Planning performance and fees: consultation analysis

Analysis of a consultation to obtain the views and opinions of stakeholders on a new approach to how the performance of planning authorities is measured, the role of the National Planning Improvement Co-ordinator (NPIC) and the new structure for the planning fee regime.

3. Planning Performance

3.1 Introduction

3.1.1 The Planning (Scotland) Act 2019 places annual performance reporting by planning authorities on a statutory basis. The Act sets out that Ministers may make further provision about the form and content of performance reports in regulations.

3.1.2 The Planning Performance Framework[1] (PPF) is the Planning Authorities annual report on the planning service providing a range of qualitative and quantified indicators to document planning activities. The PPF provides a good starting point to look at how the performance of the planning system is measured going forward. The consultation sets out the Government's initial proposition for the structure and content of performance reports going forward.

3.2 Purpose of Planning

3.2.1 The Planning (Scotland) Act 2019 states that the purpose of planning is "to manage the development and use of land in the long-term public interest". The Government considers there is merit in developing an accompanying statement about the performance of the system, a vision of a system we all want to see. The consultation proposes the following vision:

"The Planning System must provide certainty, consistency and clarity to all those who participate in it, through effective engagement, policy, decision making and communication".

Q1. Should we set out a vision for the planning service in Scotland?

3.2.2 The table below shows that of the 82 respondents answering the question, there was almost unanimous agreement (96%) that a vision should be set for the planning service in Scotland. The support was provided from all major groups.

Should we set out a vision for the Planning Service in Scotland
Yes No Not Answered
Business 20 9
Civil Society 21 2 5
Development Industry 11 1
Policy and Planning 27 1 12
Total 79 3 27
% of Respondents Answering Question 96 4

Q1a. Do you agree with the vision proposed?

3.2.3 While there was strong support for a vision for the planning system in Scotland, the table below shows that there was very marginal support for the vision proposed in the consultation document. A slight majority (52%) of respondents answering the question supported the proposed vision. Across business and civil society there was a majority of respondents in favour of the vision but, for the development industry and policy and planning groups, a majority of respondents did not agree with the proposed vision.

Do you agree with the vision proposed in this consultation document?
Yes No Not Answered
Business 12 8 9
Civil Society 14 5 9
Development Industry 4 7 1
Policy and Planning 10 17 13
Total 40 37 32
% of Respondents Answering Question 52 48

3.2.4 There were 70 comments relating to the vision across a range of themes:

Aspiration and Outcomes

  • Several respondents from business, development and policy and planning felt that the vision should be more aspirational and reflect the importance of planning in anticipating the development and land uses needed to ensure all parts of Scotland flourish. It should highlight that planning is about managing change and achieving sustainable development, not just making decisions.
  • Several respondents from civil society and policy and planning felt that the proposed vision was more of an outline of how the planning system should operate rather than a vision i.e. it was too focused on the process and not enough focus on the outcomes to which planning contributes.
  • A few comments were made regarding the relationship of the vision to the National Performance Framework (NPerF). One felt it was not clear (civil society), one (policy and planning) felt that the vision should focus planning services towards the delivery of the national outcomes in the National Planning Framework (NPF) and one (policy and planning) felt that clarity was required on the "status" of the vision i.e. how it will link to the NPerF and how those in the planning system will be measured against it.


  • Several respondents from business and civil society raised the issue of the terms "planning system" and "planning service" being used interchangeably in the consultation document and assumed that the consultation was referring to a vision for the planning service to be provided by planning authorities. In contrast, a few policy and planning respondents felt that the reference to "participating" in the planning system broadened the vision to more than just planning authorities and questioned if there would be an obligation on developers.


  • Several respondents from all groups except civil society highlighted the need to introduce a framework of priorities and measurable criteria which are designed to ensure the vision is delivered and measures to be implemented if not delivered.
  • Several business and development respondents identified inconsistency in the way planning authorities operate their service, apply policy and make decisions.
  • A few civil society respondents highlighted that translating the vision into reality will require careful management to ensure the vision is equally perceived across all authorities and to minimize authorities re-interpreting legislation.

