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Site assessment methodology - Engagement version

Top­ic: Site assess­ment methodology

Engage­ment ver­sion – August 2025

Require­ments addressed in this section

Table 1 Inform­a­tion required by the Town and Coun­try Plan­ning (Scot­land) Act 1997, as amended, regard­ing the issue addressed in this section.

Sec­tionRequire­ment
Sec­tion 15(5)(a)The prin­cip­al phys­ic­al, cul­tur­al, eco­nom­ic, social, built her­it­age and envir­on­ment­al char­ac­ter­ist­ics of the district.
Sec­tion 15(5)(b)The prin­cip­al pur­poses for which the land is used.
Sec­tion 15(5)(ca)The hous­ing needs of the pop­u­la­tion of the area, includ­ing, in par­tic­u­lar, the needs of per­sons under­tak­ing fur­ther and high­er edu­ca­tion, older people and dis­abled people.
Sec­tion 15(5)(cb)The avail­ab­il­ity of land in the dis­trict for hous­ing, includ­ing for older people and dis­abled people.
Sec­tion 15(5) (cc)The desirab­il­ity of alloc­at­ing land for the pur­poses of resettlement.
Sec­tion 15(5)(cd)The health needs of the pop­u­la­tion of the dis­trict and the likely effects of devel­op­ment and use of land on those health needs.
Sec­tion 15(5) (ce)The edu­ca­tion needs of the pop­u­la­tion of the dis­trict and the likely effects of devel­op­ment and use of land on those edu­ca­tion needs.
Sec­tion 15(5) (cf)The extent to which there are rur­al areas with­in the dis­trict in rela­tion to which there has been a sub­stan­tial decline in population.
Sec­tion 4ZB(2)In exer­cising their func­tions of pre­par­ing, revis­ing or amend­ing a loc­al devel­op­ment plan, a plan­ning author­ity must have regard to their adop­ted region­al spa­tial strategy and any loc­al hous­ing strategy.
Sec­tion 264AIn the exer­cise, with respect to any land in a Nation­al Park, of any power under the plan­ning Acts, spe­cial atten­tion shall be paid to the desirab­il­ity of exer­cising the power con­sist­ently with the adop­ted Nation­al Park Plan.

Links to evidence

Sum­mary of evidence

Policy con­text

Nation­al Park (Scot­land) Act 2000

The Nation­al Park has four dis­tinct aims as set out in The Nation­al Parks (Scot­land) Act 2000):

  • To con­serve and enhance the nat­ur­al and cul­tur­al her­it­age of the area.
  • To pro­mote sus­tain­able use of the nat­ur­al resources of the area.
  • To pro­mote under­stand­ing and enjoy­ment (includ­ing enjoy­ment in the form of recre­ation) of the spe­cial qual­it­ies of the area by the public.
  • To pro­mote sus­tain­able eco­nom­ic and social devel­op­ment of the area’s communities.

These aims are to be pur­sued col­lect­ively. How­ever, if there is con­flict between the first aim and any of the oth­ers, great­er weight is giv­en to the first aim (as set out in Sec­tion 9(6) of the 2000 Act). This helps ensure con­ser­va­tion of the nat­ur­al and cul­tur­al her­it­age under­pins the eco­nom­ic, social and recre­ation value of the Cairngorms Nation­al Park. This approach is embed­ded in the Nation­al Park Part­ner­ship Plan and all oth­er decision-mak­ing tools, includ­ing the Loc­al Devel­op­ment Plan, adop­ted by the Park Authority.

The Deliv­er­ab­il­ity of Site Alloc­a­tions in Loc­al Devel­op­ment Plans 2020

Pub­lished in Feb­ru­ary 2020 by the Scot­tish Gov­ern­ment, the doc­u­ment sum­mar­ises a sur­vey of the 32 Scot­tish loc­al plan­ning author­it­ies and two nation­al parks. It explores the types of inform­a­tion provided by site pro­moters to demon­strate a devel­op­ment site’s deliv­er­ab­il­ity and how that inform­a­tion is used by plan­ning author­it­ies. The research and report was pre­pared by Ryden LLP, with assist­ance from Neil Col­lar of Brod­ies LLP.

It con­cludes that the focus of site assess­ment, at that time, was on the ini­tial deliv­er­ab­il­ity of devel­op­ment land through assess­ment of con­straints, and not upon the sub­sequent deliv­er­ab­il­ity of development.

It iden­ti­fied ​‘a major and con­sist­ent gap’ between site assess­ment inform­a­tion require­ments and the inform­a­tion typ­ic­ally provided by site pro­moters. It noted that inform­a­tion on phys­ic­al con­straints is ​‘usu­ally’ or ​‘sel­dom’ provided, and mar­ket inform­a­tion ​‘sel­dom’. It found that small towns and rur­al plan­ning author­it­ies receive less applic­ant inform­a­tion on site con­straints than oth­er authorities.

