Places, people and planning: consultation on the future of the Scottish planning system

03 Building more homes and delivering infrastructure

We want Scotland's planning system to help deliver more high quality homes and create better places where people can live healthy lives and developers are inspired to invest.

Proposal 10

Being clear about how much housing land is required

Proposal 11

Closing the gap between planning consent and delivery of homes

Proposal 12

Releasing more 'development ready' land for housing

Proposal 13

Embedding an infrastructure first approach

Proposal 14

A more transparent approach to funding infrastructure

Proposal 15

Innovative infrastructure planning

3.1 - More must be done to support the delivery of the homes that people need, now and in the future. This is a high priority. While many factors are currently limiting the number of homes being built across Scotland some of the solutions need to come from the planning system. Planning can assist by ensuring enough land is available for development, but can go further by actively enabling development. Infrastructure has a critical role to play in supporting housing delivery.

3.2 - The benefits of housing development go beyond making sure that everyone has somewhere to call home. Health and improved quality of life is supported by well designed, functional places. Housing in the right places can help to sustain community facilities, contribute to the economy and support jobs in the construction sector. The need to deliver more homes is in all our interests.

3.3 - We agree with the independent panel that planning must move away from debating overly complicated housing figures and focus much more on enabling development. We must all adapt to different market circumstances if the development sector is to contribute to the wider outcomes communities need. Existing communities have a critical role to play in accepting that further development is necessary if we are to ensure that everyone has a home. Developers also need to work effectively with planning authorities and communities to achieve this.

Proposal 10: Being clear about how much housing land is required

3.4 - We believe that there is a need to change the way we plan for housing. We agree with the independent panel that there is too great a focus on debating precise numbers rather than delivering development and creating good quality places to live.

3.5 - We need to act now to resolve ongoing challenges in housing delivery. Changes in practice could have a more immediate impact than statutory amendments. We want to introduce a more strategic and aspirational approach to establishing the number of homes required at a higher level. By agreeing the amount of land required for housing much earlier in the plan preparation process, planning and housing authorities, developers and communities can move forward and focus on delivery.

National aspirations for housing development

3.6 - The independent panel called for housing targets to be set nationally. We are also aware that planning and housing authorities will need to continue to collaborate and engage with stakeholders locally, to make sure there is proper consideration of local circumstances and commitment to delivering on the targets which are agreed. National or regional targets within the National Planning Framework ( NPF) could provide some clarity, but would have little practical effect if it is not consistent with local and developer priorities and commitments to investment.

Glasgow Commonwealth Games Athletes' Village - Low Carbon Infrastructure

The Athletes' Village is a 35-hectare residential community now established in the East End of Glasgow. The 700 homes and 120-bed care home, as well as the adjacent Emirates Arena, are powered by a district heating system comprising a combined heat and power energy centre and 28km of pre-insulated pipes supplying heat and constant hot water. The system is approximately 30%-40% more efficient than conventional heating schemes, providing residents with substantial cost benefits. This system, alongside a Fabric First Approach to housing design as well as the use of solar PV panels, contributed to a 95% carbon reduction on 2007 levels. To ensure the site remains sustainable for years to come, the energy centre has been future-proofed to include capacity for an additional combined heat and power engine, boiler and thermal store. This will accommodate connection to further phases of housing development planned for the site. When fully operational it will also generate and export electricity to the national grid.

3.7 - Fundamentally, we want to improve the focus on delivery and quality of place-making but also provide greater clarity and confidence on planning for all those involved. To support this, we agree that the National Planning Framework ( NPF) should be clear on our national and regional aspirations for housing delivery, and for these aspirations to be used to guide and inform the way we plan for housing at the local level. The estimated range of homes required over a 10-year period could provide a clear picture of what we are working towards, but also be sufficiently flexible to allow for changing market circumstances.

3.8 - We have undertaken some initial work to explore how this could be achieved. The independent panel recommended that we strengthen the links between local authority housing strategies and local development plans. We have already made progress in reducing the debate around housing figures, by ensuring that the Housing Need and Demand Assessment ( HNDA), which provides the evidence base for land use planning and housing policy, is submitted to our Centre for Housing Market Analysis for appraisal as 'robust and credible'. This, together with the development of the HNDA Tool, is helping to reduce the cost and complexity of HNDAs, and limits the debate on numbers to an extent.

