	1 (25%)	1 (25%)
Land and built environment	5 (83%)	0 (0%)	1 (17%)
Music, events and hospitality	2 (7%)	3 (11%)	23 (82%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	2 (40%)	0 (0%)	3 (60%)
Total	59 (7%)	47 (5%)	752 (88%)

Many respondents reiterated their opposition to such PDR in principle. However, of those who commented specifically on the appropriateness or otherwise of limits to the PDR, respondents gave a range of views and suggestions. Some noted that any such PDR should include clear minimum space and amenity standards, and in many cases caps on the number and scale of units. Minimum floorspace requirements were seen by some as important to prevent substandard or overcrowded accommodation and to protect health, wellbeing, fire safety, daylight, and overall living quality. Some respondents suggested maximum limits on unit numbers or total scale to avoid overdevelopment, excessive density, and unmitigated pressure on infrastructure, services, and shared facilities, while safeguarding the operation of ground-floor businesses. Overall, many regarded limits as being necessary to balance housing delivery with quality, safety, and place-based considerations.

Other respondents expressed views that conversions are too complex and context-specific to be suitable as permitted development, and that they should instead be assessed through planning applications, to allow for proper scrutiny, public consultation, developer contributions, and protection of town centre vitality. Key concerns included risks to existing businesses (particularly noise-sensitive uses), fire safety and access, loss of planning control, pressure on infrastructure and services, and unintended harm to the viability and regeneration of town centres, contrary to NPF4’s Town Centre First policy.

Question 14: What other potential limits, restrictions and exclusions to such PDR should be considered?

Many respondents reiterated their strong opposition to any PDR allowing change of use to residential accommodation in town and city centres.

A variety of limits, restrictions and exclusions were suggested by respondents. These included: limits to the number of conversions within a single street or block; exclusions in areas at risk of flooding or in major hazard consultation zones; restrictions in conservation areas and listed buildings; and an ability to consider access and parking provision.

Some respondents highlighted a need, if PDR was to be introduced, for limits and exclusions, including to provide protection for existing pubs, clubs, and music venues through exclusion zones established through consultation with affected venues.

Question 15: Do you consider that a prior notification and approval mechanism should be required in respect of a PDR for ‘town centre living’ as discussed in the consultation? If yes, what matters do you consider should potentially be subject to prior approval? Please explain your answer.

There were 857 responses to this question. A breakdown of responses by respondent category is provided in Table 15.

Table 15

Respondent category	Yes	No	Unsure
Individuals	32 (4%)	25 (3%)	718 (93%)
Public bodies: planning authorities and HOPS	1 (4%)	21 (88%)	2 (8%)
Public bodies: other	5 (71%)	0 (0%)	2 (29%)
Land and property development	4 (80%)	0 (0%)	1 (20%)
Land and built environment	3 (43%)	2 (29%)	2 (29%)
Music, events and hospitality	10 (33%)	3 (10%)	17 (57%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	4 (67%)	0 (0%)	2 (33%)
Total	59 (7%)	51 (6%)	747 (87%)

Many respondents reiterated their strong opposition to any PDR allowing change of use to residential accommodation in town and city centres.

Those who opposed the use of a prior notification and approval mechanism gave various reasons for this. Some considered the mechanism was insufficient to ensure various matters are addressed including the protection of existing pubs, clubs and music venues. Some regarded the mechanism as being cumbersome, complicated and inefficient and no simpler or quicker than the planning application process.

Some respondents highlighted that the prior approval mechanism for similar PDR in England has failed to prevent poor-quality and noise-sensitive residential development, and places additional strain on planning authorities. While a small number of respondents supported prior approval as a safeguard, others considered that full planning permission should be required, including to enable assessment of issues such as noise, flood risk, access, infrastructure, heritage, agent of change matters, and cumulative effects.

Some respondents suggested that a prior notification and approval mechanism would be appropriate in relation to a PDR for ‘town centre living’. Others suggested that a single-stage mechanism of prior approval only, would be more appropriate. Amongst the matters suggested to be covered in such a mechanism were: noise and amenity impacts, access arrangements, impacts on transport and parking, impacts on town centre vitality, provision of natural light and ventilation, impact on infrastructure and accessibility and inclusive design.