It found that site assess­ments by plan­ning author­it­ies share sim­il­ar cri­ter­ia, but the sieve order and weight­ing – by mar­ket factors, phys­ic­al capacity/​constraints, or spa­tial plan pri­or­it­ies – are not con­sist­ent, and could poten­tially influ­ence the short-list­ing and thus the alloc­a­tion of sites. In addi­tion, it noted that weak­er mar­ket areas can end up with a very lim­ited choice of sites, so that the ​“best pro­moted” sites are favoured.

The report advises that the concept of viab­il­ity with­in deliv­er­ab­il­ity is val­id, but its applic­a­tion must be treated with cau­tion. It high­lights that many mar­ket sec­tors and loc­a­tions in Scot­land will struggle to fully fund all land assembly, site works, infra­struc­ture, policy require­ments and devel­op­ment on a ​‘day one’ assess­ment and that seek­ing fund­ing solu­tions and value engin­eer­ing dur­ing and post-alloc­a­tion are nor­mal activities.

It advises that the site alloc­a­tion pro­cess should embed mar­ket real­it­ies but should not inad­vert­ently place these ahead of spa­tial plan­ning con­sid­er­a­tions. It advises that this will be par­tic­u­larly import­ant as action / deliv­ery pro­grammes are bound more tightly into the pro­cess of land releases.

The research pro­poses a pro­por­tion­ate frame­work for assess­ing the deliv­er­ab­il­ity of site alloc­a­tions. It seeks to improve con­fid­ence in deliv­er­ab­il­ity across dif­fer­ent site types, uses, geo­graph­ies, and through the plan­ning sys­tem from loc­al devel­op­ment plan alloc­a­tion onwards.

It pro­poses a staged-and-scaled site assess­ment which applies as a site pro­gresses through the plan­ning sys­tem and is pro­por­tion­ate to dif­fer­ent sites. This is illus­trated in Table 2.

Table 2 Staged-and-scaled sites assess­ment (Fig­ure 1 of the deliv­er­ab­il­ity of site alloc­a­tions in loc­al devel­op­ment plans report). Note that the ​‘future approach’ iden­ti­fied in this dia­gram dif­fers from the approach set out Scot­tish Government’s Loc­al Devel­op­ment Plan­ning Guid­ance and The Town and Coun­try Plan­ning (Devel­op­ment Plan­ning) (Scot­land) Reg­u­la­tions 2023.

Cur­rent approach: Calls for Sites → Main Issues Report → Pro­posed Plan → Loc­al Devel­op­ment Plan

Future approach: Call for Sites and spa­tial plan → Gat­echeck → Loc­al Devel­op­ment Plan

Stage 1Stage 1 inform­a­tionStages 1 and 2 information
Stage 1 Arrow Stage 2
Loc­al, small, early, rur­al, pass­ive / patient sitesMajor sitesStra­tegic sites: high impact, com­plex delivery

The first stage is inten­ded to provide suf­fi­cient inform­a­tion to con­duct a sieve of sites, includ­ing sites sub­mit­ted through a call for sites, exist­ing alloc­a­tions and unbuilt sites with plan­ning per­mis­sion. It would include site inform­a­tion, land use pro­pos­als, descrip­tions and dis­tances to facil­it­ies as well as an ini­tial indic­a­tion of issues relat­ing to nat­ur­al her­it­age and the envir­on­ment, his­tor­ic envir­on­ment or oth­er poten­tial con­straints. This first sieve would also be sub­ject to a spa­tial plan­ning approach to determ­ine wheth­er the site would be in broad accord­ance with the emer­ging loc­al devel­op­ment plan.

The report high­lights that defer­ring or demot­ing spa­tial plan­ning con­sid­er­a­tions dur­ing the site alloc­a­tion pro­cess risks skew­ing devel­op­ment plan­ning towards a more mar­ket-led pro­cess, how­ever it does recog­nise that viab­il­ity and fund­ing are the lynch­pin of deliv­er­ab­il­ity, when the site is accept­able in broad policy terms, and there­fore stage 1 should con­sider wheth­er there is:

  • A will­ing landowner.
  • A will­ing developer or a note of mar­ket potential.
  • Aware­ness of policy require­ments and the infra­struc­ture context.
  • Con­firm­a­tion that, in these con­texts, the site is believed to be viable (or if not that there is a poten­tial defi­cit fund­ing solution).

Stage 1 will yield three types of outcomes:

  • Sites not suit­able for devel­op­ment plan allocation.
  • Sites suit­able for alloc­a­tion without fur­ther inform­a­tion being sought. In the interest of trans­par­ency and best inform­a­tion there may some minor fur­ther dia­logue with pro­moters or oth­er organ­isa­tions. These sites could pro­ceed straight to pro­posed allocation.
  • Sites where fur­ther inform­a­tion is required via a Stage 2 assessment.

