Chamber and committees

Resource is clearly an issue for the planning system, but that is not the blockage that is stopping planning permission from being granted.

We have some analysis on stalled sites. The first cohort of sites were identified by industry as sites where blockages were stopping things from happening. The next steps on that involve working through the 164,000 units to understand the reasons for those blockages. Some of the plots will have longer-term build-out plans, so there are then questions about whether we can accelerate some of those and bring them forward. For some sites, commercial aspects might have changed since planning permission was granted and the development might not make economic sense in the way that it used to. There is a whole series of reasons why building is not happening. Frankly, some applications will have been speculative, but if we are using resources within the planning system to give planning permission to units that will never be built, or that are unlikely to be built, that is a separate question that we need to address.

In terms of stalled sites, 20,000 units were looked at, which we distilled to about 11,000 units over a number of sites. Most of those sites are fairly large, comprising some 2,000 units, and are spread around the country. There are some in Aberdeenshire, Fife, Ayrshire and elsewhere. Understanding what the blockages are is a question of getting people around the table. Some of the issues relate to section 75 of the Town and Country Planning (Scotland) Act 1997 and education provision, some relate to transport, and some are key agency issues. For each specific issue, the planning hub team is pulling together the relevant parties. It is the first time that we have taken the approach of getting parties around the table in order to understand what the specific blockages are on specific sites and who needs to do what for things to move on.

It is work that will never conclude, because there will always be more to look at, but we will be able to give you an update as sites move through that process. There is a limit to how much we will say up front, because some of that information will be commercially sensitive, as it will include financial figures. However, as we get the sites unblocked, I will be happy to share the information.

It is a matter of fact that it is a figure that is a high-level estimate. It has come from adding the numbers from local authorities on what they have in their planning systems that has been given planning permission but has not yet been built out. Clearly, the number is dynamic, which I think is the point that the Statistics Authority is making. It is moving, because more units are being given permission and more units are being built on a weekly basis. I absolutely accept that it is a high-level estimate, but that does not take away from the fact that a significant number of units have permission but have not been built out.

We are always looking for ways to streamline processes. We work closely with Heads of Planning Scotland, the national planning improvement champion and others to do that, and that applies to local development plans as well as the planning system more generally.

I recognise that gate checks are there for a reason, which is to make sure that the plans that come through are robust. It is better to address issues with plans earlier in the process rather than later, when a lot more work could have been put into a plan but evidence is not in place or is missing or there are other reasons why the plan cannot be taken forward to completion.

At the moment, six planning authority plans have passed the gate check, and those plans are being further prepared off the back of that. Another two are at the gate check, and three have been sent back because of insufficient evidence. Work by the planning authorities is on-going to fill the gaps in the evidence.

I will let officials answer on the specifics in relation to authorities but, when there are issues because authorities are not clear or have misinterpreted what is required, it is important that there is a dialogue to resolve that. If we felt that it was worth putting in place guidance, we would do that, too.

We are watching the situation closely. From conversations with industry and others, I know that it is more of a challenge for some local authorities than others. I will let officials talk to the provisions that are in place to support the specific issue that you mentioned, but I will say that there is a pipeline of land in place across the country to enable development to take place.

The whole point behind NPF4 is that it is a plan-led system, so you agree up front where you will build and then you build there. Moving away from that takes us back to having speculative opportunities come forward in the middle of the process, which causes problems around the other factors that must be considered.

The planning system must be robust, and all the policies, including the biodiversity and woodland policies that we talked about earlier, and flooding issues, which I am sure that we will come on to talk about, need to be considered in the round. The whole point is that you get the plans laid down, you make sure that there is enough supply in place and then you move forward on that basis.

Fiona Simpson will talk about the specifics of addressing some of the challenges.

As with everything else that we have talked about, the letter was intended to bring clarity—in this case, it was to bring clarity to how policy 22, in particular, should be considered. The point that we have made throughout is that NPF4 has been laid out to cover all the different aspects and policies that need to be considered and determined in planning applications. However, if we see the need to give clarification because of how a policy has been implemented, we are very willing and keen to do so to ensure that expectations are more fully understood.

As I mentioned, we are also progressing earlier work in order to do audits of the planning functions at key agencies, including SEPA, to understand specifically how the interplay between what advice SEPA is offering and what the flood teams at planning authorities are looking at is being considered, to ensure that we get the balance right.

Clearly, flood risk is real. For lots of very good reasons, the last thing that anyone wants to do is build somewhere that will get flooded. We are gathering more information all the time about the risks associated with climate change, and the situation is deteriorating over time because of that challenge, which needs to be considered in the round. Getting the balance right is really important, but we are working with all those involved to ensure that we do that.

That is a knock-on effect of the determination that SEPA has made. It is important to recognise that SEPA will take a view, and the planning authority will make the decision. As I said earlier, things are changing, so areas that were not previously at risk of flooding might be now or in the future. On your specific point about individuals who have properties adjacent to land where planning permission has been refused on those grounds, that is outside the planning system’s scope.

First, in terms of the premise, nothing has changed on the timelines for local development plans—the deadline is May 2028. As I said, we are monitoring the situation to understand any risk, and we will work with planning authorities to make sure that they hit the deadline. That has not changed.

I do not know why you think that local place plans would not be included—there is provision for them to be included. If anything, if local development plans were taking longer, there would be even more scope for local place plans to be included, because there would be more time to do that. As I said, the requirement is for planning authorities to consider local place plans as part of the process.

We have deliberately set quite a low bar in relation to what needs to be in a local place plan. It does not need to be a professionally prepared document; it just needs to be an indication from the community of what is important to it. That gets taken into account as part of the local development plan process.

Any communities that are looking at this should be assured that their local place plan will be taken into account. There is support out there to work with communities on preparing and producing a local place plan. Does Andy Kinnaird want to comment?

It is a valid point that goes back to what we said earlier about the high-level estimate of 164,000 stalled sites, which is made up of all kinds of units, from very big sites that are not being built over a period of time because there are commercial issues, for example, right down to very small sites that have individual units. The team is carrying out initial stalled sites work to understand the issues across the country. We will start with the bigger sites and work our way down, because that will have the most impact most immediately. That work is on-going and we have seen the first cut of it. We want to understand the issues that are holding up those developments. We encourage local authorities to look at small sites, particularly in rural areas, to try to understand whether there is anything that they can do to help to secure the build-out of those units.