Planning – 2025 priorities: Ministerial and Chief Planner letter - January 2025

29 January 2025

Dear colleagues

Happy new year to you and your teams. This is an opportune time to take stock of achievements over the last year and to look ahead to priorities for planning in 2025.

We are at a critical point in our country’s development, and this Government is determined to bring about positive change and support investment in our future. More affordable homes are urgently required in both our urban and rural areas, and as we transition to net zero we need to put in place new infrastructure across Scotland.

We are fully aware that planning has not created these challenges – but we also believe it can be a key part of the solution.

National Planning Framework 4 (NPF4) sets out important tests for development proposals given its strong commitment to tackling the climate and nature crises and the pressing need to future-proof our places. It is also our clear expectation that where development has been well-planned and is supported by the development plan, all those involved must work hard to actively help make it happen.

In the year ahead, we would urge all planning authorities to continue to demonstrate this by positively facilitating development and investment in their areas. We will do all we can to help make this happen, but will continue to depend on your leadership.

Housing emergency

In November 2024 we published the Planning and the Housing Emergency Delivery Plan which set out a range of priority actions. We will be focused on progressing these actions, at pace, along with our wider business plan commitments, over the coming months.

The draft budget includes additional funding which will be used to support delivery of our priorities, including the Housing Planning Hub. This will build on the early work led by the Improvement Service to develop a Hydrogen Planning Hub. We are developing a fuller plan for this, so we can better support planning authorities in their crucial work to address the housing emergency, as well as the transition to net zero.

Over the coming weeks we will continue to have a strong and immediate focus on priorities arising from work to identify and address housing sites that have stalled. The work has demonstrated that there are many reasons for this, both before and after planning consent has been granted, including decision-making timescales, funding issues, construction costs and viability, the continuing bedding in of national planning policies, infrastructure delivery and the need to maintain strong communication and a shared sense of urgency with all relevant parties.

We are very grateful to all Heads of Planning for meeting with us over the last few weeks, often at short notice, to discuss the stalled sites that have been reported to us in work undertaken by members of the Short Life Working Group. Our partnership work on this is progressing well and at a meeting on 17 January we worked through the list of sites in detail and identified a number of actions for a range of parties to progress. Some of our proposed interventions are site specific whilst others are more strategic actions which could help to move a number of sites forward. We will keep you updated on progress over the coming weeks and will be in touch with individual authorities to seek your advice and involvement as appropriate. Your continuing shared commitment to this work, and the leadership you have already shown, is really appreciated.

Also on housing, on 20 January, we published updated guidance on Housing Land Audits. It promotes a consistent approach across Scotland to enable improved monitoring locally and nationally of the housing pipeline and its progress through the planning system. The guidance has been prepared following engagement across a range of interested stakeholders and whilst as much consensus as possible has been sought, not everyone will agree on all aspects. It is however important that we have reliable, consistent data to drive the system – to inform decisions, support delivery and monitor the role planning plays in the housing emergency. 

As well as taking actions to address all of these challenges, we recognise the need for continued work to improve planning authority resource and capacity. We would reiterate our expectation that the recently increased planning fee income is re-invested by local authorities in their planning service, given the central role of planning in delivering on a wide range of cross-cutting priorities.

We are also preparing to launch a significant future planners graduate programme to play our part in securing a future pipeline of planners. The programme will combine work-placed learning and experience with post-graduate university education. We will be offering a fixed-term two year appointment within Scottish Government together with payment of post-graduate university fees. Further details about the programme will launch soon and we would ask all partners to help us promote the opportunity, particularly to those who may not have otherwise looked towards planning as a career opportunity.

Policy 22 Flood risk and water management

The application of NPF4 policy 22 is continuing to generate debate, including matters raised with us through our work on stalled housing sites. We have been considering this carefully with planning authorities and SEPA, to support implementation in practice, and additionally we have been engaging with representatives of the development sector on this policy. We are actively progressing this collaboration, engaging further with all parties to explore the issues in more detail. We will say more on this important work as soon as we can.

Battery Energy Storage Systems

We are aware of calls for guidance and further advice on Battery Energy Storage Systems (BESS). Last month the UK Government published its Clean Power 2030 Action Plan which recognises the role that short duration battery storage will play in a net zero energy system and provides details on future locational and capacity requirements for battery storage. The National Energy System Operator (NESO) Future Energy Scenarios model the projected amount of (short duration) battery storage that could be required in the GB system and Scotland. The Scottish Government uses modelling evidence such as this to explore the future storage capacity that could be required in Scotland and GB under different decarbonisation pathways. We are currently considering the GB wide measures proposed in the UK Government’s Clean Power 2030 Action Plan to understand the impact this might have on future battery storage projects in Scotland.