Stage 2 is inten­ded for major sites (great­er than 50 houses / 2 hec­tares) which are being pro­moted for devel­op­ment plan alloc­a­tion. While stage 1 seeks inform­a­tion and land pro­moter aware­ness of factors affect­ing deliv­er­ab­il­ity, stage 2 seeks evid­ence. This is likely to include require­ments for lay­out plans, devel­op­ment mix and phas­ing, com­munity engage­ment and site con­di­tions. Evid­ence of devel­op­ment viab­il­ity and tar­get mar­kets would be required for hous­ing uses and tar­get mar­kets for employ­ment and com­mer­cial uses.

The report also sug­gests a stage 3 site assess­ment for very large stra­tegic sites, which, it advises, demands a much high­er hurdle than loc­al or major sites.

The report recom­mends that data is cap­tured via spread­sheets that include some func­tion­al­ity, for instance with hyper­links to policies, maps and infra­struc­ture inform­a­tion and forms with min­im­al open-ended ques­tions and free text (where pos­sible yes / no fields or numer­ic­al answers).

Note that this research, and its recom­mend­a­tions, were pro­duced pri­or to the adop­tion of Nation­al Plan­ning Frame­work 4.

Nation­al Plan­ning Frame­work 4

Nation­al Plan­ning Frame­work 4 came into force in Feb­ru­ary 2023 and is the long-term Nation­al Spa­tial Strategy for Scot­land. For the first time it con­tains a set of plan­ning policies that form part of the stat­utory devel­op­ment plan.

Scotland’s nation­al spa­tial strategy is divided into three parts which are sus­tain­able places, live­able places and pro­duct­ive places, each with two spa­tial prin­ciples, nation­al devel­op­ments and policies. This over­arch­ing, integ­rated strategy should form the basis of the loc­al devel­op­ment plan’s site selec­tion and assess­ment meth­od­o­logy and is there­fore set in Table 3.

Table 3 Nation­al Plan­ning Frame­work 4 – Nation­al spa­tial strategy, spa­tial prin­ciples and what it means for sus­tain­able, live­able and pro­duct­ive places

Sus­tain­able places
Nation­al spa­tial strategy
‘Scotland’s future places will be net zero, nature-pos­it­ive places that are designed to reduce emis­sions and adapt to the impacts of cli­mate change, whilst pro­tect­ing, recov­er­ing and restor­ing our environment.’
Spa­tial principles
* Just trans­ition – empower­ing people to shape their places and ensure the trans­ition to net zero is fair and inclusive.
* Con­serving and recyc­ling assets – mak­ing pro­duct­ive use of exist­ing build­ings, places, infra­struc­ture and ser­vices, lock­ing in car­bon, min­im­ising waste, and build­ing a cir­cu­lar economy.
What it means for site selec­tion and assessment
* Ensur­ing the right devel­op­ment hap­pens in the right place.
* Devel­op­ment that is access­ible by sus­tain­able travel.
* Using land wisely includ­ing through a renewed focus on reusing vacant and derel­ict land to help lim­it the new land that we build on.
* Pro­tect­ing and enhan­cing our his­tor­ic environment.
Live­able places
Nation­al spa­tial strategy
‘Scotland’s future places will have homes and neigh­bour­hoods that are health­i­er, afford­able and vibrant places to live.’
Spa­tial principles
* Loc­al liv­ing — sup­port­ing loc­al live­ab­il­ity and improve com­munity health and well­being by ensur­ing people can eas­ily access ser­vices, green­space, learn­ing, work and leis­ure locally.
* Com­pact urb­an growth – lim­it­ing urb­an expan­sion so we can optim­ise the use of land to provide ser­vices and resources, includ­ing car­bon stor­age, flood risk man­age­ment, blue and green infra­struc­ture and biodiversity.
What it means for site selec­tion and assessment
  • Cre­at­ing com­munit­ies that are inclus­ive, empowered, resi­li­ent, safe and provide oppor­tun­it­ies for learn­ing – loc­al liv­ing shaped by loc­al context.
  • Homes served by loc­al facil­it­ies and ser­vices – enough land in the right loc­a­tions to meet future needs and aspirations.
  • High­er dens­ity devel­op­ment to sus­tain pub­lic trans­port and sup­port loc­al living.
  • Vir­tu­al con­nectiv­ity and invest­ment in act­ive travel links.
  • Green infra­struc­ture to con­nect people with nature.
Pro­duct­ive places
Nation­al spa­tial strategy
‘Our future places will attract new invest­ment, build busi­ness con­fid­ence, stim­u­late GDP (Gross Domest­ic Product), export growth and entre­pren­eur­ship, and facil­it­ate future ways of working.’
Spa­tial principles
* Rebal­anced devel­op­ment – tar­get­ing devel­op­ment to cre­ate oppor­tun­it­ies for com­munit­ies and invest­ment in areas of past decline and man­aging devel­op­ment sus­tain­ably in areas of high demand.
* Rur­al revital­isa­tion. Encour­aging sus­tain­able devel­op­ment in rur­al areas, recog­nising the need to grow and sup­port urb­an and rur­al com­munit­ies together.
What it means for site selec­tion and assessment
* Diver­si­fic­a­tion of town and com­mer­cial centres.
* Dis­trib­ut­ing devel­op­ment, invest­ment and infra­struc­ture stra­tegic­ally by enabling rur­al development.

