Planning - 2025 progress update: Ministerial and Chief Planner letter - April 2025

Dear colleagues

We have had a busy few months, and expect planning to continue to be in the spotlight over the remainder of the year, given its critical role in supporting the economy. In particular, we have been focused on housing issues, and we are making good progress in delivering the commitments in our Planning and the Housing Emergency Delivery Plan. This progress update covers this and our wider work programme, setting out our actions under the priority themes of policy, delivery, efficiency and capacity.

Policy

The Scottish Parliament’s Local Government, Housing and Planning Committee is undertaking its annual review of National Planning Framework 4 (NPF4) and we are reading with interest responses to the committee’s recent call for views. Our work to support the implementation of NPF4 continues.

We have continued to focus on the implementation in practice of policy 22 flood risk and water management. This has included the Short-Life Working Group comprising members from SEPA, Heads of Planning Scotland (HOPS) and Scottish Government. Over the course of three meetings since November 2024, the Group has worked collaboratively to identify areas of consensus and prepare updates to guidance. The Group’s final meeting was in March and the outputs from this work, including an additional suite of guidance documents, are being finalised by SEPA. We will write to you with this further information once the materials are available.

Improving biodiversity is a cross-cutting theme which runs throughout NPF4. Where relevant and applicable, applicants will want to consider how policy 3b has been addressed. NPF4 does not specify or require a metric to be used, though the policy makes clear best practice assessment methods should be utilised. As we have set out in our draft Biodiversity guidance, the absence of a universally adopted Scottish methodology or tool should not be used to frustrate or delay decision making, and a flexible approach is crucial. NatureScot are working at pace to produce a robust and thorough metric but they acknowledge that this is very complex work and they want to get it right. We anticipate the publication of interim guidance on use of existing biodiversity metrics by NatureScot by summer this year.

NPF4 policy 11 (energy) supports development proposals for all forms of renewable, low-carbon and zero emissions technologies including enabling works, such as grid transmission and distribution infrastructure.  Whilst proposals for much of the large-scale infrastructure required to achieve net zero will be considered by the Scottish Government’s Energy Consents Unit under the Electricity Act, applications for standalone sub-stations are made to planning authorities under the Planning Act. The use of suspensive conditions to secure the submission and implementation of schemes such as compensatory planting and other biodiversity measures can be appropriate. Careful thought should be given to the wording of such conditions to ensure that they are proportionate and do not unduly delay development, whilst still meeting the tests for conditions set out in Circular 4/1998. For example, it is worth considering whether it would be reasonable for a condition to require a scheme to be agreed before the development can come into operation, rather than before any development can commence. The tests governing the use of planning obligations are contained in Circular 3/2012; the Circular underlines that planning obligations should not be used to address issues that can be resolved in another way, such as through a planning condition or the use of an alternative legal agreement.

We are currently finalising our guidance on climate change adaptation and mitigation and expect to publish this shortly. This has taken extra time to enable feedback from the advisory group and other stakeholders to be  taken into account.

Reinforcing the content of previous letters, policies 17 and 29 on rural homes and rural development are supportive policies that encourage sustainable development in rural areas. This positive position is embedded across NPF4, with ‘rural revitalisation’ being one of six spatial principles, spatial strategies identifying a wide range of opportunities across rural areas, and several national developments expected to be located in rural areas. We want to be clear that NPF4 is not intended to reduce flexibility of supportive local rural policies, but that NPF4 and the wider development plan should be read and applied as a whole, and work alongside all relevant policies and considerations to achieve the intention of encouraging, promoting and facilitating delivery of appropriate new homes and economic development. Guidance on local living recognises the importance of diversity and specific local conditions in rural areas, noting needs are likely to differ to more densely populated areas and therefore requiring flexible solutions, such as a network approach, and realistic consideration of accessibility by different modes of transport in the travel hierarchy. 

Delivery

This financial year, we are expanding the services offered by the Planning Hub. The emerging model is working towards a National Planning Hub led by the Scottish Government, delivered in partnership with the Improvement Service and with input from key stakeholders. It builds on the Hydrogen Hub hosted by the Improvement Service and delivered by the National Planning Improvement Champion with a multi-organisational team, and also incorporates the work of the current Housing Hub.  We are currently discussing the proposed model and approach with HOPS, with the intention of it being delivered through a partnership approach with key stakeholders. It will provide both sector specific support, with Housing and Renewable Energy (including On-shore Wind, Hydrogen, Battery Energy Storage) as priorities.  The Hub will offer planning authorities support to bring in capacity and expertise, support for brokerage for strategic stalled sites, building professional skills and capacity, and supporting efficiency and practice.

