Local development plans - deliverability of site allocations: research

3 Survey and Consultations

Introduction 

3.1 The research programme into the deliverability of site allocations included a survey of Scottish local planning authorities, consultations and working sessions. The purpose of the survey was to: 

• identify the information provided by promoters of sites in support of allocations in development plans; 
• explore to what extent that information does or does not provide confidence in deliverability; and, 
• consider how that confidence could be improved. 

3.2 Following analysis of the online survey, planning authorities were selected for one-to-one discussions and exploration of their experiences of requesting, receiving and assessing sites information to support deliverability. The planning authorities were: Aberdeenshire Council; Clydeplan (for a strategic perspective); North Ayrshire Council; and Perth & Kinross Council. A consultation was also undertaken with the British Geological Survey in relation to an LDP data project which the organisation is currently undertaking for the Scottish Government.

3.3 Two further consultation sessions were held: a panel review of the early research in January 2018; and a Steering Group in February 2018. The sessions were attended by representatives of: Architecture and Design Scotland; Homes for Scotland; the Royal Institution of Chartered Surveyors; the Royal Town Planning Institute; Scottish Enterprise; Scottish Property Federation; and Scottish Water.

Planning Authority Survey

3.4 The online survey was open to the 32 Scottish local development planning authorities and 2 National Park planning authorities between December 2017 and January 2018. The survey secured a 100% response rate ^[8].

3.5 The analysis below provides the combined responses to each question. Where free text or supplementary comment was requested, a summary review of those written responses is also provided. As an indication of the depth of interest in this topic among planning authorities, the exercise attracted not only the 100% response rate noted above, but also more than 8,000 words of written comment. 

3.6 Question 1 asked respondents to indicate which planning authority they were responding on behalf of. This allowed the consultants to manage the response rate including dealing with duplicate responses and offline submissions, and conduct later sub-analysis by local authority type reported at paragraphs 3.17 to 3.23.

3.7 Question 2. Please select your job title.

A small majority of respondents are at managerial level in their planning authority. The balance are planners or senior planners. Very few (2) are at executive level. This suggests that receiving and assessing sites information is a qualified and experienced, ‘hands on’ process rather than an executive function.

3.8 Question 3. Who leads on, and who is involved in, the assessment of site deliverability?

As would be expected, site deliverability is assessed by Development Planning teams. The large majority of Development Planning teams also involve other local authority departments and key agencies in their sites assessments. Two-thirds of respondents also involve their Development Management teams in assessing the deliverability of sites. Other consultees were mentioned by a minority of respondents, but the range is extensive, including Transport Scotland, Historic Environment Scotland, landowners, developers, Homes for Scotland, housing associations, Forestry Commission, regional transport partnership, Network Rail, community planning partners and the Scottish Wildlife Trust.  

3.9 Question 4: At which stage in the Local Development Plan process do you request site allocation submissions? 

Site allocation proposals are predominantly requested before preparing the Main Issues Report within the current plan process. One authority has not called, for sites but where information is required on a particular location the agent/owner is then contacted. Another One authority takes a “planning approach” to current and potential sites, and may issue a targeted call for sites if required. Some authorities consider sites proposed during the MIR consultation. One authority requests sites information to help update its action programme.

3.10 Question 5: How important is supporting information in understanding a site's deliverability? 

The question seeks to understand the link between site information and understanding of deliverability. Planning authorities require a notable range of information. Location is clearly essential.  Physical constraints and transport/ access information is mainly essential, or at least desirable, as is ownership. A majority report that contamination, infrastructure / utilities, land use and environmental designation information is essential; and the balance say that such information is desirable. Together these will inform whether a site is potentially physically deliverable, or faces one or more major constraints.

The responses to market factors governing whether development might be deliverable on site are more nuanced. Authorities would, in the round, like to receive information on viability, marketability and deficit funding, but only a minority think this information is essential, and the balance that it is desirable. 

