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General Comments

Local Authorities

Aberdeen City Council: The White Paper heralds a new and exciting time for planning. It is clear that delivering the new system will require a significant culture change for local authority staff, elected Members, the development industry and other stakeholders. The White Paper states that the Executive's top priority is promoting sustainable economic growth and emphasizes that the aim is to facilitate rather than obstruct high quality appropriate development. It also aims to rebuild confidence in the planning system and to revitalise it as a critical tool for shaping the future of communities and securing a better quality of life for all. This is welcomed by the Council as assisting in achieving its own vision for the future of Aberdeen.

Angus Council: Many aspects of the White Paper on Modernising the Planning System are to be generally welcomed, not least the recognition of the vital role which land use planning plays in ensuring that development is encouraged and managed in a sustainable way.

City of Edinburgh Council: The modernisation proposals are welcomed in their aim of creating a more positive and dynamic Planning system. Many of the Government's proposals are compatible with the Council's own approach to the continuous improvement of its Planning service in improving transparency and accountability, in pursuing efficiency and in broadening the engagement of all stakeholders at the most appropriate time in the Planning process. Although generally supportive of the constructive improvements proposed, there are 15 proposals that raise issues of concern. Some proposals require much more detailed work before they could be implemented and there are also significant resource implications arising from the transfer of duties to the planning authority or the creation of new processes, particularly to extend transparency and participation in the system.

Comhairle Nan Eilean Siar: The Comhairle welcomes the overall objectives of the White Paper and considers that a reasonable balance has been struck between seeking to provide a clear national Planning Framework and national policy and the maintenance and enhancement of local democracy and local community involvement.

Dumfries & Galloway Council: We welcome the modernisation of the planning system, but are concerned that there are inherent conflicts in the improvement proposed in terms of the following principle objectives:

• Strengthening the involvement of communities
• Speeding up decisions
• Reflecting local views better
• Allowing quicker investment decisions

Dundee City Council: The Council is broadly in agreement with the principles and aims of the process particularly with regard to the management of the process and involvement of stakeholders. The Council supports the majority of the proposed changes to the system as representing a more rational and workable alternative.

East Ayrshire Council: The proposals are generally welcomed but the White Paper, if implemented will have significant and widespread implications for the Council in the exercise of its overall planning function.

East Dunbartonshire Council: The white paper contains a large number of proposals that will be difficult to measure in terms of the impact until the details are provided and drafted in a subsequent Planning Bill with supporting policy documents. However the emphasis on the National Planning Framework, Call-in Powers and the strengthening of Reporters recommendations suggest a further centralising trend with the Executive gaining greater influence over the Planning System

East Renfrewshire Council: While there is much to support and be positive about this Council have reservations about whether or not the proposals would make the system any less complex or more efficient. There would be improvements in some areas but in some ways the system would become more complicated, more difficult for the lay person to understand and have significant new resource implications. There is an obvious tension between achieving more effective engagement in the Planning system and efficiency. On balance it is unlikely that decision making and Development Plan preparation would be speeded up. Furthermore, Local Authority Planning departments could, on balance, have an enlarged workload. It is, therefore, vital that they receive the necessary resources, both in terms of funding and recruitment, to meet the new demands. While the White Paper does devolve more local decision making power to Councils there still remains too much opportunity for Scottish Executive intervention in what are essentially local matters.

Falkirk Council: Overall, as a package, the proposed changes are welcomed. The emphasis on the Development Plan, on plan led development, on greater public involvement in the process and on reduced opportunities for appeals contrary to the development plan should help to achieve a fairer and more consistent system for all. Nevertheless concerns remain about the proposed new system's fitness for purpose, the public's perception of the existing planning system as unfair and inaccessible and whether what is proposed will overcome these concerns. Another key area of concern is the balance between national and local responsibilities and perceived centralisation of responsibility for planning. However none of the proposals will work without adequate resources particularly skilled staff to undertake the work. It is considered, therefore, that the proposals merit support in principle. However a number of key proposals in the White Paper require further clarification and greater detail on how they will work in practice. In many cases the reasons for change appear well founded but the mechanisms for delivering change seem likely to raise practical difficulties. While it may be possible to resolve these potential problems this could have a serious impact on the effectiveness of the new system.

Glasgow City Council: A lack of detail on how many of the proposals in the White Paper are to be implemented is a matter of concern to the Council. Local Planning Authorities should be involved wherever practicable in shaping the detail of these proposals The general aims of the White Paper (as outlined in Para 2.2) are supported and the continued primacy of development planning is particularly welcomed. There are, however, a number of general concerns relating to the proposals. The White Paper does nothing to resolve the fundamental tension between the desire to speed up the planning process and the desire to increase public participation and accountability. For example, neighbour notification of new development plan proposals will be both time and resource intensive. SE should put in place transitional arrangements for plans on which work is already underway. There is also concern that some of the SE's proposals relate to procedures that the Government has introduced south of the border and which have subsequently been withdrawn, e.g. reducing the time within which an appeal can be submitted from 6 to 3 months. Clarification is required from the SE on why these proposals are being introduced in Scotland, given their apparent failure south of the border. On the whole, the modernisation of the planning system is welcomed but the range and scale of proposals and, in particular, the, as yet unknown, implications of their impact in terms of additional financial and staff resources, over and above those of, e.g. the recently introduced Strategic Environmental Assessment process, remains a major concern for the City Council. It is difficult to assess the final impact of most of the major White Paper proposals without more clarification/guidance regarding the way in which they are to be implemented.