The Scottish Government will convene a roundtable discussion on BESS, to include Heads of Planning Scotland, and we will share further information on this in due course.

Vertical farming

We would like to hear from any planning authorities who have, or anticipate dealing with any planning applications for vertical farming. This has significant potential to contribute to food security but our collective understanding of the impacts and their mitigation is limited. If there are applications that we can learn from in this respect, we would be happy to co-ordinate a shared learning event on the topic.

Digital planning

We continue to collaborate with our colleagues in the Digital Directorate on our digital priorities.

We have had the successful delivery and roll out of Phase 1 of the Fee Calculator update for Planning, which was completed in time for the December fee increase. Phase 2, will be focusing on Building Standards, is currently in progress and scheduled for release in April.

Digital colleagues are also nearing the completion of development for a new Planning and Building Standards Pay solution, in collaboration with three Private Beta partners: Loch Lomond & Trossachs NPA, Stirling Council, and Glasgow City Council. The solution, expected to go live with the first Private Beta partner by late February 2025, offers improved functionality for both customers and planning authorities, including additional payment options and enhanced refund and reconciliation processes. Additionally, Digital colleagues are planning the rollout for other planning authority partners and will soon begin gathering information to inform these plans.

Early work on the Apply business case has started, involving the review and update of materials prepared prior to the Digital Planning Programme’s pause. Over the coming months, Digital colleagues will be engaging with stakeholders to identify key priorities for initial delivery. The goal is to secure funding to develop a new Apply service in FY2025/26, subject to the completion of the business case and further approvals.

Local development planning

The updated NPF4 Delivery Programme (October 2024) provides an overview of the progress of new local development plans (LDPs) and reinforces Ministers’ expectation that a full suite of new style LDPs will be in place across Scotland by May 2028. We will continue to work closely with planning authorities to help enable this. 

We have bought together authorities that have progressed through the Evidence Report stage to share experience and learn lessons. As you will be aware our LDP Guidance sets a key expectation that LDPs are delivery-focused. So we are preparing for a similar session on delivery with a focus on Delivery Programmes that support new LDPs.  Meanwhile, by 31 March 2025, Scottish Ministers expect all planning authorities to review their action programmes for constituted LDPs and to update and publish them as delivery programmes. This was set out in a letter of June 2024.

Masterplan Consent Areas (MCAs)

The legal provisions allowing authorities to prepare Masterplan Consent Area schemes came into force on 5 December. We have published supporting guidance and will also issue a new Notification Direction and accompanying circular that will ensure the same notification triggers apply to both planning applications and MCA schemes, providing a consistent level of scrutiny.

In our Programme for Government we committed to support early adopters of MCAs, supporting the delivery of major projects, including national developments, Green Freeports, and green data centres. We are excited to be entering the delivery phase for MCAs, and have met with the first of the early adopter planning authorities. We also see potential for MCAs to be used to take action to tackle the housing emergency, and will be discussing with the new provisions with industry later in January. Planning authorities may wish to work collaboratively with potential developers and investors in the establishment of MCAs to support delivery.

Keeping in touch

Please sign up to our e-alerts or follow us on X @ScotGovPlanning or Linked-in to receive progress updates on all our workstreams.

In the coming weeks, look out for the following announcements:

• launch of the future planners programme to invest in new talent
• publication of the Planning Infrastructure and Place Advisory Group Annual Report
• publication of the Notification Direction and Circular
• launch of a co-ordinated skills and recruitment drive

Please also note recent publications:

• Compulsory Purchase Reform Progress Report
• Planning Fees Circular 3/2024
• guidance on effective community engagement in local development planning
• responses overview of the Infrastructure levy for Scotland discussion paper
• Blog on NPF4 Policy 16 Quality Homes – Statements of Community Benefit
• Blog on how permitted development rights can help address the housing emergency – comments invited by 14 February
• Minutes of the meeting of the High Level Group on Planning Performance, December 2024

Thank you once more for your continuing commitment to ensuring that our planning system helps to make Scotland the best place to invest. We look forward to working with you on our delivery priorities throughout the year ahead.

Yours faithfully

 

Fiona Simpson
Chief Planner

Ivan McKee MSP
Minister for Public Finance