Policy compliance, public consultation and design attracted a range of different responses from planning authorities, around a central view that information on these is ‘desirable’ within site proposals.

As an inference from these responses, it could be stated that the current focus of development planning is upon the initial deliverability of development land through assessment of constraints, and much less so upon the subsequent deliverability of development.  Physical constraints are a clear precursor in making a site developable. They may also be subject to less future variation - and alternative interpretation - than market factors and viability; meaning that early physical site information is more useful, may be more easily agreed upon, and may decay less over time.

Additional useful information noted by authorities includes planning history, any options held, any legal restrictions, land tenure, greenfield or brownfield / vacant & derelict, developer and anticipated programme, funding source, socio- economic benefits, landscape impact and trees/ hedges on site, compatibility with neighbouring uses, broadband coverage, core paths/ routes, green belt / network, and accessibility to services/ facilities including via public transport^[9]. 

3.11 Question 6. What supporting information do applicants provide in site submissions? 

This question provides a direct comparison with question 5.  Given the information that planning authorities would like to receive to assess site deliverability, what do they actually receive from site promoters?  

Remarkably, only two-thirds always receive a location plan. About one-third always receive land use and ownership information. Regarding the physical constraints highlighted as important to assessing site deliverability at Question 5, the balance of responses for all information types sits between ‘usually’ and ‘seldom’.  For the market factors (viability, marketability and deficit funding), responses are clustered around ‘seldom’. Planning authorities note that the information submitted by promoters varies greatly by site and submission.   

Overall there is a major and consistent gap between the information attributed to categories of sites information by planning authorities and the information that is typically provided by site promoters.  

Whether this gap adversely impacts upon deliverability by creating persistent information gaps is less clear; site information may accumulate during the subsequent planning and design activities up until the determination of a planning application. Understanding deliverability may be a process rather than a stage. 

A further direct comparison can be made here, with PAN 2/2010s’ effectiveness criteria for housing sites (paragraph 2.4). The third (ownership) to ninth (land use) information categories in Questions 5 and 6 were set to mirror those effectiveness criteria. The typical response above is that site promoters usually or seldom provide this information. This suggests a major information gap against policy requirements when assessing promoted housing sites, meaning that the effectiveness of those sites must be assessed elsewhere in the planning process.

3.12 Question 7. How is the deliverability assessment actually undertaken, for example do you use an assessment matrix? Please provide a brief description.

This question attracted a range of responses, some very detailed. It is possible that there is an element of self-selection here, with those authorities applying the most rigour to assessing site deliverability also providing the most detailed responses to the survey. Among the more brief comments, one respondent for example noted that they are currently developing a sites assessment methodology for the first time. Another responded that they do not have a formal approach to sites assessment but use internal discussion to assess sites. 

Those authorities responding in some detail use the information provided by site promoters to populate a comprehensive sites assessment matrix, including scoring. This can also apply to current LDP allocations, not just new proposals. The method and results of the sites assessment are made public by some authorities. Site evaluation reports are provided by some. One notes the importance of a commentary on deliverability undertaken with other local authority teams, such as housing. Another notes that site visits are conducted. It was noted that sites assessment matrices can identify information gaps and form the basis for further information requests and subsequent dialogue with site promoters.

One authority noted that they do not challenge site promoters’ statements regarding deliverability, as this would require detailed knowledge, but that they do set out comprehensively the issues to be addressed. Another requests evidence of marketing, interest and values (while acknowledging that, pre-allocation, this may be limited); that respondent would like design information and development appraisals to accompany site submissions. A further respondent uses the sites assessment as an opportunity for dialogue with site promoters about, for example, their past and anticipated future development rates.

A planning authority described a staged process, where sites were shortlisted then reviewed by ‘key stakeholders’ to help select preferred sites for public consultation through the MIR process. Non-preferred sites were presented as alternatives and also consulted upon and subject to Strategic Environmental Assessment. Another describes a process of internal (local authority) and external consultations to come to a view on sites.