Highland Council: In summary, there was strong support for moving forward and support for the principles contained in the White Paper. However, it was acknowledged that the "devil is in the detail" and that secondary legislation must be the subject of wide consultation before being placed before Parliament for approval. Finally, it is considered that the White Paper underestimates the extent of additional responsibilities falling to local government and therefore the issue of proper resourcing - human and financial -should not be lost sight of. If it were to be so then the implementation of the new approach to planning could be severely damaged at birth.

Inverclyde Council: There is no doubt that the proposals will radically change the way in which Local Authorities will operate, giving more powers in genuinely weak areas at present - eg enforcement - and has the potential to reduce the burden in dealing with minor works. On the other hand there is little in the White Paper to suggest that the bureaucratic burden - which is often the greatest obstacle to getting things done - will be lifted. Indeed the burdens could be increased by some of the proposals. In his foreword the First Minister suggests that "our proposals will restore confidence in the planning system and revitalise a critical tool …". On face value there are some doubts as to whether this will indeed be the case. If it is to achieve that it will be essential that the detailed arrangements for implementing the proposals are carefully thought out and resourced to enable the confidence in the planning system to be restored. Having said that, Inverclyde Council broadly supports the changes being proposed, which in some respects are quite radical, but the successful implementation of many of these changes will require more than the general notion emanating from the SEDD that there will have to be a 'culture change' particularly in local authorities but with the support of stakeholders and the public. There appears to be little recognition/evidence of the equal need for a "culture change" - incorporating 'efficiency' and 'wider inclusion' - in the SEDD, which will also be essential if the proposals in the White Paper are to be successfully implemented.

Midlothian Council: As a general comment, there is much to be welcomed in the White Paper, and indeed this Council has expressed support for a number of the proposed changes during earlier consultation. The reasons for seeking to modernise planning are wholly laudable, and few would deny that parts of the system have become outdated, unresponsive and lacking in transparency. As has been remarked, this is a "once in a generation opportunity" to overhaul planning in Scotland. That said, the sheer breadth of the proposed changes to the planning system is daunting, and sets considerable challenges to the local authorities as well as to the Scottish Executive in terms of delivery and resources. A note of caution should be sounded. There are examples of initiatives which have, in practice, failed to deliver forecast or anticipated improvements in efficiency and performance. Great care must be taken, therefore, in ensuring that the proposals to be introduced through the Bill are kept simple and focused. The stated aim is to speed up the planning process. The Executive must avoid changes which might result in greater bureaucracy, and/or could lead to inconsistency and confusion for members of the public.

Moray Council: The Council indicates a substantial degree of "in principle" agreement with measures that are being proposed - in themselves, they are reasonable suggestions as to how to tackle a particular issue - but in their totality they will not meet all the objectives of the modernising agenda. The Scottish Executive set their aims of achieving efficiency, on a par with their aims of extending community involvement; achieving speeded-up decisions at the same time as reflecting local views better. It should be obvious, after so many years of public participation in planning, that greater community involvement does not speed up the process of either development planning or development decisions. It may improve the quality of the decision-making and it may provide more inclusiveness in the process, but it does not speed the process up. The White Paper simply continues this long established conflict. If efficiency had been the primary target, then for example, in Development Plan preparation, the White Paper should have addressed, in detail, the overbearing bureaucracy, and adversarial trends, in Public Inquiries. If inclusiveness was the primary target, then neighbour notification by the local authority (for both plan designations, and applications) would be logical, but as it is, it is an encumbrance which will undoubtedly slow the process, for the reasons given in the Appendices. It is possible that 'efficiency' and 'inclusiveness' could both be improved by these modernising proposals, if local authorities could afford the resources to do so. The development industry has expressed grave concern that the new measures will worsen the burden of duties on planning officers and their statutory consultees; and that greater community involvement will slow down decision making, despite the removal of the controversial 'third party right of appeal' proposal. In all, therefore, there were certain clear areas in the modernising agenda where the Scottish Executive had to bite the bullet, and steer the legislation either towards efficiency, or towards inclusiveness; and they have avoided it.

North Ayrshire Council: The proposals contained in the White Paper are generally to be welcomed. It should be recognised that they will have significant and wide spread implications for the Council in the exercise of its duty as Planning Authority.