Question 16: Should any such PDR (permitting the change of use of floors above Use Class 1A premises) also permit certain external alterations of a building to facilitate the conversion to residential use, if so what alterations? Please explain your answer.

There were 858 responses to this question. A breakdown of responses by respondent category is provided in Table 16.

Table 16

Respondent category	Yes	No	Unsure
Individuals	16 (2%)	737 (94%)	28 (4%)
Public bodies: planning authorities and HOPS	6 (25%)	17 (71%)	1 (4%)
Public bodies: other	2 (40%)	1 (20%)	2 (40%)
Land and property development	2 (50%)	1 (25%)	1 (25%)
Land and built environment	2 (40%)	1 (20%)	2 (40%)
Music, events and hospitality	0 (0%)	24 (83%)	5 (17%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	2 (29%)	0 (0%)	5 (71%)
Total	30 (3%)	781 (91%)	47 (5%)

A large number of respondents stated that any PDR for change of use to residential use in town and city centres should not also permit external alterations. This was primarily on the basis that changes such as the installation of windows and doors create an increased risk of noise nuisance complaints. Respondents stated that external alterations should require full planning permission with adequate noise mitigation and planning conditions.

A variety of other points were raised by respondents opposed to allowing external changes as part of any ‘town centre living’ PDR. These included that new windows could create harmful overlooking/loss of privacy and other impacts on neighbouring properties. In addition, that unrestricted alterations could adversely affect conservation areas, listed buildings, traditional shopfronts and facades and the character of the area.

Other points raised included the need to properly consider and address flood risk, access, refuse and cycle storage, and impacts on historic fabric, conservation areas, and World Heritage Sites.

A small percentage of respondents considered that external alterations should be permitted under the PDR. Suggestions for external alterations to be permitted included: windows and balconies; minor changes to windows and roofs; alterations required for safety (e.g. external fire escapes); accessibility features; external insulation and micro-renewables; shutters. Some respondents considered that some of those changes should be subject to restrictions and potentially a prior approval mechanism.

Question 17: Please provide any other comments regarding the potential options to introduce PDR for ‘town centre living’ proposals as discussed in the consultation.

Many respondents stated that in England, PDR have resulted in unsuitable residential conversions next to music venues, pubs and clubs, leading to poor quality housing, and complaints about those venues, resulting in closures. Those respondents argued that Scotland should learn from this by not introducing PDR for changes of use to residential use in town and city centres.

One respondent identified a range of non-planning barriers that they consider limit the feasibility to reactivate upper floor spaces. These include finance and investment barriers, mortgage regulation and ownership constraints, lack of visibility and ownership clarity of upper floors.

Another respondent highlighted that planning policy is generally supportive of the principle of conversion of upper floors in town centres to residential, but that a planning application is the only appropriate way to fully assess matters such as amenity, design, infrastructure and agent of change effects. The respondent also highlighted that any PDR for the creation of new homes would make monitoring more difficult, with consequences for development planning. Others raised concerns about cumulative impacts on businesses, services and infrastructure.

Some respondents expressed doubt that such PDR would make a meaningful difference in terms of streamlining or encouraging the delivery of new homes. It was also suggested that the role of masterplan consent areas in delivering place-specific residential areas should be explored further.

Other Considerations and Options

Question 18: Do you consider that any expanded PDR for rural homes (described in chapter 2) should be subject to a condition prohibiting the use of the new units for short-term letting? Please explain your answer.

There were 293 responses to this question. A breakdown of responses by respondent category is provided in Table 18.

Table 18

Respondent category	Yes	No	Unsure
Individuals	89 (38%)	21 (9%)	126 (53%)
Public bodies: planning authorities and HOPS	14 (58%)	7 (29%)	3 (13%)
Public bodies: other	2 (33%)	1 (17%)	3 (50%)
Land and property development	2 (40%)	2 (40%)	1 (20%)
Land and built environment	4 (67%)	0 (0%)	2 (33%)
Music, events and hospitality	4 (44%)	2 (22%)	3 (33%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	2 (50%)	0 (0%)	2 (50%)
Total	117 (40%)	33 (11%)	143 (49%)

Respondents who supported a condition noted that PDR should deliver permanent housing for local residents, families, and rural workers. Short-term lets were seen by some as reducing housing availability, inflating prices, undermining community cohesion, and placing additional pressure on services. Some considered a condition was important in order to align PDR with objectives for the provision of affordable and long-term housing.