3.9 - Several changes could be explored further:

• The HNDA tool can be used to quickly derive housing estimates under a range of scenarios. These estimates could be produced on the basis of agreed policy assumptions so that the National Planning Framework ( NPF) provides a strategic steer on national and regional aspirations for housing.
• Providing more support to local authorities and certainty to developers by 'signing off' the number of homes that are needed at an early stage in the production of local development plans. This could be done either centrally, or through the early gatecheck that is proposed to form part of the examination process.
• Improving monitoring of housing land availability, including by making audit information more transparent through publication of a housing sites register online.

3.10 - Views on these options would be welcome. On the basis of the responses to the consultation, we will revisit policy and guidance on effective housing land and related guidance to housing managers.

Proposal 11: Closing the gap between planning consent and delivery of homes

3.11 - We are already taking steps to support housing delivery. Our More Homes Scotland approach supports an increase in the supply of homes across all tenures, and a commitment to deliver 50,000 affordable homes over the current parliamentary term. The approach includes more investment for housing, from support for the affordable housing target to a Rural Housing Fund and Housing Infrastructure Fund.

3.12 - To further support housing delivery, planning needs to play a different role in delivering good quality homes in the right locations. More attention needs to be given to delivery, including place making principles. Planners should be pro-actively involved in securing development on the ground rather than reacting to proposals for housing. Planning authorities should work with others to define where development should take place in an agreed plan, and secure commitments to its delivery from all relevant parties. They need to be clear on infrastructure requirements, its cost and how it will be financed.

3.13 - The development of housing can be complex, involving developer, market and financial confidence. The gap between the numbers of planning consents which are granted each year and the number of homes which are built needs to be closed.

Actively enabling development

3.14 - Sites which are not being progressed are not only lost opportunities, but undermine the purpose of the local development plan by adding to the pressure for land to be released elsewhere. A stronger focus on the local development plan delivery programme can go some way towards improving our understanding of what makes a development happen or not happen. In turn this can improve the capacity of planning authorities to make informed decisions when allocating land for housing in the plan and granting consent.

3.15 - Land allocated in development plans needs to be supported by appropriate evidence that it can be developed. More can also be achieved by having a sharper focus on delivery of development proposals at the application stage. We propose also requiring, as part of national standards on validation requirements, that all major applications for housing are accompanied by appropriate information on the development viability. This will help planning authorities to identify and address any delivery blockages. We recognise that there are some challenges, as well as benefits arising from this proposal. To ensure clarity and to avoid delay at validation stage, further guidance on this would be needed.

3.16 - If a site does not progress as predicted in the local development plan delivery programme or if there is insufficient evidence that an application is deliverable, a range of tools are already available to planning authorities so that they can manage the situation. Using existing land assembly powers, local authorities can enable development themselves, remove the allocation from the plan or bring forward alternative sites instead. We want to see more planning authorities and their partners intervening to unblock developments using these and other tools.

3.17 - It is currently unusual for a planning authority to take such steps. A change in direction is needed so that we can unlock housing sites for development, make sites available at a range of scales, and ensure that rates of house building increase. Rather than simply allocating land and waiting for development to commence, planning authorities should actively seek out new ways of delivering development where progress is slow. There is a need to increase choice in the housing market, and to support progressive local authorities who want to shape their area and drive development. This will complement delivery by the private sector and reduce over-reliance on others to find solutions.

3.18 - In moving to a more active delivery role, we have a significant opportunity to diversify housing provision to support the expansion of new and alternative delivery models so that we can deliver a greater choice and range of housing. This can include models such as custom and self-build (which already makes a significant contribution in rural and island areas), Build to Rent, Private Rented Sector ( PRS), and specialist provision such as supported homes for the elderly. Alternative models and the promotion of a broader range of sites through the development plan could be considered, together with more targeted use of publicly-owned land. Expanding how we deliver homes would also support small and medium-sized developers and expand capacity within the development industry if we can achieve greater rates of construction.

Planning and land reform

3.19 - Proposals that emerged from earlier work on land reform could be instrumental in helping planning to fulfil this role. We are determined to see more land across Scotland in community ownership and have set an ambitious target of reaching one million acres by 2020. We will continue to support and encourage local communities to take advantage of opportunities that are open to them in this area, including through the Scottish Land Fund which makes £10 million per year available for developing plans and buying the land itself. In some cases, communities themselves may choose to exercise their right to buy land to help deliver development. We are currently consulting on a Land Rights and Responsibility Statement. The vision states that 'A fair system of land rights and responsibilities should deliver greater public benefits and promote economic, social and cultural rights.'