Information on required infrastructure enhancements are a major focus. One respondent focuses on “physical feasibility, not financial viability”, reflecting the distinction made here at paragraph 3.10. The respondent also notes that site promoters “have rarely indicated that a potential site and its necessary infrastructure are undeliverable”. 

The use of Strategic Environmental Assessment data in site assessments is mentioned by a small number of respondents who use that process and their sites assessment in parallel to avoid duplicate work. 

One respondent prepares individual site assessments covering physical, environmental and infrastructure topics, rather than a comparative matrix. Sites are drawn from the Housing Land Audit process, public sector surplus sites, those nominated by site promoters at pre-MIR call for sites and during consultation, other sites noted and sites from the previous LDP. Assessments include site history (from internal records and consultations and key agencies), and a consideration of how each site fits within the development plan strategy. This approach combines the spatial plan aims with all potential site options.  

Similarly, another respondent reports that groups of sites are assessed against sustainability and location as the principal considerations, and then also deliverability on a qualitative basis guided by PAN2/2010 (for housing sites). Another combined approach uses three broad categories - environmental factors (using Strategic Environmental Assessment – SEA – data), infrastructure availability, and viability/marketability – to assess candidate sites. 

Some approaches appear to be more market-led. One authority first sieves sites for effectiveness and deliverability, requiring them to pass that stage before a more detailed assessment is undertaken. Another authority overlays (for housing sites) a “marketability map” provided by Homes for Scotland onto SEA and Key Agency data. One authority conducts detailed assessments and consultations, where having an active developer on board is critical. One undertakes an assessment of site deliverability, while another specifically does not assess deliverability at the call for sites stage. Another relies upon information in the annual Housing Land Audit (for housing sites). Another undertakes a consultation exercise to understand viability. Taking a more detailed approach, one authority specifically ensures that site promoters have considered viability - including policy requirements - in order to save time and costs at the development management stage.  

The approaches to site assessment clearly share some common ground in terms of the range of criteria, but the sieve order and weighting – by market factors, physical capacity/constraints, or spatial plan priorities – are not consistent, and could potentially influence the short-listing and thus the allocation of sites.

Only one respondent specifically mentions assessment of deliverability of employment rather than housing sites^[10]. All other land use-specific comments in the survey referred to housing.

A few respondents mentioned the software they use to assemble sites information. Microsoft Access, spreadsheets and internal GIS systems were specifically mentioned. 

Some respondents described specific working practices. These include an LDP Project Board, internal working groups, and a panel of professional disciplines which guide the criteria and site scoring. One mentioned hosting Place Standard workshops with communities. The importance of including commentary as well as simply scoring was noted.

In summary, these responses to Question 7 indicate the evolutionary nature of assessments of site deliverability in the preparation of Scotland’s LDPs. The general trend is towards greater upfront investigation across a wider range of site-specific matters, a more interlocking approach with other services, agencies and workstreams, and better transparency and consultation with site promoters and communities. The process is however clearly moving at different speeds and in different ways across the country.

The clearest differences are in the prominence which development viability and marketability are afforded in the process. Most authorities assess whether sites are physically deliverable, while some also assess – or indeed prioritise – whether future development might be deliverable. The two are of course linked, as viable development can permit prior physical site investment and funding of policy requirements.

3.13 Question 8. What are the current constraints to improving information for the assessment of sites? (multiple answers can be ticked)

The major constraints on improving site assessment information are planning authority resources and specialist skills; more than two-thirds of respondents cite each of these. As the process of information front-loading to improve confidence in deliverability gathers pace, both the volume and specialist nature of information and assessments received present challenges. The majority response indicates that information overload is not simply a prime market phenomenon, but is a common feature of development planning.

The resources of applicants to provide information is cited as a constraint by a large minority of authorities. Not all site promoters are major developers with extensive resources and skills and professional advisors. Site promoters may include communities, individuals, small developers, long term landowners, public agencies, economic development organisations, social housing landlords and in areas of low demand or for non-housing sites, the planning authority themselves.