Rel­ev­ant Nation­al Plan­ning Frame­work 4 policies

Policy 1 Tack­ling the cli­mate and nature crisis requires sig­ni­fic­ant weight to be giv­en to the glob­al cli­mate and nature crises in the con­sid­er­a­tion of all devel­op­ment pro­pos­als. This includes by ensur­ing that the loc­al devel­op­ment plan’s spa­tial strategy will reduce emis­sions and adapt to cur­rent and future risks of cli­mate change by pro­mot­ing nature recov­ery and res­tor­a­tion in the area. Site alloc­a­tions will be a key part of the spa­tial strategy¹.

¹ Mat­ters relat­ing to Policy 1 are covered in a range of evid­ence papers, including:

This is re-enforced by Policy 2 Cli­mate mit­ig­a­tion and adapt­a­tion which requires loc­al devel­op­ment plans to guide devel­op­ment to, and cre­ate, sus­tain­able loc­a­tions based on the six spa­tial prin­ciples, informed by an under­stand­ing of the pro­pos­als on green­house gas emissions².

With­in the con­text of Policies 1 and 2, the key policies relat­ing to site selec­tion and assess­ment are Policy 16 Qual­ity Homes and Policy 26 Busi­ness and industry.

Policy 16 advises that deliv­er­able land should be alloc­ated to meet the 10-year Loc­al Hous­ing Land Require­ment in loc­a­tions that cre­ate qual­ity places for people to live. The loc­a­tion of new home alloc­a­tions should be con­sist­ent with loc­al liv­ing includ­ing, where rel­ev­ant, 20-minute neigh­bour­hoods and an infra­struc­ture first approach³.

Policy 26 requires loc­al devel­op­ment plans to alloc­ate suf­fi­cient land for busi­ness and industry, in par­tic­u­lar ensur­ing that there is a suit­able range of sites that meet cur­rent mar­ket demand, loc­a­tion, size and qual­ity in terms of access­ib­il­ity and ser­vices. The alloc­a­tions should take account of loc­al eco­nom­ic strategies and sup­port object­ives of deliv­er­ing a low car­bon and net zero eco­nom­ic recov­ery, and a fairer and more inclus­ive well­being economy⁴.

The fol­low­ing policies place require­ments on the loc­al devel­op­ment plan, which will be import­ant con­sid­er­a­tions for site selec­tion and assessment.

Policy 4 Nat­ur­al Places requires loc­al devel­op­ment plans to pro­tect loc­ally, region­ally, nation­ally and inter­na­tion­ally import­ant nat­ur­al assets. When alloc­at­ing land, the spa­tial strategy should safe­guard them and con­sider the object­ives and level of their pro­tec­ted status⁵.

Policy 5 Soils, requires loc­al devel­op­ment plans to pro­tect loc­ally, region­ally, nation­ally and inter­na­tion­ally val­ued soils. This means lim­it­ing devel­op­ment on prime agri­cul­tur­al land (or land of less­er qual­ity that is cul­tur­ally or loc­ally import­ant for primary use), peat­land, car­bon-rich soils and pri­or­ity peat­land hab­it­at to a series of excep­tions (and sub­ject to the more detailed policy word­ing) relat­ing to essen­tial infra­struc­ture only where there is a spe­cif­ic loc­a­tion­al need; small-scale devel­op­ment dir­ectly linked to a rur­al busi­ness, farm or croft; pro­duc­tion and pro­cessing facil­it­ies asso­ci­ated with the land; the gen­er­a­tion of energy from renew­able sources or the extrac­tion of minerals.

Policy 9 Brown­field, vacant and derel­ict land and empty build­ings, aims to max­im­ise the use of exist­ing land and build­ings and min­im­ise addi­tion­al land take. Policy 9(b) states that pro­pos­als on green­field sites will not be sup­por­ted unless the site has been alloc­ated for devel­op­ment or the pro­pos­al is expli­citly sup­por­ted by policies in the loc­al devel­op­ment plan. The site selec­tion and assess­ment meth­od­o­logy there­fore need to care­fully con­sider and jus­ti­fy any pro­pos­als for green­field devel­op­ment in the con­text of brown­field land availability⁶.