A short life working group (SLWG) was established to provide advice on our work on stalled housing sites. The Group which comprises the Scottish Government, Homes for Scotland, Scottish Property Federation, Scottish Federation of Housing Associations and Heads of Planning Scotland have been working at pace with the aim of accelerating delivery. 114 stalled housing sites across Scotland have been identified, covering just over 20,000 homes. The SLWG has agreed that in addition to brokerage, strategic actions be progressed for issues that are relevant to a number of sites. These include flexibility of affordable housing provision, flooding, water and drainage, transport (road and rail), market interest/viability, brownfield land, education provision and longer term revenue costs for authorities of more new homes. 

The self-selected sites have been mapped and categorised by progress towards build-out.  We will be providing brokerage support to four authorities, taking care to ensure statutory roles of Ministers and planning authorities are not impacted. On the strategic actions, HOPS are convening a discussion to promote joint working across planning and housing systems at local authority level.  Engagement is ongoing with a range of agencies, including SEPA, Scottish Water, Nature Scot and Transport Scotland and connections have been made to the Housing Investment Taskforce.  Discussions are also taking place with Scottish Futures Trust and the National Planning Improvement Champion. The SLWG continues to convene on a monthly basis, or more frequently as required. Thank you to all planning authorities and agencies for their input to this work.

The Planning, Infrastructure and Place Advisory Group will continue to meet this year, and will turn its focus to informing the preparation of the next Infrastructure Investment Plan in 2026. A work programme will be provided to the group for members’ agreement at the next meeting in May. The work to date is providing useful insights to our efforts to unlock stalled housing sites.

The legal provisions allowing authorities to prepare Masterplan Consent Area schemes came into force on 5 December and we have since published guidance to support their roll out. We have recently been discussing opportunities with several planning authorities to be early adopters of MCAs, to incentivise some development priorities in their areas. Some grant funding is being made available to those who are ready to work with us to drive this important opportunity forward.

It is crucial that the first round of 'new style' local development plans (LDPs) are prepared promptly to support the delivery of NPF4, address the housing emergency and wider priorities including net zero, and to inform decisions on development and investment to meet the needs and aspirations of Scotland’s places and communities.

As a first step in that process, some good progress has been made on a number of Evidence Reports. Reflecting on those completed to date, we would urge authorities to pay particular attention to the provision of a robust and evidence-based indicative Local Housing Land Requirement to back up their ambitious approach to enabling housing delivery (using the MATHLR as the starting point). Similar care and attention is advised in reporting the evidence that will inform an Infrastructure First Approach. A clear and transparent approach at this stage, understood by relevant stakeholders, should save time going forward. It should provide a clear record to assist in responding to representations on the proposed plan and also as an evidence source at development plan examination.

Relevant sections of the Local Development planning guidance provide advice on the Scottish Government’s expectations on these matters.  Gate Check decisions already issued by reporters from the Planning and Environmental Appeals Division should further assist those currently working on Evidence Reports.  Even when an Evidence Report is returned for recommended changes, it should be possible to move quickly to re-submission without substantial delay. The recent, quick turn around on the revised Glasgow Evidence Report illustrates this point. A clear and focussed response from the authority has enabled the appointed reporter to move quickly to issue a positive decision. 

Scottish Ministers have set out that every planning authority in Scotland should have a new-style LDP in place by May 2028. This target provided a five-year period from the new development planning regulations coming into force for authorities to prepare and adopt their new LDPs. To support the achievement of this target, we are closely monitoring timescales for plan preparation and this is raising some concerns about potential slippage in a number of authorities. As a result, we are now requiring all planning authorities to provide information on a six monthly basis on their intended timescales. The information can be very brief to avoid diverting capacity in LDPs teams, but should include action being taken to prevent delay and accelerate the process where adoption dates are expected beyond the May 2028 target.  This may include, for example sharing or accessing additional resource, or taking proportionate and efficient approaches to handling information. The first update should be sent to our Development Plans Mailbox Developmentplans@gov.scot by 30 September 2025.

