Planning review position statement: analysis of responses

Analysis of responses to the Scottish Government's Position Statement following the consultation on Places, People and Planning.

Executive Summary

This report records the analysis of the responses to the Scottish Government's Position Statement following the consultation on Places, People and Planning. It was prepared by researchers from Kevin Murray Associates.

The Scottish Government's consultation was undertaken in June - August 2017, with responses taken to 11 August 2017. 122 responses to the consultation were duly received, again from a wide range of stakeholders, representing a broad range of perspectives on planning and the planning system.

The purpose of this report is primarily to aid the Scottish Government in moving forward with their work. Therefore, the analysis has sought to draw out the major areas of agreement and concern from across the full body of evidence, and areas in which respondents sought more information or had ideas or comments. Whilst all responses have been taken into account it has not been realistic to set out the qualitative content of every single response in equal detail, because of the volume and length of the report that would ensue.

The analysis identified the sectors that the responses came from. Four primary sectors were identified. The breakdown of responses returned from these primary sectors was as follows:

Main Group % response to Position Statement
A Civil Society 39.3
B Policy and Planning 32.8
C Business 9.8
D Development Industry 18.0

The research team processed the 122 responses to the Position Statement and had produced this analysis, which follows the four main themes in the consultation document, plus the three questions on the SEA and Environmental Report. The responses were coded using the 20 proposals in the Position Statement as the main framework, with additional codes added as the work progressed to gather information on other issues raised.

The methodology adopted by the research team took the following approach to the submissions:

  • First, every submission was given an initial equal weighting, allowing every idea presented to be considered equally.
  • Second, while the frequency of an idea may be suggestive of the 'weight' it became apparent this might not be the case. For example, one idea could be proposed by 30 Group A1 "individuals", while another could be mentioned once by a Group B1 professional body with 100 members who have produced a collaborative response. We have taken the view that while both ideas have validity, undue consideration should not be given to an idea solely based on frequency.

The following summary provides a quick-look overview of the main areas of agreement by theme, and a supporting overview table with additional detail on the responses to the proposals in Places, People and Planning.

Key Theme 1: Making Plans for the Future

  • Support for a statutory link between community and spatial planning, including a sign-off process.
  • Support for stronger partnership working that provides a robust platform at the regional scale.
  • Support for enhancing the status of both the National Planning Framework and Scottish Planning Policy.
  • Support the 'gatecheck' process and resolution of issues at an early stage.
  • Support for the principle of enhanced engagement for unallocated sites – with the detail of what this means varying between the respondent categories.

Key Theme 2: People make the system work

  • Support for Local Place Plans that are informed by Local Development Plans.
  • Support for early engagement, and engagement with young people.
  • Support for mandatory training for elected members.

Key Theme 3: Building more homes and delivering infrastructure

  • Support for any move that gives greater certainty to housing numbers and reduces debate.
  • Support aims of proposals to close the gap between planning consent and delivery of homes.
  • Support for Simplified Planning Zones, and the proposed rebranding. Lessons should be taken from trials, previous experiences and research.
  • Support for the infrastructure first approach, with mixed views on whether or not a National Agency or national working group is the better approach.
  • Mixed support for the proposed infrastructure levy.
  • Support from business and development industry respondents for retaining the ability to modify or discharge Section 75A obligations.
  • Support for removal of Section 3F of Section 72 of the Climate Change (Scotland) Act 2009 from planning and policy and development industry respondents, contrary to the Position Statement's approach. It is felt building standards and control is better positioned to enact change in this area.

Key Theme 4: Stronger leadership and smarter resourcing – Areas of Agreement

  • Support for skills and service sharing if it makes for a more able planning service.
  • Support for the Royal Town Planning Institute skills audit.
  • Increased fees are supported, for business and development industry respondents the caveat to the support is if there is a demonstrable improvement in service.
  • Support for monitoring outcomes rather than performance, and seeking ways to improve under-performing planning departments through support systems rather than penalise them.
  • Support for expanding permitted development rights, with each respondent category having their own reasons for providing this support.

SEA and Environmental Report

  • Generally it was viewed that the SEA and Environmental Report was covering the right scope.
  • The predicted environmental effects in the Report were generally seen to be accurate – the exceptions being on removal of supplementary guidance, monitoring environmental change across 10-year LDPs and potential impacts from Simplified Planning Zones.
  • The proposals for mitigation and monitoring were viewed to be appropriate, given that the proposed changes are largely procedural and operational.

Other key threads emerging:

  • For many of the respondents, they were offering support in principle but would like to see further detail on the proposals. Consequently, there was some criticism of the current level of detail.
  • There continues to be a high level of interest in Local Place Plans ( LPP), but with divergent views both across and within the respondent categories; on issues such as the need for additional resources and aid for communities, and on whether this creates an additional burden for the planning service.
  • Community organisations were still calling for some form of Equal Rights of Appeal – even if that was just an exploration of options.
  • Simplified Planning Zones ( SPZ) were generally supported provided the matters of detail can be worked out to provide heritage and environmental designations with adequate protection, and for design and place quality to be assured. However, the idea of Ministerial designation of SPZs did not have broad support.
  • Investment in an improved planning service was supported broadly. However, the development industry has expressed concern that no measures have been suggested at this stage that demonstrates the link between increased fees and increased performance.
  • Permitted Development Rights proposals drew support from different perspectives for various reasons across the respondent categories. Community responses focused on small scale development such as bike sheds and community growing space. Planning and policy raised different issues on whether or not extending permitted development rights would free up additional resources. The business sector sought permitted development rights for energy developments below a certain scale, and the development industry supported this on the basis that it would free up additional resources to work on the main applications.


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