Respondents opposing the use of a condition gave various reasons. Some highlighted that short-term lets can support rural diversification, tourism, and the reuse of vacant buildings. It was also highlighted that a condition would likely have resource implications for planning authorities, in terms of potential monitoring and/or enforcement. Many suggested that short-term lets would better be controlled through other means, including short-term let control areas, or a separate use class rather than a universal restriction.

For those unsure, views were mixed. Points raised included that short-term lets may benefit rural economies and building reuse, but enforcement challenges exist, and restrictions could be more appropriately applied locally rather than universally.

Question 19: Do you consider that any ‘town centre living’ PDR (described in chapter 3) should be subject to a condition prohibiting the use of the new units for short-term letting? Please explain your answer.

There were 289 responses to this question. A breakdown of responses by respondent category is provided in Table 19.

Table 19

Respondent category	Yes	No	Unsure
Individuals	99 (42%)	19 (8%)	117 (50%)
Public bodies: planning authorities and HOPS	13 (54%)	8 (33%)	3 (13%)
Public bodies: other	2 (40%)	1 (20%)	2 (40%)
Land and property development	1 (25%)	2 (50%)	1 (25%)
Land and built environment	3 (60%)	0 (0%)	2 (40%)
Music, events and hospitality	3 (33%)	3 (33%)	3 (33%)
Energy, renewables and utilities	0 (0%)	0 (0%)	3 (100%)
Other	2 (50%)	1 (25%)	1 (25%)
Total	123 (42%)	34 (12%)	132 (46%)

Supporters of such a condition argued that short-term lets affect permanent housing supply, worsen affordability, and harm community cohesion, safety, and town centre vitality, undermining housing and placemaking goals. Opponents generally considered that a blanket ban would be disproportionate and hard to enforce, stressing the role of short-term lets in supporting regeneration, tourism, and local economies, and favouring flexible local management instead. Those undecided called for a balanced, case-by-case approach that considers local conditions, enforcement practicality, and the need to weigh housing pressures against economic benefits.

Question 20: Do you consider that it would be appropriate to amend PDR for existing dwellinghouses, to allow homeowners to make better use of their existing properties? Please explain your answer.

There were 291 responses to this question. A breakdown of responses by respondent category is provided in Table 20.

Table 20

Respondent category	Yes	No	Unsure
Individuals	57 (25%)	32 (14%)	143 (62%)
Public bodies: planning authorities and HOPS	7 (29%)	9 (38%)	8 (33%)
Public bodies: other	2 (25%)	4 (50%)	2 (25%)
Land and property development	2 (50%)	1 (25%)	1 (25%)
Land and built environment	2 (33%)	1 (17%)	3 (50%)
Music, events and hospitality	0 (0%)	4 (44%)	5 (56%)
Energy, renewables and utilities	1 (33%)	0 (0%)	2 (67%)
Other	0 (0%)	2 (40%)	3 (60%)
Total	71 (24%)	53 (18%)	167 (57%)

Those in favour of amending PDR for existing dwellinghouses gave a variety of reasons, including expansion of the PDR being a beneficial way to help homeowners adapt and improve homes, including for energy efficiency and adaptation to meet changing needs. Some respondents suggested specific ways they considered the PDR should be expanded or amended, and potential safeguards.

Those opposed to amending the PDR generally considered that the existing PDR was sufficient and strikes the right balance between flexibility and control; further relaxation was unnecessary and could result in overdevelopment and other negative impacts.

Most respondents were unsure, acknowledging potential benefits of amendments but expressing concern about unintended impacts, lack of clarity, and the need for clear limits, safeguards, and further consultation.

Question 21: Do you consider that the reference in the PDR for domestic air source heat pumps (ASHPs) should be revised to make it clear that the installation must comply with Microgeneration Certification Scheme (MCS) 020 a)? Please explain your answer.

There were 296 responses to this question. A breakdown of responses by respondent category is provided in Table 21.