Policy 12 Zero waste requires loc­al devel­op­ment plans to identi­fy appro­pri­ate loc­a­tions for new waste man­age­ment infra­struc­ture to sup­port the cir­cu­lar eco­nomy and meet iden­ti­fied needs⁷.

Policy 13 Sus­tain­able trans­port requires loc­al devel­op­ment plans to pri­or­it­ise loc­a­tions for future devel­op­ment that can be accessed by sus­tain­able modes. It also requires best use to be made of exist­ing infra­struc­ture and ser­vices. This means alloc­at­ing land well served by exist­ing or com­mit­ted infra­struc­ture in line with Nation­al Trans­port Strategy 2⁸.

Policy 14 Design, qual­ity and place requires loc­al devel­op­ment plans to be place-based and cre­ated in line with the place principle⁹.

Policy 15 Loc­al liv­ing and 20-minute neigh­bour­hoods requires loc­al devel­op­ment plans to sup­port loc­al liv­ing through the spa­tial strategy, includ­ing, with­in set­tle­ments, 20-minute neigh­bour­hoods. The pre­par­a­tion of the spa­tial strategy and iden­ti­fic­a­tion of land alloc­a­tions should sup­port loc­al liv­ing and 20-minute neighbourhoods.¹⁰

Policy 18 Infra­struc­ture first requires loc­al devel­op­ment plans to be based on an integ­rated infra­struc­ture first approach. The site selec­tion and assess­ment meth­od­o­logy there­fore need to con­sider infra­struc­ture capacity¹¹.

⁵ Mat­ters relat­ing to nat­ur­al places are covered in the fol­low­ing evid­ence papers:

⁶ Mat­ters relat­ing to soils and brown­field, vacant and derel­ict land and empty build­ings are covered in the Land use, soil and resources evid­ence paper: https://​cairngormsldp​.com​mon​place​.is/​e​n​-​G​B​/​p​r​o​p​o​s​a​l​s​/​l​a​n​d​-​u​s​e​-​s​o​i​l​-​a​n​d​-​r​e​s​o​u​r​c​e​s​-​s​urvey

⁷ Mat­ters relat­ing Zero waste are covered in the Zero waste evid­ence paper: https://​cairngormsldp​.com​mon​place​.is/​e​n​-​G​B​/​p​r​o​p​o​s​a​l​s​/​z​e​r​o​-​w​a​s​t​e​-​s​urvey

⁸ Mat­ters relat­ing sus­tain­able trans­port are covered in the Sus­tain­able trans­port evid­ence paper: https://​cairngormsldp​.com​mon​place​.is/​e​n​-​G​B​/​p​r​o​p​o​s​a​l​s​/​s​u​s​t​a​i​n​a​b​l​e​-​t​r​a​n​s​p​o​r​t​-​s​urvey

⁹ Mat­ters relat­ing to design, qual­ity and place are covered in all top­ic papers, with the fol­low­ing being par­tic­u­lar­ity relevant:

¹⁰ Mat­ters relat­ing Loc­al liv­ing and 20-minute neigh­bour­hoods are covered in an evid­ence paper on Loc­al liv­ing and 20-minute neigh­bour­hoods: https://​cairngormsldp​.com​mon​place​.is/​e​n​-​G​B​/​p​r​o​p​o​s​a​l​s​/​v​3​/​l​o​c​a​l​-​l​i​v​i​n​g​-​a​n​d​-​2​0​-​m​i​n​u​t​e​-​n​e​i​g​h​b​o​u​r​h​o​o​d​s​?​s​t​e​p​=​step1

¹¹ Mat­ters relat­ing to the pro­vi­sion and capa­city of infra­struc­ture are covered in the fol­low­ing evid­ence papers:

Policy 19 Heat and cool­ing requires the spa­tial strategy to con­sider areas of heat net­work potential¹².

Policy 22 Flood risk and water man­age­ment requires loc­al devel­op­ment plans to avoid devel­op­ment in areas at flood risk as a first prin­ciple. This should be sup­por­ted by man­aging the need to bring pre­vi­ously used sites in built up areas into pos­it­ive use¹³.

Policy 27 City, town, loc­al and com­mer­cial centres requires loc­al devel­op­ment plans to provide a pro­por­tion of their loc­al hous­ing land require­ment in city or town centres and be pro­act­ive in identi­fy­ing oppor­tun­it­ies to sup­port res­id­en­tial development.

