Reviewing and extending permitted development rights: consultation analysis

6. Other comments

6.1 The final consultation question invited respondents to provide any other comments on the SA report.

Q5. Do you have any other comments on the Sustainability Appraisal report?

6.2 A total of 58 respondents addressed Question 5. Table 6 summarises these responses by respondent type.

6.3 Most of these respondents used Question 5 as an opportunity to reiterate points discussed earlier in relation to specific development types, or common themes. This included specific reference to consideration of cumulative impact (particularly on flood risk), effects on cultural heritage, and environmental impact for biodiversity and flooding.

6.4 Some of those providing comment at Question 5 raised other issues which had not been fully considered in relation to Questions 1 to 4. These are summarised below.

• Some suggested that if the overall approach to extending PDR is to deliver the expected benefits, it should result in consolidated legislation and guidance. This included specific reference to the opportunity to review the current prior notification/approval scheme to streamline the process, with a planning authority recommending a simplified one-stage prior approval procedure.
• Some referred to general principles that should shape consideration of which development types are suitable for PDR. This included reference to the potential need to limit PDR for development types where predicted effects are expected to be significantly negative, or where effects are unclear. This reflected wider comments regarding the degree of uncertainty in the SA evidence base, and concern that this should not be interpreted as there being no significant effects.
• Several respondents highlighted the importance of ongoing consideration of issues raised by the SA, including more detailed mitigation and monitoring proposals, as part of the proposed work programme. This included a number of respondents specifically expressing interest in ongoing engagement with the Scottish Government as part of this process.
• Reference was made to specific policy priorities or objectives which respondents felt should be acknowledged by the SA. This included sustainable development, the purpose of planning as set out in the 2019 Planning Act, and the National Performance Framework.
• A third sector respondent also suggested that a principle of net biodiversity gain may be appropriate as a condition for developments benefiting from PDR.
• Some respondents questioned the use of a SA as opposed to a standalone Strategic Environmental Assessment (SEA). This included suggestions that integration of SEA findings into the SA report narrative made it difficult for readers to track the full range of complex environmental considerations through the SA.