3.20 - We want to see a clear, accessible, effective and efficient system of legislation and policy which allows for the compulsory acquisition and purchase of legal interests in land and property for the public benefit. We will support interim measures, such as amendments to guidance, ahead of changes to legislation. Although they will not form part of the Planning Bill, we will investigate proposals which give local authorities more confidence and tools to acquire land which is not being used as allocated within the development plan. We will also explore how best the intended Compulsory Sale Orders legislation could complement existing tools to tackle the problem of abandoned buildings and land, and support wider measures that aim to secure the productive use of vacant and derelict land.

3.21 - The responsibility for delivery should be shared, not just by local authorities and agencies but also by those who have control of the land. Ministers are committed to consult with stakeholders on whether a development land tax approach could help to tackle the issues associated with sites being held in the hope of improved market conditions. Such an approach would require sites to be released or a tax paid.

3.22 - Collectively, these proposals will play a critical role in helping to deliver more homes and tackling market failures. They will also help the planning system to enable development and achieve place making objectives.

Self-build - Maryhill, Glasgow

Glasgow City Council is bringing forward serviced plots for self-build as part of its housing strategy. The project will test the local appetite for self-build homes and offer an alternative option for those who want to stay living in the city. The small site, accommodating six plots, forms part of a wider regeneration area where a contemporary urban village is planned. If a design passport and code is followed, there is no need for self-builders to go through the formal planning process.

Proposal 12: Releasing more 'development ready' land for housing

3.23 - Our proposals for development planning aim to make plans more flexible but also stronger and more certain. We believe that longer-term planning, supported by zoning for housing, could help to achieve this. We are currently piloting the use of Simplified Planning Zones ( SPZs) for housing development. Within these areas, development can go ahead without the need for an application for planning consent, as long as it is in line with a clear and agreed scheme which sets out development parameters, design guidelines and other criteria, and environmental assessment requirements have been met.

3.24 - We believe greater use can be made of this type of approach (effectively a way of consenting masterplans) to support development. To encourage their use we want to broaden the use and scope of a zoned approach to housing by updating provisions for Simplified Planning Zones. The independent panel recommended SPZs be rebranded. We would like to invite views on this idea of creating these as 'Ready Planned' or 'Consented Development' zones. Where potential locations for these zones are identified in the development plan, community involvement could form an integral part of the process. An alternative approach for this could be for the local authority to put in place a general consent for key sites or areas they want to promote for development.

3.25 - We propose using the outcomes from the ongoing pilot work to identify how the statutory requirements and procedures can be made more flexible, to allow them to be introduced in a wider range of circumstances, to consider linkages with development planning, and to look at ways to speed up the preparation process. Figure 2 sets out the relevant procedures that could be updated.

3.26 - We recognise that preparing SPZs requires time and potentially financial support from planning authorities, with no planning application fee to follow. We want the development sector to be willing to frontload their investment and contribute to scheme preparation work, including masterplanning and assessments. As SPZs provide certainty about the concept of development earlier on in the process without going through the planning application process, they can offer an uplift in the value of the land and possibly an earlier return on investment.

3.27 - SPZs are often put in place through partnership involving the planning authority and developer. To strengthen this, we will consider how we can resource the procedures for delivering SPZs on a wider scale. We are aware some planning authorities have had reservations about SPZs due to concerns that without a planning consent to provide a framework for discussions it would be harder to access developer contributions. We will look at the use of conditions or unilateral obligations to secure greater certainty on delivery. We will also look at how the proposed new finance and funding mechanisms for an infrastructure first approach could support the use of SPZs.

3.28 - To continue to build momentum and experience in the meantime, we will continue to provide financial support to encourage additional SPZs for housing in the coming months.

Figure 2: Better use of zoning to support the long-term planning of housing

Preparation of SPZ schemes has parallels with preparing local development plans, with opportunities for engagement, a draft placed on deposit for representations and opportunities for modification and a Public Local Inquiry at the end of the process. However, the current legislative requirements predate the last planning reform, and we want to ensure the process is brought in line with this wider review. We propose:

• Encouraging the preparation of SPZs as an integral part of preparing the development plan, as recommended in the existing guidance. ¹²
• Promoting more inclusive community engagement such as charrettes informing SPZs.
• Removing the requirement for a Public Local Inquiry to be held at the end of the process of preparing a SPZ.
• Removing the blanket restriction for SPZs in conservation areas.
• Accompanying SPZs by a commitment to ensure that other consents supporting development will be managed by the planning authority drawing on the success of the planning protocol supporting Enterprise Areas.
• Including SPZs in the plan delivery programme.
• Examining the interface between plan and project level environmental assessment requirements, and scope for technical guidance to ensure a robust but proportionate approach is taken.