Policy 28 Retail advises that when loc­al devel­op­ment plans are alloc­at­ing sites for hous­ing, that they con­sider the need for fur­ther retail pro­vi­sion to both meet the need for neigh­bour­hood shop­ping and to sup­port loc­al living¹⁴.

¹² Mat­ters relat­ing Heat and cool­ing are covered in the Heat­ing and cool­ing evid­ence paper: https://​cairngormsldp​.com​mon​place​.is/​e​n​-​G​B​/​p​r​o​p​o​s​a​l​s​/​h​e​a​t​i​n​g​-​a​n​d​-​c​o​o​l​i​n​g​-​s​urvey

¹³ Mat­ters relat­ing Flood risk and water man­age­ment are covered in the Flood risk and water man­age­ment evid­ence paper: https://​cairngormsldp​.com​mon​place​.is/​e​n​-​G​B​/​p​r​o​p​o​s​a​l​s​/​v​3​/​f​l​o​o​d​-​r​i​s​k​-​a​n​d​-​w​a​t​e​r​-​m​a​n​a​g​e​m​e​n​t​-​s​u​r​v​e​y​?​s​t​e​p​=​step1

¹⁴ Mat­ters relat­ing to the city, town, loc­al and com­mer­cial centres and retail are covered in the fol­low­ing evid­ence papers:

Loc­al devel­op­ment plan­ning guid­ance 2023

The guid­ance sets out the Scot­tish Min­is­ters’ expect­a­tions for new style loc­al devel­op­ment plans. It advises that it should be con­sidered togeth­er with Nation­al Plan­ning Frame­work 4 and rel­ev­ant legis­la­tion to give a full under­stand­ing of all require­ments and expect­a­tions for loc­al devel­op­ment plans. It replaces and repeals Scot­tish Gov­ern­ment Plan­ning Cir­cu­lar 6/2013 and the guid­ance states that it should be giv­en the same weight as the repealed circular.

It is inten­ded to assist and sup­port plan­ning author­it­ies and oth­ers with an interest, rather than cre­at­ing require­ments in addi­tion to those in legislation.

Plan­ning author­it­ies are expec­ted to con­sider how the guid­ance can be applied in a pro­por­tion­ate and place-based way and to use their dis­cre­tion in decid­ing which com­pon­ents of the advice are rel­ev­ant to their plan preparation.

In rela­tion to site selec­tion, the guid­ance high­lights Nation­al Plan­ning Frame­work 4’s infra­struc­ture first approach and advises that, in pre­par­ing loc­al devel­op­ment plans, infra­struc­ture con­sid­er­a­tions should inform site selec­tion and the evol­u­tion of the spa­tial strategy, not be a by-product of it (para­graph 41).

The guid­ance (fig­ure 5, page 18) sets out the key stages and assess­ments of the loc­al devel­op­ment plan pro­cess. The Cairngorms Nation­al Park is cur­rently with­in the first stage, evid­ence gath­er­ing, where the focus is on estab­lish­ing the evid­ence baseline through col­la­tion of evid­ence and seek­ing the views of key agen­cies, chil­dren and young people, and the pub­lic at large. Fol­low­ing the gate check, plan pre­par­a­tion com­mences. This includes pre­par­ing a spa­tial strategy, early engage­ment, for instance through a ​‘Call for Ideas’, and site assessment.

Para­graph 108 advises that ​‘detailed policies and site pro­pos­als should not be included in the evid­ence report. Detailed site apprais­al will not be appro­pri­ate at the evid­ence report stage, but the author­ity could use­fully estab­lish a site apprais­al meth­od­o­logy that will be used to appraise sites and inform alloc­a­tions for the pro­posed plan. This could also be linked or ideally integ­rated with the approach to Stra­tegic Envir­on­ment­al Assessment’.

Para­graphs 141 – 190 provide a step-by-step guide to pre­par­ing pro­posed plans and advice on tak­ing account of Nation­al Plan­ning Frame­work 4 policies. While pre­par­ing the pro­posed plan is the next stage, fol­low­ing the approv­al of the evid­ence report, the guid­ance provides help­ful guid­ance on how to estab­lish a site apprais­al methodology.

Para­graph 152 advises that all sites should be assessed using the site apprais­al meth­od­o­logy agreed in the evid­ence report. This includes sites alloc­ated in an exist­ing loc­al devel­op­ment plan; sites pro­posed through any call for ideas and any oth­er sites the plan­ning author­ity con­siders may have potential.

Para­graph 153 advises that the site apprais­al pro­cess and the Stra­tegic Envir­on­ment­al Assess­ment require­ments can be help­fully linked as they cov­er sim­il­ar envir­on­ment­al top­ics. It also notes that all ​‘poten­tial’ sites should be covered by the Stra­tegic Envir­on­ment­al Assess­ment, so that if, at exam­in­a­tion, it is con­sidered that addi­tion­al sites need to be iden­ti­fied, these have already been assessed.

