On 17 July 2020 the Scottish Government published a consultation paper setting out proposed interim changes to the Scottish Planning Policy (SPP) (2014).[i] The consultation period closed on 9 October 2020.
The Scottish Ministers have since reflected on the responses to the consultation, including evidence highlighted by respondents and gathered during the consultation period. This paper:
- Summarises the key issues arising from responses to the consultation. A fuller analysis is set out in an independent report.[i]
- Reflects on available evidence.
- Sets out the Scottish Government's response, in light of the comments and evidence received.
- Sets out our finalised interim policy position including revised text of the relevant sections of the Scottish Planning Policy 2014.
Enabling the delivery of good quality development is an important objective for the Scottish Government. The Scottish Ministers wish to see homes and other essential developments delivered in a way that respects and is consistent with development plans that have been drawn up with input from local communities and other interests.
Our final policy position reflects our view that the planning system requires co-operation from all parties to work together effectively to deliver good quality development. It is clear that there are many different views on how that can best be achieved, and that this is a key issue for the wider review of national planning policies to consider further.
The amended interim policy is intended to make the system more transparent, fairer and more consistent with these objectives, ahead of National Planning Framework 4 being adopted in 2022.
The consultation process
We considered the consultation to be necessary, as a result of recent litigation and complexity arising from certain parts of the Scottish Planning Policy. Some of the proposed changes also aimed to respond to the impact of COVID-19 on the planning system and housing developments. Overall, views on the proposals were divided, with some supporting the changes and others opposing them.
Some responses expressed concern about the consultation process, its timing and the lack of a transition period, forewarning or scope for earlier involvement. Issues included the scale and significance of the changes proposed (with suggestions that the paper's title and assessments underplay its impacts), a perceived lack of supporting evidence and impact assessments, the accessibility / language used in the consultation paper and presentation of the proposals as relating only to housing matters rather than wider development proposals. In response to these views:
- There was a good level and range of responses to the consultation. We received 244 responses by the deadline from a wide range of stakeholders including public and private sector organisations, community groups and individuals, as set out in the independent consultation analysis report. This number and range exceeds the response from the consultation undertaken when the presumption was introduced in the 2014 version of the Scottish Planning Policy (160 responses).
- There is no evidence to suggest there was widespread or universal dissatisfaction with the consultation process. In response to a specific question on the Citizen Space platform, a minority of respondents (28) who expressed a view felt dissatisfied with the consultation, a majority (83) were satisfied, and the remainder did not express a view or a preference either way.
- The title of the consultation was not intended to minimise its importance. This is undoubtedly a complex area of planning, the paper was titled as a 'technical consultation' to accurately describe its content, rather than as an attempt to minimise its significance. We fully appreciate the importance of the issues and this is reflected in our decision to formally consult on the proposals.
- We provided extra support to a range of stakeholders. To help stakeholders understand the proposals, we offered support to a range of representative organisations by meeting with them to answer their questions and clarify issues.
- Sufficient time was allowed for responses. The consultation period was of sufficient length to allow respondents to submit their views in a timely manner.
- Overall this has been a meaningful and effective consultation. Whilst we recognise that this is a difficult topic for some people to engage with, taking into account the number and range of responses we have received, we do not agree with assertions that this consultation has been underplayed or that people have not had an opportunity to express their views as a result.