The Hillington Park Simplified Planning Zone

This award-winning SPZ Scheme was prepared in a partnership between Renfrewshire Council and Glasgow City Council, and MEPC Hillington Park (now Patrizia), who owns and manages the majority of the site. Initiated by the landowner, preliminary studies and a risk assessment were prepared by consultants instructed by the landowner to shape and inform the SPZ scheme. The scheme deals with the planning issues 'up front' and confirms what type of development, and how much, is allowed, providing greater certainty for developers and stakeholders. It removes the need for repetitive planning applications, covering the same range of planning issues, which will save time and cost for the existing organisations and new businesses looking to invest in the park. It also benefits the planning authorities by reducing the resources needed to manage development in this dynamic area. ^[16]

Proposal 13: Embedding an infrastructure first approach

3.29 - Good quality places have to function properly, and infrastructure plays a critical role in supporting this. Infrastructure can have a significant effect on the quality of a place, with new construction offering wider opportunities for improvements. We want infrastructure to help us build places that function properly so people have choices about how they move around, can access the facilities they need, and can live sustainable and healthy lives. Infrastructure planning, like housing development, should be recognised as key part of place making.

3.30 - We agree with the independent panel that infrastructure is the most significant challenge for planning at this time. It also presents a significant opportunity to support the delivery of the homes that we need. An infrastructure first approach to development should ensure that existing infrastructure capacity is properly understood, can help to identify where additional investment should be prioritised to enable future development, and can be achieved where delivery is co-ordinated. Better infrastructure planning can help to achieve efficiencies, build in long-term resilience and support innovation. We need to ensure that we understand and make best use of our existing capacity and make improvements to meet the needs of future generations.

National level co-ordination

3.31 - The independent panel proposed that a national infrastructure agency or working group be set up to better co-ordinate infrastructure delivery. An enhanced National Planning Framework ( NPF), which informs and is informed by, the Infrastructure Investment Plan, could play a key role in helping to prioritise future infrastructure spend.

3.32 - Our view is that this is not the right time to create a new, additional infrastructure agency at a national level. This would take time to establish, would need significant extra resourcing and, rather than bringing them closer together, may further distance infrastructure planning from spatial planning. We recognise, however, that all infrastructure providers should be behind our shared commitment to sustainable growth and development.

3.33 - Instead, to support our commitment to delivering 50,000 affordable homes this Parliamentary term and to address failings in the delivery of market housing, we propose establishing a national infrastructure and development delivery group, comprising appropriate representation from the Scottish Government and its agencies, public and private sector infrastructure providers and the Scottish Futures Trust. The group would:

• Ensure that knowledge about the key areas for growth and future development, as set out in the National Planning Framework ( NPF) and local development plans, is used to help prioritise our future infrastructure spending as reflected in the Infrastructure Investment Plan.
• Work with local government and the development industry to broker solutions and support delivery at key housing sites across Scotland.
• In the first instance, contribute to developing more detailed proposals for an infrastructure levy.
• Consider how developer contributions could work with wider funding and finance solutions, including city deals, to secure investment that fully supports regional priorities for growth.
• Encourage better co-ordination of development plan strategies and infrastructure capital investment plans and programmes. It is also essential that development plans better understand and reflect on infrastructure investment priorities in order to achieve an infrastructure first approach. The group could oversee and consider regional infrastructure audits, prepared by regional partnerships.

3.34 - This group would not need additional legislation to become established or deliver on the duties set out above.

Regional partnerships

3.35 - Stronger co-ordination in infrastructure planning and investment at a regional scale is particularly relevant to planning and delivering development. We agree with the independent panel that co-ordination should be significantly improved at this level. As set out in section 1, our proposals aim to ensure that planning is better placed to respond to the partnerships at the regional level that are already, and will continue to, emerge and develop.

