News: 26 October 2020Scotland team respond to Scottish Planning Policy Consultation

Our Scotland team have been busy responding to the Scottish Government’s Scottish Planning Policy and Housing: Technical Consultation on Proposed Policy Amendments.

Iain Hynd, Planning Associate said “It is fair to say that we do not agree with the timing or content of the proposed amendments to SPP and consider that the Presumption should remain as an important check and balance to our Planning System. There are simpler ways to respond to potential impacts arising from Covid-19 and thankfully its effect on the delivery of housing does not appear – yet – to have been as devasting as many of us feared. But still we cannot be complacent.

Ultimately, what we want to see is better and closer cross-sector working to ensure our plan-led system is delivering as effectively as it can be, delivering a generous supply of truly effective housing land for sustainable residential neighbourhoods where people want to live. The resulting approach needs to be robust against effects from separate political agendas and retain a nation-wide focus and commitment to the need and benefit of new housing – collectively agreed and set for the long term through NPF 4 and Regulations for the new Planning (Scotland) Act.”

We’ve summarised, below, seven of our key suggestions.

  1. Do not remove the Presumption in favour of sustainable development. Instead, retain it and ensure that our plan led system is functioning as it should, with all development plans being up-to-date and with a generous supply of effective housing land being allocated in marketable location.
  2. Rather than the excessive changes proposed to SPP, use simpler tools like a Chief Planner’s letter or addition of a couple of lines to SPP to respond to potential delays due to Covid-19 (such as a temporary change to the five year definition for when plans go out of date).
  3. Retain and strengthen a Development Management sub-section within SPP’s Principal Policy on Sustainability to be used as an effective tool in the decision-making process for planning applications.
  4. Reject all proposed changes to the definition of the five-year effective housing land supply.
  5. Include detail on how completion rates should be recorded and set a methodology for local authorities, the Scottish Government and developers to agree and sign off this number.
  6. Provide a Development Management sub-section within SPP’s section on Enabling Delivery of New Homes. This should include a methodology for the calculation on establishing the five-year effective housing land supply which takes into account the past performance regarding housing completions.
  7. Changes proposed through this SPP amendments consultation, if taken forward, will directly affect the outcome of planning decisions and will have a significant effect on the delivery of development, new homes and economic growth across Scotland. Instead of these changes, embrace increased dialogue between sectors across both plan making and development management processes and use the NPF 4 process to have the inclusive and open debate required to get cross-sector agreement on how our Planning System can best deliver new homes needed for the country.

You can download/read our full response here.

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