Table 21

Respondent category	Yes	No	Unsure
Individuals	72 (32%)	16 (7%)	140 (61%)
Public bodies: planning authorities and HOPS	16 (67%)	1 (4%)	7 (29%)
Public bodies: other	3 (60%)	0 (0%)	2 (40%)
Land and property development	3 (50%)	1 (17%)	2 (33%)
Land and built environment	6 (100%)	0 (0%)	0 (0%)
Music, events and hospitality	2 (20%)	2 (20%)	6 (60%)
Energy, renewables and utilities	11 (92%)	1 (8%)	0 (0%)
Other	4 (80%)	0 (0%)	1 (20%)
Total	117 (40%)	21 (7%)	158 (53%)

Those who supported the revised MCS standard, commented that it would improve clarity, consistency and management of noise issues. Some favoured aligning with England and removing the term “or equivalent” to avoid uncertainty or ambiguity.

Respondents opposed to revising the reference raised a variety of concerns, including in relation to the noise and effectiveness of air source heat pumps. Some expressed concern that compliance with the revised MCS standard might not fully address cumulative impacts or enforcement challenges. Some respondents highlighted that planning authorities lack the tools and expertise to verify noise calculations and that responsibility for compliance is unclear, particularly where installations later fail to meet standards. Several felt that stronger acoustic measures, clearer national guidance and tighter controls – rather than expanded PDR – would be needed to protect residential amenity.

A small number of respondents expressed concern about the removal of the wording “or equivalent” from the condition which currently requires ASHP installed under the PDR to comply with the MCS Planning Standards or equivalent. They highlighted that equivalence allows relevant other standards to be used as appropriate and might limit futureproofing.

Some respondents expressed reservations about the practical implications of requiring compliance with the updated MCS standard. They noted that consistent application, monitoring, and enforcement would be important and questioned whether existing processes were robust enough.

Other respondents expressed concern about the impacts and effectiveness of air source heat pumps generally, rather than commenting on the reference to a MCS standard.

Question 22: Do you consider that ASHPs installed on domestic properties under PDR should be permitted to be used for heating and cooling but not solely cooling? Please explain your answer.

There were 294 responses to this question. A breakdown of responses by respondent category is provided in Table 22.

Table 22

Respondent category	Yes	No	Unsure
Individuals	57 (25%)	19 (8%)	151 (67%)
Public bodies: planning authorities and HOPS	12 (50%)	4 (17%)	8 (33%)
Public bodies: other	3 (75%)	0 (0%)	1 (25%)
Land and property development	4 (67%)	0 (0%)	2 (33%)
Land and built environment	4 (67%)	0 (0%)	2 (33%)
Music, events and hospitality	3 (30%)	2 (20%)	5 (50%)
Energy, renewables and utilities	9 (75%)	3 (25%)	0 (0%)
Other	2 (40%)	1 (20%)	2 (40%)
Total	94 (32%)	29 (10%)	171 (58%)

Those answering ‘yes’ gave several reasons, including that cooling would be increasingly necessary because of climate change and more frequent heatwaves. Increased consumer choice; the dual heating and cooling function of many existing heat pump models (particularly air-to-air pumps); and benefits for decarbonisation were also commonly mentioned as reasons for answering yes. A number of respondents considered it would be beneficial to align with the changes made to the equivalent PDR in England.

Many respondents agreed that PDR should not allow the installation of ASHPs solely to be used for cooling, including because these were seen as less energy efficient. On the other hand, some considered that the PDR should permit ASHPs to be used only for cooling. Reasons primarily related to increased consumer choice; because a different method of heating may be more appropriate or feasible; and because the appearance and noise of ASHPs were the main factors relevant to planning, rather than the temperature output of those ASHPs. A few respondents highlighted potential difficulties in monitoring and enforcing any requirement that the ASHPs should not be used solely for cooling.

Some respondents who answered ‘no’ expressed concerns about the efficiency, effectiveness and noise impacts of air source heat pumps generally.

Some respondents noted that it would be important to provide guidance to householders about alternative options for cooling including ‘passive cooling’.

Question 23: Do you consider that the PDR for domestic ASHPs in Scotland should be amended to allow for the installation of up to two ASHPs on a detached dwellinghouse? Please explain your answer.