Third party agency resources and timescales are noted as constraints by a large minority of respondents. Just over half of respondents note that confidentiality of information is a constraint. 

This question about constraints attracted significant additional comments from authorities.

Information submitted varies from site to site; some submissions are very lengthy yet still don’t provide the information required. Information provided by site promoters is often “lacking, vague or of poor quality”.  Marketability questions typically yield assertions rather than evidence. Site servicing questions can attract similar statements rather than capacity and costs. These may signal lack of resources, unwillingness to commit resources at an early and uncertain stage, or perhaps a reluctance to highlight less viable sites. Site promoters are believed by authorities to feel that a planning application merits substantial resources, but not an LDP allocation. Some site promoters are thought by authorities to also feel that the information sought is commercially confidential or sensitive.

Local authority resources vary greatly and some report receiving disproportionately high volumes of site submissions. One team received more than 600 site submissions, constraining the extent of expertise which can be applied to each within a short defined timescale. Another with only four planners in a large area received more than 80 site submissions. Yet another received more than 200 site bids in a context of reducing staff resources. 

Assembling, reviewing and assessing information then engaging in meetings and consultations is reportedly time consuming. Internal consultees for matters such as air quality, noise, heat mapping, flood risk, education and roads can also require to consider large numbers of promoted sites. 

Rural authorities report resources and skills challenges not only in their authorities, but also in their local property development and professional services sectors.

Specific skills reportedly required are mainly around market analysis and development appraisal to inform viability. However, one authority notes that challenging viability can destroy the trust built up with site promoters, and genuinely unviable sites are likely to be identified very early in the process. Another notes that major developers have declared a location ‘unviable’, only for a local developer with a different business model to successfully build in the same area. Some respondents would like to see site promoters’ development appraisals, while recognising that these may require specialist support, independent verification and will change over time.

One respondent notes that standard questions are insufficient for larger sites; impacts on infrastructure and site appraisals including independent input and ongoing dialogue are required, although this will be time-consuming for site promoters and include technical studies (for example transport, ground conditions, flood risks), without the certainty of securing a site allocation.

Key Agencies are reported to be generally helpful around the call for sites process, although occasionally their responses can be slow or not forthcoming. Repetition of facts by Agencies are less helpful to planning authorities than their views on whether constraints will affect a site’s potential to be developed; and a definitive statement of the information they would require to support rather than object to an allocation. Key Agencies and other consultees should, in the views of planning authorities, be made aware of the need to demonstrate the deliverability of development plan sites. 

One authority noted an assumption that site promoter information “does not lift the duty on the authority to consider all relevant options on a consistent basis”. This implies a potentially significant requirement for authorities to bring all submitted site information to a consistent standard and if necessary complement that with further specialist input. That would place a greater burden on planning authorities and other departments and agencies, particularly in market areas and sectors where major developers are less active. Such specialist input is often needed by planning authorities around infrastructure requirements, including estimation of cumulative needs. 

Some respondents report a “do minimum” approach by site promoters. One reports that repeated requests to site promoters to demonstrate deliverability with information such as potential layout or site constraints yielded a 10% response, none of which included financial viability. Those site promoters with relatively better proposals are believed by respondents to be aware of their competitive advantage, and thus do not feel compelled to further demonstrate deliverability.

3.14 Question 9. Would you support additional guidance on the information to be provided by applicants?

The large majority of respondents would support additional guidance on the information to be provided by site promoters seeking allocations in development plans. 

Respondents believe that local guidance and information requests are too easily ignored. Site promoters are thought likely to comply more with national guidance.

However, a significant minority of respondents do not support additional guidance and believe that allocation of sites should be assessed locally. Furthermore, many who favour national guidance would also require scope to adjust for local needs, and where necessary for that to take precedence. Examples of local variability included rural markets and former mining areas which create specific site conditions.