Suggested Vision

  • Several business and development respondents suggested "The Planning Service must provide certainty, consistency and clarity to all those who interact with it, through effective engagement, communication, policy and timeous and responsible decision making made in the long-term public interest".
  • Suggestions from civil society included the vision being "accessible" and "transparent" to reflect a service which can be accessed and understood by the general public and the vision expressing how the planning system will help manage the development and use of land for the long term, i.e. the outcomes sought. Examples include appropriate development based on overall planning and economic considerations, creating and conserving valuable buildings, landscapes etc. and involving the public in the planning process.
  • Policy and planning respondents highlighted that the vision should be more aspirational, including how the planning system:
    • adds value to development
    • co-ordinates the provision of infrastructure
    • contributes to local, national, and global outcomes
    • is responsive, flexible and adapts to new challenges
    • encourages participation, collaboration and an integrated approach
    • provides creative solutions to local issues
    • provides leadership and inspires change
    • is effective and appropriately resourced
    • encourages innovation, digital transformation and embraces diversity
    • mediates competing interests
    • builds trust and empowers local communities
    • promotes spatial strategies and a holistic, placemaking approach
    • directs development to the most appropriate locations.

3.3 Preparation and Content of Reports

3.3.1 The consultation proposes that the PPF be refocused to take account of the outcomes in the NPerF, better integrate key performance indicators and take account of customer and stakeholder views. Drawing on the experience of the PPF, the consultation suggested that the performance reports cover the following areas:

  • Statistics: range of published statistics and other quantitative information.
  • Customer Service: should include those who comment on applications, policies and plans to understand how engagement has been handled and how it can be important in building trust and confidence in the planning system.
  • Engagement: how the authority has carried out their engagement activity during the reporting year.
  • Case Studies: which demonstrate how authorities are helping to deliver better development and places and their contribution to national outcomes.
  • Outcomes: key achievements/metrics contributing to the national outcomes.
  • Improvement: areas for improvement that authorities can learn from and share good practice.
  • Resources: how an authority has allocated/used its available resources during the reporting period both financial and staff resources.

Q2. Is the proposed approach to the content correct?

3.3.2 The table below sets out respondents' views on whether the proposed approach to the content of the performance reports is correct. The majority (67%) of respondents agree with the proposed content, particularly from the business, civil society and policy and planning groups. The majority of development industry respondents disagreed with the proposed content.

Is the proposed approach to the content correct?
Yes No Not Answered
Business 9 5 15
Civil Society 12 8 8
Development Industry 2 7 3
Policy and Planning 26 4 10
Total 49 24 36
% of Respondents Answering Question 67 33

Q3. Do you have any comments on the proposed content of Planning Performance Reports (PPR)?

3.3.3 There were 72 comments on the proposed content of the PPRs across a range of themes.

National Performance Framework (NPerF)

  • The appropriateness of the NPerF for measuring outcomes was raised. Several civil society respondents suggested that outcomes should also be monitored against the 2019 Planning Act which was felt to be more specific and up to date. There was concern that specific outcomes set out in the Planning Act will not be delivered if planning authorities are not required to report on these issues and that some of the outcomes in the NPerF are broader and less directly measurable than some of those in the Planning Act. A policy and planning respondent felt that it would be difficult to evidence effective outcomes against all the NPerF measures every year and it would not provide the mechanism to provide a true picture of delivering planning and development regionally.
  • A few policy and planning respondents welcomed the proposals to measure the performance of planning services against the outcomes in the NPerF as they are broader than the statutory outcomes in the National Planning Framework (NPF). It was felt that using the NPerF would align planning well with the purpose, the values and national indicators for Scotland and provide an opportunity for the profile of planning to be raised. One respondent recommended that cross-referencing to the six statutory NPF outcomes is included in the reports.


  • A few policy and planning respondents agreed that quantitative statistics should be retained, but they should be easy to collect and correlate with objectives.
  • A few business and development industry respondents suggested that the statistics to be collected should be set out to ensure consistency and enable comparison across planning authorities.

Customer Service

  • Several business and civil society respondents suggested that planning authorities engage with a range of customers who are likely to have experienced both positive and negative planning decisions to ensure meaningful comments are received. This should include applicants (who receive approval and those whose decisions are refused) and members of the public commenting on planning applications. Standard questions should be used by all planning authorities to ensure consistency between authorities when reporting customers experience.
  • A few respondents (policy and planning, civil society) suggested the inclusion of complaints information as this is already available and it can be used to show improvements in customer experience.
  • A few policy and planning respondents also raised concerns about the measurement of customer service and suggested the focus should be on procedural aspects of customer service e.g. were customers kept informed, were they notified of the outcome.


