Development plan amendment regulations: consultation response summary

Question 2

Question 2A)

In cases where amendments would require changes to half or more of the contents of the NPF, to what extent do you agree that a full review of the NPF would be required?

There were 46 responses to Question 2A, which have been set out by respondent type in Table 2 below.

Most (a combined 73.9%) of those who answered question 2A were supportive of the proposed criteria which would trigger a full review of the NPF, with a few neutral responses. However, some opposed this proposed trigger. Support was indicated by all those in community & individuals, while within the other set groups views were more varied with some disagreement from respondents in each.

Question 2B)

Where applicable, please give reasons for your answer.

37 respondents provided further comment at Question 2B.

Summary /Themes

Most of the respondents were supportive of the principle of having a set threshold for what would trigger a full review of NPF, acknowledging that it is required by the Planning (Scotland) Act 2019. However, there was questions raised across the responses, including from those who were supportive, as to how this threshold is determined in practice.

Some common themes identified related to concerns over determining a suitable threshold included a need for clarity, guidance on how this process would work and resourcing.

Some responses deemed that the numerical threshold for review proposed to be inappropriate. There were mixed views on the correct numerical level to be set – a few responses called for a lower threshold, whilst others responded that a lower threshold would put strain on resources. Some responses stated that this approach did not account for the weight of individual policies in NPF, where amendments could be made that were still significant but would fall below the trigger.

Another common concern raised was that of the cumulative impact of amendments, and uncertainty was reflected in these comments. Some shared the view that the proposed quantitative trigger would not take this into account. This issue was raised in several planning authority responses, as well as from the professional representative body and key agency sectors.

One planning authority suggested introducing a different bar or threshold for amending national policies and national developments, stating that this is likely to be done in combination anyway, while there were a few responses which called on the Scottish Government to issue a regular statement on amendments and the impacts of these.