“NIMBY” LPPs, Call for Sites transparency and LDP formation: a case study and some questions

This post has been written with a view towards the forthcoming student research by Glasgow University post-graduates I am supporting in March, and the forthcoming review by the Scottish Government into LPPs this summer.

PKC LDP3 Call for Sites Submissions (2025) mapping (click image)

Arbitrating between developer site representations and LPPs

Perth and Kinross Council have just released interactive mapping showing where and for what representations have been received from developers during the recent Call for Sites process. Click on the image above to see it.

I think this is excellent work to establish transparency in the system at an early stage…. certainly long before the Proposed Plan is made public and laid before committee.  Bravo!

But should communities have been able to see this data before their submitted their LPPs?

Being able to now access this mapping allows for a case study into how Local Place Plans and developer representations might interact during formation of the Proposed Plan, raising some interesting questions.

(NB, I think of Local Place Plans as the equivalent vehicle for communities as developers have via representations during Call for Sites…they are both formal up-front attempts to shape LDP policy outcomes…although of course with vastly different levels of resourcing behind them).

A Case study: Errol and Grange, Carse of Gowrie (between Perth & Dundee)

1. Have a zoom on Errol and Grange in the PKC LDP3 Call for Sites Submissions (2025) mapping. You will see all the proposals for housing that have been submitted for assessment.
2. Then download the Errol and Grange Local Place Plan and read Proposal E: ‘Policy principles for housing development in Errol and surrounds’ (p23-24) and the justification for that proposal (p42-43).

PKC planners are now sitting with these two positions on their desks. They have to work through these and all the wider issues and policies (especially housing targets for the Authority) to arrive at an initial position in the forthcoming Proposed Plan. Ultimately, in law, the decision lies with the Planning Authority to decide what should happen regarding the allocation of land for housing in Errol and Grange between 2028 and 2038 (now that we have a 10 year LDP cycle).

PKC Planning Authority are the arbiters.

Note that this information is being made available in February 2026.  The original formal indicative deadline for LPPs to be included for assessment for the Proposed Plan was summertime 2025.

Questions raised

1. Who is expected to be transparent first in submissions for the formation of the LDP and why?

Between communities, the planning authority and developers, who should get to see each other’s position first?  Errol and Grange Community Council had to submit their LPP “blind” to the positions of potential future developers. And guidance encourages planning authorities to set indicative deadlines for submission from communities for their LPPs before the Evidence Report is submitted to Gatecheck. Most authorities are following the line that LPPs need to be submitted before any transparency is offered around developer representations. Many LPPs have been submitted before communities could read the Evidence Report.

Is this the right order of things?  Why should communities (generally, but not in all regions) have needed to submit their LPPs both before the Evidence Report is produced by LAs and before they can see what developers have themselves submitted? There are key questions of empowerment and positionality here.

To put it another way, if data about developer and local authority intentions are not available to communities in advance of forming their LPPs, what other position can we expect communities to take who are “flying blind” except one that basically resists housing? Or at least says nothing about it (an unreasonable ask).  This is a question I asked a couple of years ago during this training session I delivered to Local Authority Planners for Planning Aid Scotland a couple of years ago (skip to 35.10 for the section on housing).

Are we once again at risk of corraling communities into a default “NIMBYist” position in LPPs through lack of data transparency and the way the system has been designed? (Yes, technically LPPs can be submitted at any time, but in practice after this point many Authorities would be saying “you have missed the boat to influence this round of LDP formation”).

Or should Errol Community Council now also get a couple of months to amend their LPP in light of this new information?  If they do, can they be given a steer by PKC as to roughly how many houses they might be expected to absorb of the total MATHLR in their area?  This data is also still lacking. Or do they need to wait until Proposed Plan consultation in many months time, when things are already much more locked in?

What do you think and why?

2. Mediation before arbitration as part of front-loading the system prior to Proposed Plan publication.  How will this now work?

The 2019 Planning Act was predicated on a drive to “front-load” the planning system to achieve better downstream outcomes and avoid conflict.  LPPs were put forward as a way to enable up-front conversations between communities and developers to help achieve win-win solutions prior to arbitration proper (i.e. prior to Proposed Plan publication).

With one exception that I know of (credit due here), it is not the case that developers have approached the community in Errol before this point. Their own plans have not been available to date to enable any proactive mediation to occur.  Why would they do so?  They are not expected or obliged to (only encouraged to), it’s a lot of work, and many developers might only see a downside.  So, even if a community wanted to have mature, up-front conversations in the spirit of the 2019 Act, they wouldn’t even know where to start before now. (And anyway, even now they actually still don’t know who has put forward these representations to be able to contact them).

The question is whether, now that we have transparency, mediation conversations can and will now occur? (This to take advantage of the mediation provisions in the Act and the …very thin… guidance later released, so as to fulfil the goal of “front-loading” the system).

But who will initiate this?  Will the Planners at the Local Authority create contexts where this will occur? Who will pay for that time and facilitate these? Will all the developers and landowners with a stake in the Errol context join in that mediation at the same time? And given that mediation is fundamentally about two or more willing parties coming to an agreement, what incentive will there be for any side to work towards a mediated agreement given commercial interests and the fact that they already know that arbitration is certain next step. One which is already resourced and provided for by the wider system?

And who would support communities to be involved in this process?  Who would resource them with knowledge and will their time be paid for?

What do you think and why?