There were 291 responses to this question. A breakdown of responses by respondent category is provided in Table 23.

Table 23

Respondent category	Yes	No	Unsure
Individuals	60 (27%)	18 (8%)	146 (65%)
Public bodies: planning authorities and HOPS	16 (67%)	0 (0%)	8 (33%)
Public bodies: other	5 (83%)	0 (0%)	1 (17%)
Land and property development	4 (80%)	0 (0%)	1 (20%)
Land and built environment	4 (67%)	0 (0%)	2 (33%)
Music, events and hospitality	3 (30%)	2 (20%)	5 (50%)
Energy, renewables and utilities	10 (91%)	0 (0%)	1 (9%)
Other	3 (60%)	0 (0%)	2 (40%)
Total	105 (36%)	20 (7%)	166 (57%)

Those in support of allowing the installation of two ASHPs on detached houses frequently noted that this would increase flexibility, efficiency and consumer choice, especially for larger, older or rural/island properties. Another common reason given for supporting this amendment was because it would better align with the equivalent PDR in England, resulting in greater clarity for the sector. Many noted that noise remains the key concern and that safeguards would be essential to protect neighbouring amenity.

A number of respondents considered there should be no upper limit on the number of ASHPs permitted on detached houses, provided that the MCS standard was complied with and noise impacts were mitigated. Some respondents considered that a minimum separation distance should be set.

Some respondents considered that the current limit (of one ASHP per detached house) should be retained, either entirely or in the cases of conservation areas and listed buildings. Some concerns were raised about visual impacts, and it was suggested that the increased limit of two ASHPs per detached house should only apply to the rear of detached houses.

Amongst the reasons given by those who answered ‘no’ were that heat pumps are noisy, disruptive to neighbours and expensive to run; that the current noise standard is not appropriate and does not account for frequency impact, and that noise rating curves would be more appropriate.

Question 24: Do you consider that proposals that would result in more than one ASHP being installed on flatted buildings or on terraced or semi-detached properties should continue to be assessed on a case-by-case basis by planning authorities? Please explain your answer.

There were 291 responses to this question. A breakdown of responses by respondent category is provided in Table 24.

Table 24

Respondent category	Yes	No	Unsure
Individuals	73 (32%)	21 (9%)	133 (59%)
Public bodies: planning authorities and HOPS	20 (87%)	1 (4%)	2 (9%)
Public bodies: other	1 (25%)	0 (0%)	3 (75%)
Land and property development	3 (60%)	1 (20%)	1 (20%)
Land and built environment	3 (50%)	0 (0%)	3 (50%)
Music, events and hospitality	4 (40%)	1 (10%)	5 (50%)
Energy, renewables and utilities	7 (64%)	3 (27%)	1 (9%)
Other	2 (40%)	1 (20%)	2 (40%)
Total	113 (39%)	28 (10%)	150 (52%)

Reasons for answering ‘yes’ included that a case-by-case approach allows planning authorities to assess site-specific factors such as distance from, and impacts on, neighbours, and mitigation measures. It was noted that case-by-case assessment is particularly important in higher density settings where properties are closer together and where cumulative noise and visual impacts might be greater. Concerns regarding potential impacts of ASHPs on conservation areas, listed buildings and neighbouring residents and businesses were raised. It was also argued that individual heat pumps are likely to be a poor solution for flats compared to a single heat network.

Some respondents agreed that there was insufficient information at present to be able to design appropriate PDR allowing more than one ASHP on flatted buildings or terraced/semi-detached properties. Some considered it was important to undertake further research on this matter and address these information gaps as a priority.

Some respondents considered that it would be appropriate to amend the PDR to allow multiple ASHPs on a block of flats or semi-detached/four-in-a-block houses, or allowing ASHPs on a per-dwelling basis rather than a per-building basis. Some considered the current position, where planning applications are usually necessary, poses a significant barrier to decarbonisation and is based on unsubstantiated concerns about noise.

It was suggested that incorporating into the PDR a maximum permissible noise level in relation to property size or location could be explored.

Question 25: Do you consider that any other changes should be made to the existing PDR for the installation of ASHPs in Scotland? Please explain your answer.