3.36 - Our proposals to replace strategic development plans with regional partnership working would empower planners to advise on spatial priorities for infrastructure investment. At this scale, the infrastructure first approach would be supported where partnerships provide fuller and more reliable evidence for strategic decisions about investment. This could be achieved by a regional audit of infrastructure capacity which brings together, for example transport, schools, healthcare facilities, water, flooding, drainage, sewerage, energy, telecommunications, digital and green networks. The Strategic Transport Projects Review, carried out by Transport Scotland, should also work alongside spatial planning to form an essential part of strategic investment planning at both the regional and national scale.

3.37 - We have considered the independent panel's recommendation that infrastructure providers are given duties to support proposals set out in the development plan. While we agree with this in principle, we recognise that different corporate structures exist across the various infrastructure providers. A general duty could be introduced, but it would have little value if it cannot be clearly defined or if compliance with the duty is difficult to demonstrate or enforce. In addition, scope for such a duty to be imposed on some infrastructure providers will be limited by matters reserved to the UK Government.

3.38 - Improved communication and co-ordination is needed to strengthen awareness of, and commitment to, development plan delivery. In return, development plans must provide the clarity and certainty that is needed to support the case for investment in infrastructure. We will work with the key agencies and wider infrastructure providers, including those relating to digital and telecommunications and the energy networks, to see how we can achieve a greater level of commitment to development plans.

Dundee Waterfront - Regeneration - Infrastructure and Placemaking

This £1 billion transformation over 30 years comprises of 240 hectares split into five focused zones, and aims to enhance physical, economic and cultural assets. Led by infrastructure, the Central Waterfront zone has created ready-made development sites. Dated infrastructure and buildings have been removed to make way for a newly formed grid iron street pattern mixed-use extension to the city centre, which provides plots ready for development. These sites have been promoted in brochures showing the plot sizes and dates for site availability, whilst design and planning guidance is provided for developers, making the city investor ready. Beyond this, connecting the city with the River Tay, providing open space and other cultural assets means that this infrastructure first approach is carried out with placemaking at its heart.

Proposal 14: Creating a fairer and more transparent approach to funding infrastructure

3.39 - Planning and development already contributes significantly to funding any required expansion in infrastructure that is needed to deal with the effects of development. We agree with the independent panel that existing arrangements focusing on the use of Section 75 planning obligations need to be reconsidered, taking into account the delay and uncertainty associated with current arrangements. We will consider changes to clarify the scope of current provisions in Section 75.

3.40 - Current legislation allows those who enter into planning obligations to apply to modify or discharge the agreement, regardless of how recently these have been entered into and how fundamental these have been to supporting development delivery. We have seen increasing uncertainty about whether commitments to providing infrastructure will come forward in the longer term. We propose restricting the ability to modify and discharge terms of planning obligations introduced by the 2006 Planning Act so that commitments made when planning permission is granted are respected by those who entered into the obligation or who acquire the land.

3.41 - In addition, in the coming year we will carry out an intensive and closely targeted improvement project involving a small number of authorities to improve timescales for concluding Section 75 obligations. This will build on earlier work which developed the 10 good practice principles ^{[11, 12, 13]} , and will develop, test, measure and put in place changes which reduce the timescales for planning obligations. The aim is to share lessons learned more widely across the country.

Infrastructure levy

3.42 - Improvements to practice in Section 75 obligations will not fully close a gap in infrastructure funding which has emerged following the 2008 recession and the steep decline of housing delivery that arose at that time. In addition, it will not tackle challenges in securing collective contributions for strategic infrastructure. Following the recommendations of the independent panel, we commissioned research into a new development charging mechanism for Scotland. This could help to deliver strategic infrastructure that is needed to support development across a wider area and would help to build a more confident, infrastructure first approach to planning and development.

3.43 - We have considered past measures to capture land value uplift and the experience of implementing the Community Infrastructure Levy in England and Wales. We have also considered how a new charge mechanism could be developed which takes into account market differences across the country as this will affect the viability of securing or recouping infrastructure costs.

3.44 - Whilst the detailed design of such a mechanism will be challenging, we believe a solution can be found which strikes the right balance between simplicity and ability to respond to varying market circumstances. We propose that the Planning Bill includes an enabling power to introduce a new infrastructure levy for Scotland. Whilst we would develop and consult on more detailed proposals for this levy at a later stage, we propose that it should be based on the following key principles:

• It should be applied to most development types, with some potential exemptions.
• Permission to adopt and put in place a charging mechanism is granted by Ministers based on the submission of a business case prepared by the planning authority/authorities.
• The income from the charge should be collected locally.
• The fund will not replace national level infrastructure investment, as defined in the Infrastructure Investment Plan and National Planning Framework ( NPF).
• The fund will not replace site specific contributions which are needed to mitigate the impacts of individual developments not covered by the levy and secured through Section 75 planning obligations or other methods.