Thus the survey respondents are not necessarily asking for a rigid, mandatory approach to site assessment, but rather the weight and guidance of a standard approach which can retain the potential for local flexibility. 

In terms of a minimum information standard, it was noted that this is something that site promoters should “have anyway, if they are serious about developing a site”. On the other hand a fully standardised approach may deter smaller but committed developers from an onerous process. 

The structure of planning reform was noted by one respondent; they were of the view that if local supplementary guidance is removed from LDPs then the need for national guidance will be greater.

A minority of respondents do not carry out a call for sites. One in a high value market area notes that sites emerge continually. The authority assesses all available land within its strategic development areas and identifies options; information from site promoters is noted but not decisive. Site promotion at MIR and Proposed Plan stage provides more detailed information which can be of use, but mainly “presents a site in the best possible light”.

Where respondents elaborated on the details of any future national guidance, their focus was upon site viability. One sought Scottish Government resources and District Valuers’ independent input to appraisals. Developers, Key Agencies and other infrastructure providers would in their view be required to support the process. Two respondents specified the required inputs – mix, prices, costs – to allow benchmarking of development proposals and their profit margins. One respondent indicated that site hope value and constraints/abnormal costs should be provided. The willingness of site promoters to participate in cumulative and if necessary cross boundary infrastructure assessments of their sites was questioned by respondents. 

One respondent noted that the main factor in securing information to promote confidence in deliverability will continue to be the site promoter’s judgement of costs versus the likelihood of securing an allocation, even if more guidance was provided. Thus site promoters in more buoyant market areas may be prepared to commit more resources to assembling site information than those in weaker market areas. 

3.15 Question 10. Are you aware of more successful approaches for site allocations used elsewhere? If so where? (e.g. another Planning Authority, Statutory Authority etc)

This question attracted a uniform response, that planning authorities are not aware of a more successful approach to site allocations. It appears to be a “universal problem”. The level of detail provided and the potential for information to be provisional at development plan stage is a persistent challenge. Some authorities have however enhanced their approaches to site assessment and participate in cross-authority work to promote best practice.

3.16 Question 11. Are you currently proposing to change the information required to support site allocations? If so please provide details

A minority of respondents do not propose to change the information required to support site allocations. Some are also bedding-in what are relatively recent site assessment approaches developed for their LDPs.  Others are waiting to see whether further guidance is provided in the context of planning reform (particularly the proposed ‘gatecheck’) and the withdrawn 2016 guidance note. One notes lack of development industry support as a barrier to change, particularly around realistic marketability, programming and viability.

Some intend to supplement site promoters’ information with further assessments, for example of sustainability (BREEAM Communities was mentioned). Others are enhancing the range of information assessed and clarifying what is required of site bids. Some report seeking further information at MIR stage, for example using the emerging Action Programme as the basis to interrogate timescales and delivery plans.

Notably, one authority which does not propose to call for sites is undertaking additional upfront work into the deliverability of currently allocated sites. They report that this is yielding useful information around market conditions, business models, landowner issues and other constraints such as infrastructure and costs as well as the opportunity to challenge landowners/developers about these. Actions may then be taken by the authority to help inform targeting of resources to support the delivery of those current sites and inform the next LDP, which may then include a targeted call for sites around settlement areas. Site promoters can however approach the authority to discuss their sites at any time.

Area Sub-Analysis 

3.17 The online survey reported above grouped together all planning authorities. This sub-analysis seeks to establish whether there are any significant differences by type of area. Many potential variations are possible, but to test the potential for variation here a straightforward application of the Scottish Government Urban:Rural classification^[11] is used to code areas into:

• Large urban (7 authorities)
• Other urban (12 authorities)
• Small towns and rural (15 authorities)

The coding allocates each planning authority to an area based upon the largest proportion of its Urban/Rural classification. The analysis was inspected to ensure that it yielded a broadly sensible allocation for each area. 