Para­graph 154 advises that no site should auto­mat­ic­ally roll for­ward from one plan to the next without being assessed. All sites pro­posed to be alloc­ated for devel­op­ment in plans should have been assessed for their deliv­er­ab­il­ity through the site apprais­al process.

The doc­u­ment provides guid­ance on rel­ev­ant parts of the nation­al plan­ning frame­work 4 in rela­tion to each stage of loc­al devel­op­ment plan pre­par­a­tion. In rela­tion to Policy 16 Qual­ity homes, it con­firms that the loc­a­tion of homes should be in line with the plan’s spa­tial strategy and informed by engage­ment with pub­lic, private and com­munity interests. It advises that use of the Place Stand­ard, con­sid­er­a­tion of loc­al place plans and guid­ance on loc­al liv­ing and 20 minute neigh­bour­hoods can inform alloc­a­tion choices.

In rela­tion to Policy 26 Busi­ness and Industry, the guid­ance advises that all sites under con­sid­er­a­tion for alloc­a­tion should be assessed for their abil­ity to meet cur­rent needs and mar­ket expect­a­tions and that flex­ib­il­ity and resi­li­ence for busi­ness and industry should be built into site alloc­a­tions. It advises that where exist­ing busi­ness sites are under­used, for example where there has been an increase in vacancy rates, real­loc­a­tion to enable a wider range of viable busi­nesses or altern­at­ive uses may be con­sidered, tak­ing care­ful account of the poten­tial impacts on exist­ing busi­nesses on the site.

It also advises that ​‘loc­al devel­op­ment plans should encour­age, includ­ing by use of the spa­tial strategy and site alloc­a­tions, oppor­tun­it­ies for home-work­ing, live-work units, micro-busi­nesses and com­munity hubs. In the past indus­tri­al and busi­ness areas have ten­ded to be loc­ated at a dis­tance from res­id­en­tial areas. As our eco­nomy con­tin­ues to evolve, there may be scope for great­er integ­ra­tion of work and liv­ing as inter-related land uses which will also sup­port our ambi­tion for net zero. This can help to tackle inequal­it­ies by provid­ing more access­ible, loc­al job oppor­tun­it­ies which reduce the need to travel’.

In rela­tion to Stra­tegic Envir­on­ment­al Assess­ment, para­graph 184 recog­nises that, if a plan­ning author­ity under­takes a call for ideas stage, any site may be sub­mit­ted. It advises that ​‘it is legit­im­ate for the author­ity to assess each site through the broad prin­ciples of the spa­tial strategy pre­pared as part of the work on the pro­posed plan’.

Para­graph 185 con­tin­ues on this theme, advising that the place-based approach to plans (e.g. on a set­tle­ment / neigh­bour­hood basis), ​‘allows the oppor­tun­ity to reflect the broad envir­on­ment­al impacts and bene­fits of the policies and pro­pos­als rather than impacts of indi­vidu­al sites, which can sup­port pro­por­tion­al­ity in terms of report­ing and poten­tially a more enga­ging report as a consequence’.

The Joint Loc­al Devel­op­ment Plan Site Assess­ment and Stra­tegic Envir­on­ment Assess­ment Check­list pro­duced by the Gov­ern­ment Key Agen­cies (Feb­ru­ary 2024)

The Scot­tish gov­ern­ment key agen­cies group dis­trib­uted their assess­ment check­list in Feb­ru­ary 2024. The Key Agen­cies are: Scot­tish Nat­ur­al Her­it­age; Scot­tish Envir­on­ment Pro­tec­tion Agency; His­tor­ic Envir­on­ment Scot­land; Trans­port Scot­land; Scot­tish Water; and Archi­tec­ture and Design Scot­land. The doc­u­ment cov­ers the topics:

  • Water
  • Biod­iversity, flora and fauna
  • Cli­mate factors
  • Air qual­ity
  • Pop­u­la­tion and human health
  • Soils
  • Land­scape
  • Cul­tur­al heritage
  • Mater­i­al assets – deliv­er­ab­il­ity / sus­tain­ab­il­ity constraints.

These broadly fol­low the issues, lis­ted in Sched­ule 3 para­graph 6(a) of the Envir­on­ment­al Assess­ment (Scot­land) Act 2005, on which devel­op­ment pro­pos­als (referred to as plans or pro­grammes in the Act) are likely to have ​‘sig­ni­fic­ant effects on the environment’.

It asks open-ended ques­tions, link­ing these back to Nation­al Plan­ning Frame­work 4 policies. It requires scor­ing pre-mit­ig­a­tion, then details of mit­ig­a­tion and enhance­ment before requir­ing a second post-mit­ig­a­tion score, with a final column for com­ments / conclusions.

