BEFS response to the Position Statement

BEFS has now submitted a response to the Scottish Government’s position paper on the planning review, published in advance of an anticipated Planning Bill this autumn.




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BEFS has engaged with the review of the Scottish Planning system since it was launched in September 2015. The Forum has held workshops with Members, established a taskforce drawn from its membership to examine the proposals and recently held an open discussion on the research paper Barriers to Community Engagement in Planning. Working with the planning taskforce BEFS has now submitted a response to the Scottish Government’s position paper on the planning review, published in advance of an anticipated Planning Bill this autumn.

BEFS has expressed disappointment that the scope of the review has shifted from major reform to a series of procedural changes and has flagged up the inherent tension in seeking to balance greater community participation with the planning system while speeding up and simplifying decision-making processes. Strengthening regional agency is seen as desirable and the loss of Strategic Development Plans is of concern and the removal of Supplementary Planning Guidance is not supported as it can at times mitigate the unfortunate absence of local authority expertise. Extending Permitted Development Rights would likely have unintended consequences in the quality of small scale development and extending Simplified Planning Zones to include conservation areas may not be simple at all.

Reviewing BEFS Members submissions there is a shared consensus that the ambition at the outset is absent and that the opportunity for positive change is not being grasped. There is a shared refrain that warns against centralisation of decision making. There is also observation that there is a lack of integration with other policy agendas and as the National Trust for Scotland points out “there are seventeen references to housing in the position statement – but no references to landscape, or biodiversity, or amenity”. Is it a Planning Bill or Housing Bill that is being prepared?

The responses raise questions about capacity and resource to implement the proposals, for example, without additional resource the uptake of Local Place Plans will be iniquitous. Questions are also raised as to the absence of robust rationale being provided for equal rights of appeal not being explored, and criticism lack of detail on many of the proposals is also frequent.

A brief look at other published responses reveals similar concerns. The Scottish Federation of Housing Associations does not think that the proposals will deliver more quality affordable homes, Homes for Scotland says that there is a “distinct overall lack of detail” and Scottish Environment LINK is disappointed to see none of its concerns addressed in the position statement.

At the discussion on Barriers to Community Engagement in Planning there was a shared sense from community representatives and planning practitioners that as long as the success of planning was measured by speed of decision making neither meaningful community participation and quality place making can be achieved. The survey undertaken by the researchers revealed that 92% of community respondents and 59% of professionals agreed with the statement that “planning is not effective at engaging communities”. This is a stark statistic and explains why equal rights of appeal remains a background conversation that is getting ever louder and will no doubt make its presence felt in the passage of the Planning Bill in parliament.

In 2015 Alex Neil MSP, then Social Justice Secretary, wanted the “game changing review” to result in planning playing “a more positive and effective role in creating high quality places for current and future generations”. As it stands, respondents to the Scottish Government’s position statement do not appear to see this being the result.

You can read BEFS response in full, along with those of our Members, here.

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