There were 283 responses to this question. A breakdown of responses by respondent category is provided in Table 25.

Table 25

Respondent category	Yes	No	Unsure
Individuals	11 (5%)	32 (14%)	179 (81%)
Public bodies: planning authorities	1 (4%)	16 (67%)	7 (29%)
Public bodies: other	2 (67%)	0 (0%)	1 (33%)
Land and property development	1 (25%)	2 (50%)	1 (25%)
Land and built environment	2 (40%)	1 (20%)	2 (40%)
Music, events and hospitality	2 (20%)	3 (30%)	5 (50%)
Energy, renewables and utilities	10 (91%)	1 (9%)	0 (0%)
Other	1 (25%)	1 (25%)	2 (50%)
Total	30 (11%)	56 (20%)	197 (70%)

The significant majority of respondents did not consider that any other changes should be made to the PDR at this stage, or were unsure. Some respondents considered that the options set out in the previous questions would strike an appropriate balance, and that further changes could have unintended consequences. Many respondents commented that they did not have enough information or expertise to provide a view.

Some respondents commented it would be appropriate to keep PDR under review, given the evolving nature of heat pump technologies and increasing understanding of the impacts.

The minority who answered yes generally considered that the PDR should be further expanded, with reasons given including to reduce barriers to the adoption of low-carbon heating technologies. Suggested changes included allowing installations anywhere within the curtilage; raising or removing the size limit; permitting more than two units where noise limits are not exceeded; and enabling upper-floor flats to install ASHPs at higher rear elevations. Some respondents emphasised the importance of clear, accessible guidance and training in relation to the PDR. Some responses repeated earlier comments that the standards relating to noise should be revised.

Question 26: Do you consider that it would be appropriate to have PDR for the installation (and subsequent repair and maintenance) of connections from individual buildings to heat networks? Please explain your answer.

There were 288 responses to this question. A breakdown of responses by respondent category is provided in Table 26.

Table 26

Respondent category	Yes	No	Unsure
Individuals	47 (21%)	19 (9%)	157 (70%)
Public bodies: planning authorities	18 (78%)	2 (9%)	3 (13%)
Public bodies: other	4 (67%)	0 (0%)	2 (33%)
Land and property development	4 (80%)	0 (0%)	1 (20%)
Land and built environment	3 (50%)	0 (0%)	3 (50%)
Music, events and hospitality	2 (22%)	2 (22%)	5 (56%)
Energy, renewables and utilities	9 (82%)	0 (0%)	2 (18%)
Other	2 (40%)	0 (0%)	3 (60%)
Total	89 (31%)	23 (8%)	176 (61%)

Many of the comments in support highlighted that such PDR would reduce costs and incentivise and accelerate the rollout of low-carbon heat provision, particularly for flats, tenements, and rural areas. Respondents generally considered that underground installation results in minimal visual and environmental impact, but noted the importance of requiring reinstatement of ground surfaces and recommended safeguards for sensitive heritage sites and other sensitive locations. Some noted the PDR would be comparable to those that already apply to various utility providers.

Some suggested that the PDR should also cover the drilling of boreholes and the installation of above ground connections and shared heat collectors as well as underground pipework.

The respondents who answered ‘no’, generally considered that heat network connections should be the subject of planning applications, including to allow assessment and management of impacts, the protection of heritage, and the collection of data on such connections. It was also noted that the pipe networks might be complex involving many properties and users, and impacts on historic environments and habitats would need to be understood.

Several respondents highlighted gaps in knowledge about roles, responsibilities, enforcement mechanisms, and how PDR might apply alongside other renewable energy technologies like solar panels or air source heat pumps (ASHPs).

Top of Form

Assessments

Question 27: What are your views on the accuracy and scope of the environmental baseline set out in the environmental report?

There were 288 responses to this question.

A large number of respondents commented that the environmental baseline does not take proper account of current and future pressures facing existing live music venues, nor does it take proper account of the current and future baseline for music venues in towns and centres. Some considered the role of town centre cultural and entertainment venues should be more explicitly recognised.

Other respondents indicated that they were content with the accuracy and scope of the environmental baseline.