It high­lights that there are many scor­ing tech­niques and gives the example of a col­oured sig­ni­fic­antly pos­it­ive (++) to sig­ni­fic­antly neg­at­ive ( — ) sys­tem. It also includes an explan­a­tion of the key Stra­tegic Envir­on­ment­al Assess­ment topics.

Guid­ance on Key Agency engage­ment with loc­al devel­op­ment plan site apprais­als (March 2025)

This guid­ance sets out high level prin­ciples aimed at get­ting the best out of the key agen­cies in sup­port­ing the site apprais­al pro­cess. The prin­ciples facil­it­ate timely and effect­ive responses that add most value to the loc­al devel­op­ment plan pre­par­a­tion pro­cess and ulti­mately sup­port the smooth deliv­ery of sites. They are framed around where and how key agen­cies are best involved in the process.

To max­im­ise value from the key agen­cies, the guid­ance states that fol­low­ing the ini­tial sift­ing pro­cess key agen­cies should be con­sul­ted on sites that:

  • Are pre­ferred or a reas­on­able altern­at­ive and align with your spa­tial strategy and asso­ci­ated infra­struc­ture first approach; and,
  • Relate to issues or oppor­tun­it­ies that fall with­in the remit of the rel­ev­ant key agency where fur­ther bespoke advice is required to sup­port deliv­ery. Some agen­cies may want to review all the pre­ferred and altern­at­ive sites due to poten­tial cumu­lat­ive effects and will advise the plan­ning author­ity accordingly.

It is not required to con­sult the key agen­cies on all sites that are pro­posed for development.

The key agen­cies request that sites sub­mit­ted to them should be:

  • Sup­por­ted by a sum­mary of the reas­on for request­ing key agency input.
  • Grouped in one batch — repeated indi­vidu­al requests under­mine the advice provided and may not enable agen­cies to provide robust advice on cumu­lat­ive impacts.
  • Sup­plied with a GIS shapefile.
  • Accom­pan­ied by the ini­tial site assess­ment find­ings (and indic­at­ive or draft SEA site assess­ment find­ings for Con­sulta­tion Authorities).
  • Presen­ted in an easy to under­stand and clear format, for example, pre­ferred / altern­at­ive sites and dif­fer­ent site use classes could be col­our coded and/​or clearly categorised.

A min­im­um con­sulta­tion peri­od of six weeks is reques­ted, how­ever more time may be required depend­ing on the num­ber and com­plex­ity of the sites involved.

The Park Author­ity will fol­low the key agen­cies’ guid­ance when enga­ging them on sites.

Scot­tish Envir­on­ment Pro­tec­tion Agency Plan­ning Advice Note for Plan­ning Author­it­ies: Scot­tish Envir­on­ment Pro­tec­tion Agency engage­ment in loc­al devel­op­ment plan site apprais­al and assess­ment (May 2025)

The guid­ance aligns with the key agency guid­ance that the Park Author­ity will fol­low in enga­ging with the key agen­cies. The Scot­tish Envir­on­ment Pro­tec­tion Agency advice note also out­lines spe­cif­ic evid­ence related to their area of interest that should be used for the ini­tial stages of the site apprais­al and when Scot­tish Envir­on­ment Pro­tec­tion Agency may need to be con­sul­ted later in the process.

In par­tic­u­lar, the advice note high­lights the import­ance of stra­tegic flood risk assess­ment out­puts for the site assess­ment pro­cess. The Park Author­ity has pre­pared a Stra­tegic Flood Risk Assess­ment, which has been found suf­fi­cient by Scot­tish Envir­on­ment Pro­tec­tion Agency:

The out­puts of the stra­tegic flood risk assess­ment will form part of the site assess­ment pro­cess. Fur­ther inform­a­tion on these mat­ters are presen­ted in the flood risk and water man­age­ment top­ic paper:

The Park Author­ity will fol­low Scot­tish Envir­on­ment Pro­tec­tion Agency’s advice note when enga­ging them on sites.

Stra­tegic Envir­on­ment­al Assessment

Stra­tegic Envir­on­ment­al Assess­ment is a stat­utory require­ment that aims to ensure the envir­on­ment is a primary con­sid­er­a­tion in the pre­par­a­tion of qual­i­fy­ing pub­lic plans, pro­grammes and strategies. The Envir­on­ment­al Assess­ment (Scot­land) Act 2005 requires those pre­par­ing qual­i­fy­ing plans, includ­ing the loc­al devel­op­ment plans, to under­take a Stra­tegic Envir­on­ment­al Assess­ment. Stra­tegic Envir­on­ment­al Assess­ment can also bene­fit the pre­par­a­tion of a loc­al devel­op­ment plan, sup­port­ing bet­ter under­stand­ing of its envir­on­ment­al con­text and setting

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