Development plan amendment regulations: consultation response summary

Question 1

Question 1A)

To what extent do you agree that it is appropriate to adopt a broad and high-level approach as to when a full review of the NPF is required?

There were 46 responses to Question 1A, which have been set out by respondent type in Table 1 below.

Almost all (a combined 84.8%) of those who answered question 1A were supportive of the proposed approach of adopting a broad and high-level approach as to when a full review of the NPF is required, while some disagreed and a few were neutral on the proposal. All of the Planning Authorities who responded to this question indicated their support.

Question 1B)

Where applicable, please give reasons for your answer.

38 respondents provided further comment at Question 1B.

Summary /Themes

The key themes identified throughout all responses to question 1B were around resourcing, transparency, flexibility and a few calls for further guidance.

Most of the respondents supported a high-level approach as to when a review of NPF4 would be required is appropriate, with the reasons cited ranging from the confidence this gives to the planning system, to the resource implications of a full review. This included support from every planning authority, while most of the key agencies and other public sector organisations who responded were also supportive.

All supporting responses broadly echoed the intent of the proposal, that the NPF should be established and consistent to enable confidence in the planning system over the long term, whilst acknowledging the need to have an appropriate mechanism to amend where appropriate. There was also a strong appreciation of the resource implications a full review would have on both the Scottish Government and stakeholders.

There were some who opposed the proposal, however there was no consistent issue arising across those responses. The most detailed concern was over the approach to attributing a quantitative value to that which would be considered a significant change.

A common discussion point arising throughout the comments regardless of opinion was around what a 'significant change' to NPF takes into account and how that can be applied in regulation. This issue is raised in various questions throughout the consultation, and responses range from wishing for guidance to clarify this, a change in approach and questions about the cumulative impact of any amendments over time.

Similarly, across all types of responses, it was acknowledged that minor administrative changes to the NPF should not require a full review.

Along with calls for various uncertainties to be clarified in guidance, one response suggested that the Scottish Government should be required to publish an annual statement regarding amendments to the NPF. They suggested such a statement might offer the opportunity to set out future amendments proposed for the near future in order to aid in transparency.