Question 28: What are your views on the predicted environmental effects of the proposal as set out in the environmental report? Please give details of any additional relevant sources.

A large number of respondents stated that they believe the report fails to predict the likely impact of the proposals on cultural institutions such as live music venues, including the risk of closure due to noise nuisance complaints.

Some respondents considered potential negative impacts on the environment and on human health had not been explored enough. Some considered that the report underplayed potential impacts including on private car use, biodiversity, carbon emissions and infrastructure.

Historic Environment Scotland provided detailed comments in relation to potential effects of the various options on the historic environment, and suggested additional mitigation measures for some of the proposals.

NatureScot generally agreed with the assessment findings, but made some comments on the detail, and suggested that various protected areas should be excluded from extended permitted development rights for new rural homes. NatureScot also considered that the role of all classes of permitted development, in delivering NPF4 Policy 3 is not clear, and recommended that associated mitigation should be informed by its Developing with Nature guidance.

Question 29: What are your views on the assessment of alternatives as set out in the environmental report?

Responses to Question 29 on the assessment of alternatives in the environmental report were limited. Some respondents generally supported or agreed with the assessment of alternatives set out in the report.

Many respondents did not agree with the statement in the environmental report that the ‘town centre living’ PDR options would likely lead to increased footfall in town and city centres, supporting local businesses. They argued that the PDR options would conflict with the agent of change principle.

Some respondents suggested there should be more detailed analysis of socio-cultural and economic impacts, especially on urban cultural venues. Some emphasised the need for safeguards such as prior approval mechanisms, application of the agent of change principle, and stronger support for permanent rural housing to sustain communities.

It was suggested by some that the analysis in the report was overly pessimistic, or overstated potential environmental effects, especially when compared with potential benefits of options.

Some respondents questioned the robustness and impartiality of the assessment and evidence used.

Question 30: What are your views on the proposals for mitigation, enhancement and monitoring of the environmental effects set out in the environmental report?

Some respondents indicated that they were content with the mitigation, enhancement and monitoring proposals, whereas others suggested that the proposals were not sufficient.

Specific concerns included that the impacts of PDR on historic building fabric; ‘placemaking’; nearby land uses; flood risk and biodiversity were not sufficiently considered or mitigated.

It was suggested that rural homes permitted by PDR should be occupied as long-term residences rather than short-term lets. In addition, that clear guidance should be provided including in relation to prior notification/approval mechanism; design, landscape and cultural heritage.

The importance of ongoing monitoring of PDR impacts was emphasised, particularly in relation to cumulative effects and impacts on cultural venues. Some suggested that monitoring should cover not only the number of homes delivered but also quality outcomes (e.g. energy use, amenity, place vitality, resident satisfaction, and community impact). It was suggested that monitoring should be undertaken by an independent academic body and informed by baseline data, and that PDR changes should be piloted in a small number of authorities.

A large proportion of respondents did not respond to this question.

Question 31: Please provide any comments on the partial Business and Regulatory Impact Assessment (BRIA) and information on the potential business or regulatory impacts of any of the options identified in this consultation.

Some respondents considered the partial BRIA was appropriate and proportionate, but others considered it overly simplistic and optimistic.

Many respondents stated that they considered the partial BRIA failed to accurately assess the likely impact of the PDR proposals on cultural institutions such as live music venues, including the risk of closure due to noise nuisance complaints. They challenged assumptions that increased residential use in town and city centres would necessarily increase footfall and support existing businesses. Some commented that the partial BRIA underestimated the economic importance of the live music and wider cultural sectors.

Questions were raised about the assumed cost and efficiency savings for planning authorities, citing increased administrative impacts (including in relation to prior notification and approval); demands on infrastructure and risks to design quality.

Question 32: Are you aware of any examples of how any of the options identified in this consultation may affect, either positively or negatively, those with protected characteristics? If yes, please provide further detail.

Most respondents were unsure or provided no comment.

Some noted that expanded or new PDR could improve access to housing which may benefit people with certain protected characteristics. Positive benefits for individuals with low incomes or health vulnerabilities were also noted in relation to PDR for ASHPs and heat networks.

Concern was raised that PDR potentially removes the ability to highlight and consider matters including equalities impacts which might otherwise have been highlighted in representations.