  • Several respondents (policy and planning, business, civil society) welcomed the inclusion of engagement including feedback from other stakeholders.
  • Caution was noted from a few policy and planning respondents about the resource implications of extensive engagement and the need to balance proportionality and accurate observations. Meaningful stakeholder engagement can be resource intensive and it can be unrepresentative of the of the actual process or customer with those unhappy with any decisions being more inclined to participate. By contrast, a business respondent highlighted that targeted engagement should be open to scrutiny to avoid local authorities targeting stakeholders likely to provide positive feedback.

Case Studies

  • A few civil society respondents suggested the inclusion of case studies would help focus on the quality of the outcomes rather than just having time based targets.
  • A few business respondents felt that there should be a wider range of case studies across different industry categories and there should be examples of where the process has not worked as intended.
  • A few policy and planning respondents felt there should be a range of case studies to provide for a more comprehensive reflection of performance. Case studies would also allow qualitative outcomes to be considered.


  • Several business and development industry respondents highlighted the importance of identifying the extent to which measurable outcomes have been achieved, but also to ensure that ongoing service design and resourcing decisions are better aligned to improving the positive outcomes of planning. Examples of outcomes were provided for renewable energy and house building.
  • A few policy and planning respondents suggested that in relation to national outcomes, guidance will be required. Reference was made to the research being undertaken by the RTPI into Measuring Planning Outcomes which is exploring how local authorities and national Governments can go beyond simple metrics like speed of processing applications. The research aims to propose and test methods for measuring outcomes and will demonstrate how this information can be used to assess local and national performance. One respondent suggested that sharing good practice rather than measuring outcomes would be better.


  • Several business respondents acknowledged that PPF reports often focus on "good news" stories and suggest that whilst it is important to learn from other's successes, the most valuable improvements are likely to arise from scrutinising weaknesses, establishing their cause and methods of avoiding a repeat of poor performance.
  • A few policy and planning respondents felt that improvement areas should be a focus of the reports but acknowledged that these should take account of local authority resources, pressures and strategic direction.


  • Several business and development industry respondents welcomed the proposals to report on resourcing. It was suggested that it should be transparent and show where money is sourced from and where it goes. Measurement of resources will allow authorities to demonstrate how any increases in planning fees have been used to improve the service and provide an understanding as to why authorities may be finding response times challenging.
  • A few policy and planning respondents were concerned over the inclusion of resourcing in the PPF. It was felt that preparing PPF reports is already onerous and increasing their scope and complexity will only exacerbate the situation.
  • A few policy and planning respondents also raised issues around the complexity of identifying resources on specific aspects of planning e.g. the percentage of a flooding officer's time is spent on planning applications. Smaller authorities often have to outsource more costly specialist skills which may make them appear less efficient. The scope of resources should also be extended to include the range of specialisms (e.g. ecologists) involved in the planning system along with investment in training. Aspects of the Planning Act which sees a closer alignment with the community planning function may make it more difficult to separate what planning does from what the local authority does.

Additional Reporting

  • A few policy and planning respondents had concerns about the content of the PPF particularly the reporting process which can be onerous on small teams.
  • Policy and planning respondents also made a number of other comments including:
    • The statistics and resources analysis should be part of an annual performance report and a full performance report should be every two years to ensure meaningful time is dedicated to improvements, customer service and engagement.
    • The move from a purely statistical approach to performance outcome measurements is welcome and helps demonstrate the added value the planning system can achieve.
    • These reports are becoming too long and detailed, both to produce and for stakeholders to engage with.
    • There needs to be greater clarity on the audience(s) for the PPR to better define the style of reporting and the information to include.
    • The PPR could be used to capture the relationship between planning outcomes and the Authority's Strategic Plan.

Q3a. Do you have any comments or suggestions as to how reports should be prepared?

3.3.4 There were 45 comments or suggestions as to how the PPRs should be prepared across the following themes:

  • Several respondents across all major groups suggested the new reporting structure should take account of the experience and roles played by different stakeholder groups. Suggestions of stakeholders included the Key Agencies Group, interest groups (e.g. Homes for Scotland, home builders), applicants who fund development management services and applicants who are relied on to implement plans.
  • Several respondents (civil society, development industry, policy and planning) felt a template approach would create consistency and aid comparison between authorities. This could include a word limit and some flexibility in how the report is presented visually. A few policy and planning authorities felt that the basic structure of the report should be common to all but otherwise there should be scope for variation in content depending on the audience the report is being prepared for.
  • The use of geographical information systems (GIS) and digital reporting was suggested by a few policy and planning respondents to provide data spatially and for it to be more of a "live" document. Reference was made to a tool developed by the RTPI in Wales for presenting the value and performance of planning to the wider local authority area.
  • While a development industry respondent felt that annual reporting should enable authorities to determine whether service improvements are required, one policy and planning respondent suggested a biennial report (it would be less repetitive and aid resource management) and one suggested performance data could be reported annually (often in other authority reports) but a biennial "focus" report could focus on a particular topic.