3.18 In all types of local authority area, the development planning team leads the assessment of site deliverability (survey Question 3). Large Urban areas have consistent supporting roles for development management, local authority departments and key agencies. Other Urban and Small Towns/ Rural areas afford at least as great a role to these supporting teams, and sometimes greater. 

3.19 There is a clear distinction by areas around when site allocation submissions are requested (Question 4). Large and Other Urban areas take submissions pre-MIR and typically also at the MIR stage. Very few Small Town and Rural authorities take a second round of information at the MIR stage. The reasons are not stated, but perhaps deliverability may be less complex (or perhaps more binary – ie. it will or won’t happen) in locations away from major urban areas.  

3.20 Question 5 sought responses on the importance of 14 types of information to understand a site’s deliverability.  The findings are:

• There were no major differences by area type in the importance of a location plan and information viability, ownership, physical constraints, land use, transport and access, policy compliance, public consultation, environmental, design or utilities. 
• The possibility of site contamination is more important to larger urban authorities; probably reflecting legacy land uses in former industrial locations. 
• Deficit funding and marketability are more important to Small Towns and Rural areas, less to Other Urban, and least so to Large Urban; probably reflecting a reverse hierarchy of (presumed) viability.   

3.21 Question 6 asked what supporting information is provided in site submissions. The full survey already demonstrates a substantial gap between what information planning authorities would find useful when allocating sites, and what is provided by promoters. By area type:

• There is no notable distinction by area in promoters’ provision of location plans or information on viability, ownership, contamination, deficit funding or marketability.
• Small Towns and Rural planning authorities receive less applicant information on physical constraints, utilities, land use, transport & access, public consultation, environmental constraints and policy compliance than Large or Other Urban authorities. 

3.22 The constraints on improving site assessment information (Question 7) are broadly similar by area, although more Small Town and Rural authorities report that planning authority resources and skills are the main constraint.

3.23 The desire for local decision-making is stronger among Small Town and Rural planning authorities; 73% would support additional guidance (Question 8) compared with 92% of Other Urban and 85% of Large Urban authorities.

Consultations

3.24 The survey reported above was largely a research exercise into how sites information is gathered and analysed, supplemented by some respondent views on the effectiveness of that process and how it might be improved.

3.25 The research project consultations built upon the survey by examining topics in more detail, taking into account the wide range of perspectives among those consulted via face-to-face meetings, an Expert Panel and a project Steering Group (consultees were listed in paragraphs 3.2 and 3.3). 

3.26 Consultees report that assessing deliverability can be challenging during the early stages of considering sites, although understanding could be significantly improved. Consultees pointed to SPP and the provision of an effective land supply; noting that the planning system can deliver a consenting process, but has only a “light touch” upon the delivery of development. 

3.27 The site information initially received from promoters typically requires to be supplemented. Repeat engagement between site promoters and planning authorities tends to improve information quality during the development planning process; it is noted here, though, that this iterative approach runs counter to an ‘upfront’ approach to site assessment and selection. 

3.28 The volume of sites promoted in response to a call for can reportedly be very high, from up to 100 through to 500 or more sites in very active market areas. Consultation on those sites is required with internal local authority departments and external agencies, each of which has their own resource priorities and pressures. Researching and understanding site deliverability is reportedly demanding and can require expert inputs. 

3.29 Given these potentially large numbers of site bids and resource pressures on all parties^[12], it was suggested by some consultees that the first trawl is not the appropriate point to seek large volumes of site information, as it is simply “the start of a process”. In one area for example, the first site sieve removes proposals with no delivery potential nor planning merit, then seeks further information on sites which are assessed as having some potential. In another areas though, a more extensive standard pro forma is completed to allow all sites to be initially cross-compared in a matrix, then short-listed. 

3.30 Consultees believe that slower development in recent years may reduce the numbers of new sites being promoted in future. Responding to market activity, some planning authorities are understood to be using their next LDPs to find more deliverable sites than their current batch of under-performing allocations.