Proposal 15: Innovative infrastructure planning

3.45 - We are exploring wider opportunities for innovative infrastructure planning.

3.46 - An expert group involving all relevant parts of the Scottish Government, Heads of Planning Scotland, the Association of Directors of Education and the Scottish Futures Trust has been established. The group has considered the issues around funding and delivering new schools and is discussing how we can best address this in planning as well as in local authorities more widely. The work of this group will inform the need for future guidance as well as the more detailed proposals for an infrastructure levy as work progresses in the coming year.

3.47 - Land use and transport planning should be integrated to ensure that their impact on connectedness, accessibility, and 'active travel' (walking and cycling) are brought together and used to improve quality of place. Transport Scotland has begun a review of the National Transport Strategy which will inform the next Strategic Transport Projects Review and will consider transport governance, including the role of regional transport partnerships, as part of this. This should reflect the proposals for change set out here. In addition, we have confirmed that a review of the Strategic Transport Projects Review will be closely aligned with the review of National Planning Framework ( NPF) 3.

3.48 - Green infrastructure also has a critical role to play in supporting quality of life and sustaining the environment. The links between planning, place, environmental quality and health are very clear. Research, including work by the Glasgow Centre for Population Health underlines the importance of access to good quality greenspace and wider quality of place in helping to address inequalities and overcome longstanding patterns of poor health and vulnerability. This is a key aspect of the place standard and a priority for planning future development and regeneration. Green infrastructure also provides economic benefits, for example estimates value the benefits of the Central Scotland Green Network national development at around £6 billion over the 35 years to 2050. This should continue to be a key placemaking priority within development planning.

3.49 - The forthcoming consultations on the draft Energy Strategy will raise opportunities to plan strategically in locating new low carbon energy infrastructure and to target a roll out of energy efficiency measures. These will need to be considered by planning in the context of an infrastructure first approach to development.

3.50 - Section 72 of the Climate Change Act (2009) introduced a specific requirement for development plan policies to require new developments to install and operate low and zero-carbon generating technologies. An independent study recently found no evidence that there is any added value from this requirement - instead, building standards are driving down emissions. Whilst planning needs to be firmly committed to the principles of climate change mitigation and adaptation, this review provides an opportunity to streamline procedures that have not demonstrated added value and focus on where we can most benefit action on climate change, key to this being the location of development. We are therefore seeking views on whether to retain the current legislative requirements for these technology centred policies, or remove them.

3.51 - We are liaising closely with the Scottish Government Digital Directorate to ensure that any proposals for change support wider government ambitions on digital connectivity (broadband and mobile coverage). Opportunities include extending permitted development rights and continuing to provide strong planning policy support for the development of infrastructure networks.

Building more homes and delivering infrastructure - consultation questions

Key question

C: Will these proposals help to deliver more homes and the infrastructure we need? Please explain your answer.

Optional technical questions

17. Do you agree with the proposed improvements to defining how much housing land should be allocated in the development plan?

18. Should there be a requirement to provide evidence on the viability of major housing developments as part of information required to validate a planning application?

19. Do you agree that planning can help to diversify the ways we deliver homes? 19(a) What practical tools can be used to achieve this?

20. What are your views on greater use of zoning to support housing delivery? 20(a) How can the procedures for Simplified Planning Zones be improved to allow for their wider use in Scotland? 20(b) What needs to be done to help resource them?

21. Do you agree that rather than introducing a new infrastructure agency, improved national co-ordination of development and infrastructure delivery in the shorter term would be more effective?

22. Would the proposed arrangements for regional partnership working support better infrastructure planning and delivery? 22(a) What actions or duties at this scale would help?

23. Should the ability to modify or discharge Section 75 planning obligations (Section 75A) be restricted?

24. Do you agree that future legislation should include new powers for an infrastructure levy? If so, 24(a) at what scale should it be applied? 24(b) to what type of development should it apply? 24(c) who should be responsible for administering it? 24(d) what type of infrastructure should it be used for? 24(e) If not, please explain why.

25. Do you agree that Section 3F of the Town and Country Planning (Scotland) Act 1997, as introduced by Section 72 of the Climate Change (Scotland) Act 2009, should be removed?