A respondent noted that if PDR changes exclude consideration of culturally appropriate accommodation for the Gypsy/Traveller community, this could be seen as not advancing equality of opportunity.

It was suggested that PDR changes could exacerbate risks facing music, cultural and LGBT venues, which often provide spaces for people with protected characteristics.

Comment was also made that low quality housing, permitted through poorly controlled PDR, could disproportionately affect people in vulnerable groups (e.g. disabled or older residents needing accessible homes).

Question 33: Please provide any comments or information on the potential impacts on children’s rights and wellbeing of any of the options identified in this consultation.

Few respondents provided detailed comments. Some commented that expanded PDR would benefit children and young people through improving availability of family homes accessible to schools, services and community facilities. Some noted the importance of ensuring that new homes are of high quality and in suitable locations. It was noted that ASHPs and heat networks could enhance living conditions and reduce fuel poverty.

Concerns raised included: PDR would remove involvement of interested parties in decision-making; might result in noise impacts near entertainment venues; and short-term letting undermining community stability. It was also noted that new homes permitted under PDR might be of low quality or not be connected to adequate amenity spaces, playparks, path networks or well-lit places.

Some respondents highlighted the importance of planning safeguards and mitigation measures including prior approval, to ensure children’s living environments and opportunities are not compromised.

Question 34: Do you have any information or comments on the potential impacts of island communities of any of the options identified in this consultation? If yes, please provide further detail.

Most respondents had no comment or relevant information on potential impacts on island communities. A few highlighted that expanded PDR could encourage the provision of homes, help support repopulation and sustainability on islands and help address viability challenges. Concern was expressed that unrestricted PDR could result in unsustainable development; negative effects on local services and community cohesion; and increase pressures associated with second homes and short-term lets.

Recommendations included the use of a prior notification/approval mechanism, scale limits, restrictions on short-term letting and occupancy safeguards to protect island infrastructure and promote sustainable development. It was also suggested that PDRs should operate in line with local plans and design codes, particularly in island communities where there are specific issues such as ferries/logistics for materials, limited services, and distinct heritage/townscapes.

Question 35: Are you aware of any examples of potential impacts, either positive or negative, that the options identified in this consultation may have on groups or areas at socio-economic disadvantage (such as income, low wealth or area deprivation)? If yes, please provide further detail.

Most respondents had no comment or were unaware of relevant examples, though some highlighted socio-economic impacts. It was noted that expanded PDR for new homes could increase the availability and affordability of housing and support repopulation, access to services, and energy efficiency benefits for lower-income households. Potential negative impacts identified included a risk of poor quality homes; impacts on cultural venues and associated employment; and pressures on services. Safeguards such as prior approval mechanisms were recommended by some to promote inclusive outcomes.

Question 36: Do you agree that a Fairer Scotland Duty assessment is not required in relation to the options set out in this consultation?

There were 199 responses to this question. A breakdown of responses by respondent category is provided in Table 36.

Table 36

Respondent category	Yes	No	Unsure
Individuals	14 (8%)	29 (17%)	124 (74%)
Public bodies: planning authorities and HOPS	7 (41%)	0 (0%)	10 (59%)
Public bodies: other	1 (33%)	2 (67%)	0 (0%)
Land and property development	1 (100%)	0 (0%)	0 (0%)
Land and built environment	1 (50%)	1 (50%)	0 (0%)
Music, events and hospitality	1 (14%)	2 (29%)	4 (57%)
Energy, renewables and utilities	0 (0%)	0 (0%)	1 (100%)
Other	0 (0%)	1 (100%)	0 (0%)
Total	25 (12%)	35 (18%)	139 (70%)

Only a small proportion of respondents expressed a clear view in response to this question.

Those disagreeing that an assessment was not required gave several reasons, including a potential for disproportionate impacts on disadvantaged communities and exacerbating inequalities, and to ensure that potential impacts were fully considered. Some considered that making amendments to PDR would be a strategic decision.

Some indicated that such an assessment was necessary only for PDR for new homes and not for the potential changes to PDR for air source heat pumps and heat network connections.

Those agreeing that an assessment was not required generally did not provide reasons.