3.31 Early identification of large future sites, particularly those with a major infrastructure requirement, was discussed positively. This may however be challenging in the context of seeking early evidence of effectiveness and deliverability; it was suggested that providing information for and managing larger site proposals incurs six-figure costs for promoters. One consultee suggested that very large sites could be part-delivered during an LDP period and part strategic reserve, to be drawn down as and when development performance is demonstrated.

3.32 Views on providing information on site viability varied. It is thought that a balance is required between simply making / seeking assertions that sites are viable (as some calls for sites currently), against incurring the high costs noted above when there may be only limited confidence in the site being awarded a development plan allocation. It was noted that viability can change, not only in response to markets but also through interventions such as Help to Buy. Consultees report that development viability can be challenged by all parties at MIR and Plan examination, and interrogated by development management teams at the planning application stage, using appropriate information and expertise. Some consultees noted that a site’s viability is a “snapshot in time” and may change. 

3.33 The vast majority of sites promoted are for housing; this can be in excess of 95% of bids received in response to a call for sites. To balance this process, which is led by major sites and housebuilders, planning authorities also encourage smaller developers, landowners and communities to promote and support site allocations. Consultees suggested that site assessments could take account of who is promoting the allocation, in order not to present “barriers to entry” which may lead to potentially attractive locations and sites being dismissed.

3.34 In respect of affordable housing, the relevant developers are thought likely to promote only sites which can be delivered. In weaker market areas, there is reportedly a structural change from private sector delivery of housing and other uses pre-2008, to a dependency upon the affordable housing providers and the Scottish Government’s current active programme. Local builders are reportedly acting as contractors for the delivery of that affordable housing in some areas, rather than taking private development market risk. 

3.35 The question of what is ‘effective demand’ was discussed. As noted in the online survey, some planning authorities have experience of sites and locations being rejected as unviable by major developers then successfully developed by local builders. ‘Small sites’ policies can help to address this by supporting local markets and potentially circumventing the stranded / stalled site phenomenon, where major infrastructure is delayed or is not provided. Self-build and custom-build housing site options are also being promoted, although these are not always welcomed by the development community.

3.36 In rural areas, where sites are slower to develop and may have no developer promoting them, a more relaxed approach to site allocation is reported to be required. Some areas do attract site promotion by individuals, but those parties may not have the experience to move through the development plan process – the system was described as “impenetrable” to anyone other than experts, and that communities for example “couldn’t answer” typical call for sites questions. 

3.37 Development industry “reticence” to promote locations which may have market potential, but have no recent track record was promoted. One response noted was to identify broad land uses across large urban areas, thus directing growth and giving comfort to smaller potential sites without these requiring to be individually promoted through the call for sites. 

3.38 These targeted approaches to site allocation were described as being required in locations where there may be willing landowners and an end market for homes, but currently no willing developer^[13] promoting a site. 

3.39 The question of whether better early information might have helped stranded or stalled sites address delivery challenges was discussed. Those tend to be the sites with major impacts, for examples roads and schools investments, which have typically failed to overcome their funding challenges. Working through the deliverability of those existing allocations also forms part of the development planning process for all parties. 

3.40 The role of spatial planning was discussed. This was in the context of whether planning authorities are thought to be: searching for the best sites within preferred areas, say from the Strategic Development Plan direction, settlement patterns and infrastructure capacity; or are ‘takers’ of sites promoted by the market. Responses were mixed. Some areas are believed to apply “good planning” to identify or plan spatially around site options, but weaker market areas can end up with a very limited choice, where if deliverability is inimizing then only the “best promoted” sites with major developers attached are able to progress. 

3.41 In this context of potentially weak spatial planning in some areas, the project Steering Group supported the view that development planning should be mainly proactive in identifying preferred locations for development and planning for their infrastructure in order to create places and overcome constraints, rather than mainly being reactive to site promotion. 