We will collaborate with the National Planning Improvement Champion to raise the profile of local development plans, encourage proactive steps to accelerate timelines, and assess whether additional measures may be necessary. We are also open to offering support via the Planning Hub over the coming months, where significant challenges are emerging and support is considered by authorities to be a priority.

Efficiency

Following the publication of our Progress Report in December 2024, the compulsory purchase reform programme has continued to move forward and we remain on track to consult on a comprehensive package of proposals this September.

We received a wide range of suggestions in our recent engagement on the potential role of permitted development rights in helping to address the housing emergency. Informed by that valuable feedback, we intend to launch a consultation on options and proposals in the summer.

In November we announced that further work to introduce an infrastructure levy would stop. Since then we have commenced work to update guidance on section 75 planning obligations, which is currently set out in Circular 3/2012. We intend to publish a draft revised planning obligations circular for comment in June, with a view to issuing a finalised version towards the end of 2025.

Providing too much or too little information to accompany planning applications can add costs and delays to determination.  Our Proportionality Short Life Working Group has been focusing on this issue and has published a blog on a number of key principles and best practice.  A further blog on the effective use of pre-application discussions and processing agreements, will be published on our blog page shortly.

We are grateful to Heads of Planning Scotland for taking forward work on a standard set of planning conditions, good practice on Section 75 agreements and aligning consents.  HOPS will disseminate those findings to authorities once finalised.

Capacity

Our Future Planners Programme launched in February and aims to support the long-term resilience of the planning profession.  The programme seeks 18 candidates to join the Scottish Government on a 23 month fixed term contract working within Planning, Architecture and Regeneration Directorate, Energy Consents Unit and Planning and Environmental Appeals Division. Alongside their work, successful candidates will undertake a postgraduate planning degree at either the University of Dundee, the University of Glasgow, or Heriot-Watt University.  We have been overwhelmed by the amount of interest that the programme has generated and the number of students who are now looking at planning as a potential career who may not have otherwise done so. The recruitment process will continue over the coming weeks, with successful candidates starting in post in August. 

In addition to the Future Planners Programme, we are pleased to be offering 30 students on an RTPI-accredited Planning Masters in Scotland for 2025/26 bursaries to assist with course fees and living expense. The number of Future Planners Bursaries have been tripled this year and are part of our package of measures to encourage new talent into the profession.  Further information is available through the RTPI. 

In March we also held another Inspo Day where we invite potential future planners into our office to hear about careers in planning from a range of colleagues.  The next session will take place on 5 June.   

In March we launched our new National Planning Skills Commitment Plan in Govan, along with Scottish Young Planners and Glasgow City Region. The Commitment Plan's schedule will update every month with different themes for training sessions and recruitment opportunities designed to respond to ‘hot topics’. The Plan is underpinned by an organised, industry wide, delivery approach across the built and natural environment. The aim is that through partnership working, we will help develop skills and welcome new talent to the profession. 
We increased planning fees in December to take account of inflation in 2022 and 2023. We are now progressing with phase 2 of changes to planning fees with an inflation linked increase to fees in line with the Consumer Price Index for 2024 of 3.3%. We are also introducing fees for appealing to Local Review Bodies and Scottish Ministers. The proposed changes are intended to come into effect, subject to parliamentary procedure, in June. We expect planning authorities to make use of the increase to planning fees this summer to increase their capacity and skills and to make efficiencies.

The Digital Development Consents programme continues to develop and deliver improvements to the planning application process in Scotland. On 2 April, a new inbound payment service went live in private beta with Loch Lomond and the Trossachs National Park Authority. This has introduced the ability to pay by card, either by the applicant or the client submitting the application on their behalf. Behind the scenes, it has made it easier to request additional payments where the incorrect fee has been paid and introduced a simplified refund process. The new service will extend to two more private beta partners in the coming months, with the public beta roll out to take place from summer 2025.

Multi-year funding is in the final stages of being secured for a new Apply service to replace eDevelopment. External expertise will be commissioned for the build, with a tendering process due to get underway this spring/summer. The service will be delivered in phases, with development scheduled to be begin in autumn 2025. The first version will be live by summer 2026, followed by further iterations thereafter. The programme team has begun engagement with stakeholders and, as the project progresses, will continue to work closely with all partners to shape the service as it develops.

Keeping in touch

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Yours faithfully          

Fiona Simpson
Chief Planner      

Ivan McKee MSP
Minister for Public Finance

Planning - 2025 progress update: Ministerial and Chief Planner letter - April 2025

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