Q3b. What statistical information would be useful/valuable to include and monitor?

3.3.5 There were 59 comments on what statistical information would be useful/valuable to include and monitor. The following general points were made:

  • Several policy and planning respondents felt that the existing PPF statistics should be used. These statistics are largely drawn from Scottish Government publications and are easily obtainable, measurable, provide a reliable benchmark and can be readily monitored.
  • Resources was identified as a key statistic by business, development industry and policy and planning respondents. Several business and development industry respondents felt that there should be data and statistics on how resources are used on applications, particularly larger applications with added complexity. This would be helpful in understanding where authorities spend their effort and provide a quantitative basis for the planning fee structure. A few policy and planning respondents highlighted the need to collect data on resourcing to allow trends in staffing to be monitored. When analysed beside fee income it will allow an assessment of whether fee income is being reinvested into the planning service.

3.3.6 As expected, a variety of statistics was suggested from all groups, and these are summarised below:

  • Applications:
    • Number of applications meeting statutory or agreed timescales and then seeking to demonstrate evidence of improvement
    • Number of consents becoming delivered development
    • Measurement of turnaround of conditions
    • Number of appeals on decisions and rate of successful appeals, including local review body (LRB) and planning and environmental appeals division (DPEA)
    • Number of recommendations from officials not taken forward by elected members
    • Number of approvals and refusals
    • Number of applications receiving objections from community councils/amenity groups
    • Number of retrospective applications granted
    • Number of repeat applications received
    • Number of decisions made as a departure from the development plan
    • Number of planning consents implemented; planning conditions discharged
    • Number of applications subject to planning processing agreements and those determined within timescale
    • Exchanges between planning authorities and applicant
  • Timescales:
    • Time taken to register and validate applications, determine an application (both local and major) and issue and receive consultation responses
    • Average time between the determination and the issue of decision notice regarding legal agreements
    • Time periods for the response to requests to discharge planning conditions
  • Monitoring data:
    • Statistics relating to appeals and judicial reviews to measure performance against the proposed quality of decision outcome
    • Deadlines relating to agreement of heads of terms for planning obligations and processing agreements
    • Compliance with the delivery of planning conditions/obligations
    • Use of enforcement procedures
  • Plans and Guidance:
    • Age of local and strategic development plans and whether it is on track
    • Number of other plans and Supplementary Guidance prepared and years since review
    • Number of Local Place Plans supported/ incorporated in the Local Development Plan (LDP)
    • Applications and refusals contrary to the LDP
    • How policy is being applied
    • Alignment of priorities between LDP and Local Outcome Improvement Plan (LOIP)
    • 5-year land supply
  • Funding/resources:
    • Number of front-line Development Management staff
    • Funding raised through strategic and forward planning activities
    • Use of resources including specialists employed, training undertaken
    • Average number of applications per officer
    • How resources have been used on applications
  • Environmental:
    • Number of applications overlapping wildlife designated sites
    • Number of buildings on Buildings as Risk register
    • Number of listed buildings demolished
    • Number of applications where bio-diversity net gain was achieved.
    • Number of renewable schemes implemented, and power produced
    • Consumption of natural assets
    • Levels of blue/green infrastructure
    • Level carbon used/offset
  • Historic Environment:
    • Information to monitor outcomes, themes and pressures for the historic environment
    • Information from the Buildings as Risk Register, the Scottish House Conditions Survey, Scheduled Monuments
    • Information from the Place Standard Tool, projects by Scotland's Town Partnership and the Vacant and Derelict Land Task Force
  • Environmental Impact Assessment:
    • Average time for providing Environmental Impact Assessment (EIA) screening and scoping opinions, sector specific if possible
    • Average length of determination time for applications, sector specific if possible, and for EIA and non-EIA.
  • Other:
    • Number of public events/consultations held
    • Amount of developer obligations collected per year
    • External datasets which could review national performance e.g. local financial returns and the Local Government Benchmarking Framework
    • Customer perception/ satisfaction data
    • Monitoring engagement, value added, in relation to national outcomes
    • Quantitative measure of knowledge sharing
    • Number of homes occupied, accessible homes delivered and affordable homes
    • Amount of floorspace delivered from new businesses
    • House price inflation in home ownership and rental markets to monitor the need to stimulate supply

Q3c. What are the key indicators which you think the performance of the system and authorities should be measured against?