3.42 Aligning with this spatial planning approach, some planning authorities reportedly focus more on ‘place’ at the development planning stage, then more so on individual sites during development management. Some authorities are further noted as inimizing and supporting longer term options such as patient landowners, trusts, community groups, economic development and regeneration organisations and sites. 

3.43 The potential for double-handling of information at both development planning and development management stages was discussed as a cost and risk for all parties. Electronic management of information around a site’s planning history and progress does appear to be inimizing double-handling, although information can change over time and is amplified as more details emerge about sites, infrastructure and development proposals. Formal joint working between development planning and development management in planning teams reportedly also helps to carry site information through the planning process. 

3.44 In terms of infrastructure, it was suggested that some national agencies have limited involvement with sites, other than requesting costs if proposals impact their assets. Site-specific engagement with agencies often comes much later and identifies specific barriers and costs which may not have been obvious at the high level development planning and Action Programming stages.

3.45 Community engagement typically happens around the MIR rather than as part of the initial sites trawl, although some planning authorities also use earlier community-based events to consult on options. Community Council representatives also participate in Area Planning Committee meetings in one planning authority. Community engagement at MIR can reportedly consider information on facilities, routes, development formats and other local matters. The Place Standard has been used as a community consultation tool around promoted sites. There is no experience among the consultees of communities themselves acting as site promoters (rather than as objectors to proposals). Looking beyond planning reform though, it was suggested that the proposed Local Place Plans could potentially be produced in consultation with communities during the sites allocation process.

3.46 The MIR process is reportedly useful in demonstrating site effectiveness and deliverability. This is because site promoters “call each others’ bluff” and thereby bring scrutiny and additional information to the process. Late submissions to this process can be a challenge, particularly where a site has been significantly enhanced – eg. attracted an active developer – since the call for sites assessment previously filtered it out. On the other hand though, consultees feel that this means a high bar has been set for allocation and site promoters are trying to meet it. The current time period between MIR and Proposed Plan then allows an opportunity for a further, considered review. 

3.47 The link with the LDP Action Programme is reportedly weak at the call for sites stage. Infrastructure capacity may be broadly understood, but investment options can “rumble on” as “good intentions” rather than firm commitments. Agencies are believed to be “seen not to object” at LDP stage, while not necessarily having site-specific solutions, particularly where there are cumulative impacts. The later crystalisation of constraints and costs can then reportedly affect viability and deliverability. Programming around individual sites can sometimes help to keep the process moving, rather than becoming stuck at the frontloading stage. Engagement with agencies is sometimes via site promoters about their specific sites, and at other times by planning authorities in the process of developing their Action Programmes. Infrastructure providers can be “inundated” with site enquiries at a point where they may not (yet) have a full understanding of the spatial planning strategy and emerging development locations. A ‘circular benefit’ can be created where these organisations are engaged early in the development planning process and help to plan for growth.

3.48 Infrastructure impacts are reported as varying by land use type; housing impacts most upon schools; while industrial land uses have a highly uncertain impact upon roads and utilities, depending upon the actual activity. Alignment of local authority capital programmes for schools, local roads, community uses and so on is reportedly mixed, but is gradually becoming more embedded in Action Programmes. The need to embed local infrastructure delivery within City / Region Deals and into the National Planning Framework was noted. For smaller and rural areas though, it was cautioned that the infrastructure-and-development delivery programming being pursued in principal cities is “abnormal” in the wider Scottish land and development industry. 

3.49 The credibility of information provided in response to calls for sites was questioned, not only by planning authorities but also by the development industry. Much of the information requested can be self-selecting ‘yes/no’, brief comments, or optional (see the information gaps at Questions 5 and 6 above). This invites positive or partial (in both senses) responses, as a bid to stay in the “land game”.  Information provided in this manner is thought unlikely to be particularly helpful in assessing site deliverability. Partial responses are not necessarily short and may contain numerous documents; this is countered in one area by providing a detailed sites information form and not accepting supplementary information.