Development plan amendment regulations: consultation response summary

Question 15

Question 15A)

To what extent do you agree that an authority should be required to collate relevant evidence to inform the proposed amendment and prepare a Justification of Amendment Statement?

There were 43 responses to Question 15A, which have been set out by respondent type in Table 15 below.

Almost all respondents supported (a combined 93%) the requirement to collate evidence and prepare a Justification of Amendment Statement. There were two neutral responses and one planning authority who opposed this requirement.

Question 15B)

Where applicable, please give reasons for your answer.

34 respondents provided further comment at Question 15B.

Summary /Themes

All respondents from the key agency and other public sector and community and individuals sectors were supportive in their responses.

The themes that came through strongly from the supportive responses was primarily of transparency, as well as guidance, flexibility and resourcing. Several felt that a requirement for planning authorities to collate relevant evidence for a Justification of Amendment Statement was important to ensure confidence in the amendment, ensuring that amendments were robust and based on sound evidence.

Several responses emphasised the importance of having clear reasons for amendments, and that setting these out in a statement for the public and stakeholders would help them understand the rationale behind it. A few responses added that it would be helpful to have clear information on what should be included in the statement.

A respondent from the development sector who agreed with the proposed requirement made suggestions in relation to it what the statement should include. They suggested the regulations should require the Justification of Amendment Statement to take account of the applicable NPF; a statement confirming whether or not the planning authority considers that the proposed amendment would be compatible with the NPF, and a reasoned justification if the proposed amendment seeks to depart from the NPF or would otherwise not be compatible with the NPF. They suggested Scottish Ministers must also be consulted in this case. They stressed their view that these added requirements are essential to maintain an effective relationship between the NPF and LDPs.

The planning authority who responded 'Strongly Disagree' to Question 15A seemed to indicate otherwise in their response at 15B, stating that a local authority should have to present a reasoned justification for amendments with evidence including the results of engagement.