3.3.7 There were 57 comments about indicators which should be used to measure the performance of the system and authorities. There is some overlap in responses to this question with the content of PPRs discussed under Q3b (paragraphs 3.3.5 to 3.3.6). The main themes are as follows:


  • Many comments were received from civil society and policy and planning about the need to focus on key performance outcomes rather than indicators. Performance should be measured on outcomes of what the planning system delivers (i.e. quality housing, places and environment) rather than being focused on how long it takes to process an application. Combining statistics with outcomes will provide a more balanced understanding of authority performance.
  • Several business and development industry respondents suggested that the supply of effective housing land in Scotland is lower than it may appear in development plans and housing land audits as these plans do not take account of commercial considerations and whether building homes on the land is a realistic market option. Despite these issues, some authorities judge themselves to be maintaining an effective housing land supply. An outcome focused measure of performance would look at the number of new homes that have been successfully delivered through the planning system. The number of new homes delivered could be judged against the sites in plans and audits to determine how successful authorities have been in identifying sites that can be delivered.

Timely Decision Making

  • Many comments from all major groups related to the need for planning authorities to issue decisions as quickly as possible.
  • A few business and development industry respondents highlighted that planning applicants in Scotland do not benefit from a "planning guarantee" or access to the full range of remedies for extended delays (e.g. the provision for repayment of planning fees after 26 weeks in England). Without a timely decision, the only choice is to appeal against non-determination which can increase the uncertainty over decision making.
  • A few business and development industry respondents also highlighted the significant adverse effect that delays in determining applications can have on a business, particularly on debt-financed smaller developers and on the cash flow of any business. Existing monitoring of decision-time performance is inadequate and un-inclusive. The focus on relative performance from year to year, rather than on whether statutory timescales are being met, places insufficient emphasis or impetus on timely decision making.

Customer Satisfaction

  • Several respondents across all major groups suggested customer satisfaction should be considered as an indicator of performance.
  • A few business and development industry respondents highlighted the importance of this indicator given the increasing reliance on customers paying planning fees to subsidise frontline services. As some authorities already send questionnaires to applicants upon conclusion of the application, it could be standardised and include some questions which rate the process rather than the result. For example, questions on project management, communication, validation and speed of response of consultees.
  • One policy and planning respondent suggested a customer service rating which is similar to that carried out for the building standards verification service key performance outcomes.


  • Several business and development industry respondents suggested that performance could be assessed through the use of a processing agreement to project manage planning decisions from pre-application through to negotiation of developer obligations. This could improve efficiency and transparency from the start to the end of the development management process.
  • Several business and development industry respondents welcomed the provisions in the new Planning Act for the training of elected members. Ways to gauge the impact of member training could be to monitor any reduction in the number of decisions that are taken against officer recommendation or in the number of refusals being overturned on appeal.

3.3.8 Heads of Planning Scotland (HOPS) highlighted that the current PPF has 15 markers which provide a consistent basis to consider performance. HOPS commented on these markers and suggested amendments which can be seen in their published response.

Q3d. Do you have any other comments to make with regards to how the performance of the planning system and authorities is measured and reported?

3.3.9 There were 39 comments on this question. Some comments related to topics already covered above and, where appropriate, have been included under those headings. Other themes raised, in descending order of comments made, are:

  • Several policy and planning respondents highlight "process" aspects of the PPR which could be improved including giving authorities the opportunity to feedback/discuss the Scottish Government's response/'Red, Amber, Green assessment before it is published; faster provision of feedback from Scottish Government to inform subsequent PPF submissions; and draft PPFs should be subject to both public and wider stakeholder comments before submission to Scottish Government with these comments submitted alongside the draft report.
  • The performance of planning authorities can be affected by external stakeholders and their actions. A few policy and planning respondents suggested that the performance of other participants in the planning system should be measured and reported on. This would recognise the need for partnership working across all areas of planning and set out how they will contribute to the vision statement and key objectives of the system.
  • A few business and development industry respondents highlighted that the High-Level Group on Planning Performance does not embrace representatives of key planning applicant groups and planning fee payers e.g. the home building industry. These respondents felt that the group needs more balance if it is to play an effective role in achieving an outcome focused approach to performance and if it is to provide those funding planning services with an appropriate opportunity to discuss their experience, needs and perspectives.
  • A few business respondents highlighted the need for more consistency across authorities in the application of planning policies. Examples included the process for the Approval of Matters Specified in Conditions (AMSC) and the way material variations are applied. Inconsistencies can impact on the ability of developers to forward plan and can add to costs.
  • A few civil society responses noted that sometimes the refusal of an application or no development on a site is the best outcome. This should not be reported or viewed as a failure but the part that planning plays in preventing harmful development which does not benefit the area of development.
  • Other comments included:
    • One size does not fit all - all authorities have different geographies, demographics, property and job markets, political make-up and internal processes which cannot be compared equitably (policy and planning).
    • The lack of good settlement level data on the quality of the physical environment should be an area for development to establish what the priorities are and how well the planning system is delivering against these. Better integration of development planning with regional Land Use Strategies and helping deliver the Planning Act's objective of use of land in the long term public interest (civil society).
    • An easy to read summary of the performance reports should be widely available (civil society).
    • Rather than the proposed complex and resource intensive approach, resources should be targeted towards under-performing authorities and problem topics/areas which are constraining performance and development (policy and planning).

Q3e. Do you have any suggestions about how we could measure the outcomes from planning such as:

  • Placemaking
  • Sustainable Development
  • Quality of Decisions

3.3.10 There were 49 comments on how outcomes from planning could be measured for placemaking, sustainable development and quality of decisions. The main themes raised are:


  • Several policy and planning respondents and a development industry respondent highlighted the difficulty in measuring outcomes from planning around placemaking, sustainable development and quality of decisions. Issues raised included the subjective nature of the outcomes and the need for extensive resources to gather data.
  • A few policy and planning respondents suggested that measuring outcomes in terms of placemaking, sustainable development and quality of decisions is a long-term process as the true impact is not immediately ascertainable and many developments, particularly large scale ones, are completed over a number of years. It is not something that can be measured on an annual or 5-year basis.
  • A few civil society respondents felt that these terms were not sufficiently defined to be measured effectively. For example, placemaking can mean different things to different people. Related to definition, a development industry respondent suggested that the Scottish Government should set out criteria which define good placemaking, sustainable development and quality decisions and invite authorities to confirm whether these criteria have been met for each application (major developments only).
  • A few policy and planning respondents suggested that a national approach should be developed or perhaps even a national level assessment.
  • The RTPI research on Planning Outcomes was highlighted by a few policy and planning respondents as a valuable input to measuring outcomes.


  • Several civil society and policy and planning respondents suggested that The Place Standard is helpful in measuring placemaking outcomes and engaging local communities and stakeholders.
  • A number of possible measures/approaches were suggested. All suggestions are from policy and planning unless stated:
    • A baseline assessment of life qualities at a location prior to development and what positive changes the development will have on the local community (civil society)
    • Number of applications which meet criteria relating to national or local place principles. Authorities could nominate applications for a "placemaking award for Scotland" where they meet or surpass place principles. This could incentivise investment in the placemaking agenda (development industry)
    • Where added value has been provided by the planning process i.e. where significant improvements have been required through discussions such as increased open space, increased active travel network.
    • Positive impacts on health, well-being, safety and community participation
    • Condition of the historic environment as measured by listed building demolitions, condition of scheduled monuments, condition of pre-1919 buildings
    • Local perceptions of quality of place drawing on the Scottish Household Survey methodology
    • Remediation of vacant and derelict land
    • Delivery of a mix of housing including size, affordability and accessibility
    • Access to services including health, social care and education

Sustainable Development

  • The term sustainable development requires clarification with different interpretations from the different groups responding i.e. civil society respondents have a different definition to business and development industry. However, the need to measure the economic, environmental and social outcomes of projects is recognised.
  • A number of possible measures/approaches were suggested by civil society and policy and planning:
    • Energy saving measures and carbon neutral heating
    • Provision of electric transport
    • Remediation of vacant and derelict land
    • Proportion of development served by a heat network
    • Reduction of carbon dioxide emissions from buildings
    • Proportion of new buildings with low and zero carbon technologies
    • Improvements in air quality
    • Re-use of existing buildings, active travel data
    • Change in biodiversity
    • Contribution of development to blue/green infrastructure

Quality of Decisions

  • Measuring the quality of decisions will need to be undertaken sometime after the development was approved to see if it was implemented and had the effects detailed in the original application (development industry). This point was also made by a civil society respondent in relation to economic (employment) outcomes i.e. there is a need to measure actual outcomes and not just those estimated in the application.
  • A few development industry and business respondents also highlighted the need to track what happens after community's object to applications to determine if the perceived negative impacts arise or if they are mitigated.
  • Decisions should be measured in terms of transparency and openness to public participation. With regards to the historic environment, the Historic Environment Policy for Scotland, 2019 includes a framework for good decision making for plans and projects which requires decisions to be informed by an inclusive understanding of the potential consequences for people and communities.

Q3f. Do you have any suggestions about how planning's contribution to the National Outcomes contained in the National Performance Framework should be measured and presented?

3.3.11 There were 43 comments received on how planning's contribution to the national outcomes contained in the NPerfF should be measured and presented. The comments covered the following themes:


  • A few policy and planning respondents identified Local Outcome Improvement Plans (LOIP) as providing the most appropriate opportunity for presenting planning's contribution to the NPerF outcomes, particularly if seeking to achieve closer alignment between planning and community planning. However, more detailed advice on how planning sits within the national outcomes would be useful to ensure they are meaningful. It was also noted that not all the outcomes in the NPerF are directly linked to decisions made via the planning system.
  • Policy and planning respondents also made a number of other comments:
    • It was felt that the NPerF outcomes may be better assessed at the authority level with contributions to certain outcomes from its planning function.
    • Using more indicators that link to national outcomes is recommended
  • A few business and development industry respondents identified that National Planning Framework 4 (NPF4) will have to be very clear in terms of what actions and outcomes are required at the local authority level to achieve the positive outcomes intended. With specific reference to housing, the level of delivery needed across authorities to achieve the required level of new homes is necessary if positive outcomes are to be achieved and negative outcomes avoided. There has to be an understanding of need and demand and the consequences of failing to fully deliver against the need and demand. A policy and planning respondent also identified that housing targets are not included in national outcomes, but the delivery of housing should be a key part of how an authority is performing.
  • A business respondent identified planning as instrumental in achieving national outcomes and that the planning system needs to be a dynamic enabler of development and investment.
  • A few civil society respondents felt the outcomes listed in the Planning Act should be better reflected in the assessment of planning performance, particularly as climate change is absent from the NPerF outcomes and biodiversity may not otherwise be reported.
  • A few policy and planning respondents felt that the existing key performance indicators (KPIs) used in the PPR should be used for consistency and to prevent unnecessary additional work.

National Performance Framework Outcomes

  • One policy and planning respondent suggested the following measures for assessing planning's contribution to the national outcomes:
    • Human Rights - Service improvements to ensure the Planning Service treats people with dignity and respect. Empowering communities to influence local decisions that affect their neighborhood's e.g. through charrettes, local place plans.
    • Culture - How spatial strategies and plans support the creation of spaces for cultural production and help grow the cultural economy.
    • Environment - Identifying policies, plans and decisions that improve access to open space, protect and enhance the natural and built environment and support renewable energy.
    • Health - How policies, plans and decisions support active travel, increase opportunities for physical activity, and improve mental wellbeing (e.g. access to open space and high-quality development can create sense of pride in place).
    • Fair Work and Business - How policies, plans and decisions support businesses and economic participation by improving access to employment and by creating the conditions for investment.
    • Education - Addressing skills shortages in the planning system, ensuring that planning is integrated with other services and able to deliver a coordinated approach to achieving wider outcomes.
    • Children - Consider how policies and plans focus on the needs of children and young people. Increasing opportunities for engagement with young people.
    • Communities - Capture how the planning service engages with local communities to understand and sensitively respond to local issues. Engagement during the preparation of spatial strategies and plans.
    • Poverty - How the planning service seeks to work with others to improve access to services, facilities and so on. Directing the right development to the right place.
    • International - How plans reflect local, regional and national strategies to promote an area. Promoting the planning service internationally and networking. Considering how international research and best practice influence policies and plans.
    • Economy - Identifying policies and plans that promote inclusive economic growth and decisions that give weight to economic outcomes. Plans that seek to enhance access to digital infrastructure by frontloading integrated infrastructure. Policies and plans that support entrepreneurial activities, attract investment and seek to optimise natural capital."

Planning Act Outcomes

  • A development industry respondent made some suggestions around the outcomes in the Planning Act:
    • Meeting housing needs - Clear housing targets required for each authority; Explicit methodology to calculate housing land shortfalls; Standardise generosity allowance; Develop a housing land methodology over a minimum ten-year period.
    • Improving health and wellbeing - Prepare guidance which clarifies how planning improves health and wellbeing.
    • Increasing population in rural areas - Significantly improve quality of infrastructure and services in these rural areas.
    • Improving equality and eliminating discrimination - Existing system is effective.
    • Meeting targets relating to reduction of emissions of greenhouse gases - Existing system through building standards is effective. The challenge is to reduce emissions in existing developments not future developments. Major initiatives required to introduce low-carbon infrastructure.
    • Positive effects for biodiversity - Existing system is effective. All new developments are more biodiverse than green field sites, recognising the need to preserve and enhance existing wildlife corridors.

3.4 National Planning Improvement Coordinator (NPIC)

3.4.1 The Planning (Scotland) Act 2019 includes a power for Ministers to appoint a NPIC to monitor and provide advice to planning authorities and others on the performance of general or specific functions. The Coordinator will be appointed by Scottish Ministers and their role will be focused on the performance of the planning system as a whole. The coordinator will provide advice to Ministers in an impartial way, including looking at Planning and Architecture Division (PAD), Department for Planning and Environmental Appeals (DPEA) and Scottish Ministers' role. It is thought that the Coordinator should help to develop their role in collaboration with stakeholders once they are in post so they can learn from what does and does not work.

Q4. Do you have any comments about the role and responsibilities of the NPIC?

3.4.2 The consultation sought comments and suggestions about the role and responsibilities of the NPIC. The table below shows that a substantial majority (89%) of respondents answering the question agreed with the proposed responsibilities of the NPIC. There was broad support for the role and responsibilities from all groups except development industry.

Do you agree with the proposed responsibilities of the NPIC?
Yes No Not Answered
Business 10 2 17
Civil Society 14 3 11
Development Industry 10 1 1
Policy and Planning 22 1 17
Total 56 7 46
% of Respondents Answering Question 89 11

3.4.3 There were 64 comments on this question across a range of issues which are presented below in decreasing order of the number of comments made:

  • Many respondents across all major groups identified the need for the NPIC to promote improvements and share best practice across planning authorities. This should include best practice in terms of efficiency and decision making and advising on how to best measure outcomes against key indicators. Amongst the policy and planning respondents, it was felt that the NPIC should provide a supportive role in seeking to identify the obstacles to improve performance and share good practice rather than being there to punish underperforming authorities. Amongst the business and development industry respondents, the current forum for performance discussions (the High-Level Group on Planning Performance) was not felt to be conducive to improving performance and respondents felt that the house building industry should be part of the group. Civil society respondents highlighted that the NPIC should have a nationwide, external role to share good practice and improve consistency across planning authorities.
  • Many respondents across all major groups identified the need for the NPIC to develop communications/relationships with key stakeholders including agencies, development industry, infrastructure providers, local authorities, agents and community groups. The potential for digital tools to assist in maintaining connections was made as was the need for the NPIC to engage with stakeholders in round-table sessions as well as individually. One policy and planning respondent supported the role but felt the consultation did not provide sufficient guidance on who the stakeholders would be and how engagement would be delivered.
  • Several respondents across all major groups except policy and planning referred to the need for the NPIC to have the powers to implement change to drive improvement.
  • Several respondents across all major groups except development industry felt that it was essential that the role extended beyond monitoring the performance of individual planning authorities and seeks to address issues within the planning system as a whole. If implemented well, the NPIC has the potential to raise the profile of planning and strengthen the ability of the planning system to deliver on many of Scotland's priorities.
  • Several respondents across all major groups identified the need for the NPIC to be someone with significant experience of the statutory planning system in Scotland. The development industry and business respondents highlighted that the NPIC should have a balanced and informed perspective on the planning system, including from the user's perspective. Development management experience with both a local authority and the private sector was also suggested.
  • Several respondents across all major groups emphasised that the post should be independent. Independent from political parties, government departments and other users of the planning system. The role will require clear parameters and several business and policy and planning respondents raised the importance of having a clear distinction between the role of the Chief Planner and NPIC.



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