North Ayrshire Council (Chief Executive): The proposals contained in the White Paper are generally to be welcomed. They will have significant and wide spread implications for the Council in the exercise of its duty as Planning Authority. A number of the proposals suggested in the White Paper will require legislative change. Apart from operational and administrative changes these new processes unless clearly prescribed will open up the Council to the prospect of legal challenge. The significance of implementing the proposals in the White Paper for planning, legal and admin staff and for members cannot be properly assessed at this stage. Proper consideration of these implications will require to be undertaken as soon as the details are known and may be hampered by the incremental approach which could be taken by the Scottish Executive to implementing the changes.

North Lanarkshire Council:, North Lanarkshire Council welcomes the Executives initiative in taking an overview of the whole system and providing a package of proposals that seek to address a range of fundamental issues. The overall aims of the White Paper - to make the system fit for purpose, efficient, inclusive and sustainable - are strongly supported. Efficiency can contribute to a competitive economy and inclusion is an essential characteristic of a just society, while sustainable development has become a fundamental aim for all levels of government. It is important to recognise, however, that there can be tensions between greater efficiency, more inclusiveness and achieving sustainable, well-designed places. These aims therefore need to be balanced. The White Paper acknowledges that sustainable development requires the long-term consequences of development to be addressed, as well as the short-term effects. In the long term the system will be judged mainly by its outcomes rather than the processes through which they arrived. By promoting the role of development planning and re-focusing development management, the proposals, in the broadest terms, should assist in achieving each of the aims. However, it is vital that any proposals for major changes to the current system should pay particular regard to the long-term objectives.

Perth and Kinross Council: Some Members have noted a conflict between the desire to speed up the process and make it all inclusive and indeed have doubts that at the process would be speeded up given the expectations for increased participation in the process.

Shetland Islands Council's (interim response): In general, the Council welcomes the intention behind the review of the planning system and agrees that we need a system that is fit for purpose, efficient, inclusive and a secure foundation for sustainable development. We believe that the proposals contained within the White Paper will move the system firmly in those directions.

South Lanarkshire Council: The modernisation agenda proposals are generally welcomed in terms of seeking to improve the effectiveness and efficiency of the planning system, while at the same time making it more accessible to the community and providing businesses with a greater degree of certainty in bringing forward development proposals. Nevertheless, the modernisation agenda being proposed by the Scottish Executive is significant and the key to delivering it is to ensure that it is properly resourced. The resource implications inherent in the new system must not be underestimated. Significant detailed work will be necessary to establish the full costs and Councils must be resourced accordingly. This work will also need to examine the training/skill requirements of both local authority staff and Members as they come to discharge their new responsibilities. There are a number of changes already planned including electoral reform in 2007 which will impact on the way Councils operate and manage their business. Therefore, it will be important that Scottish Executive phase the introduction of new systems and procedures. Equally, there should be adequate time and resources made available to local authorities in advance to allow for development of new management systems e.g. neighbour notification, appeals panels, delegated powers etc. In this way, the changes can be implemented more smoothly.

Other LA Organisations

Glasgow and the Clyde Valley Structure Plan Joint Committee: Welcomes the general thrust and overall aims of the White Paper and the commitment placed by Ministers to the importance of city regions and to long-term Development Planning at the forefront of the System. Despite the positive overall nature of the White Paper and the general clarity with which it frames the future of the Scottish Planning System and the role of Strategic Development Planning, a number of issues require clarification before the Joint Committee can be assured that the overall aims of the Review will be achieved.

COSLA: Sees these proposals as a means to make clearer and stronger links between planning and other Scottish policy agendas, such as tourism, environment, transport, energy and housing, not to mention water and sewerage infrastructure and from that perspective there is much, in principle, to welcome. We cannot accept the proposals at face value. Scottish Local Government is democratically elected to deliver the planning system, and must have a clear understanding of the implications of this White Paper - not just for the delivery of the planning function but where it impacts on other key policy areas, such as utilities infrastructure, transport, and tourism.

Non Departmental Public Bodies

Disability Rights Commission ( DRC): We welcome the four principles upon which modernisation will be based. We support the Scottish Executive's aim of delivering a planning system that is fairer, more inclusive and efficient and that promotes sustainable development in Scotland to the benefit of everyone. However, we feel that further consideration needs to be given to the position of disability access in the planning system in promoting sustainable development and social justice. An estimated 1 million people in Scotland are covered by the Disability Discrimination Act 1995. This accounts for one in five of the population. Disabled people in Scotland still face physical and social barriers to accessing opportunities relating to employment, education, housing, health, retail and recreation. The role of the planning system is vital to ensuring that access considerations are mainstreamed throughout the development process. It is worth noting that the DRC's Disability Awareness Survey 2005 showed strong public support (96%) for greater involvement of disabled people in the planning process. The DRC believes that an inclusive built environment is central both to disability equality and sustainable development. We therefore welcome the proposals in the Modernising the Planning System consultation, but believe that further consideration needs to be given to clarifying the social aspects of sustainable development, and to how best to ensure that accessibility issues are mainstreamed into the planning process, particularly given the pending Disability Equality Duty on public authorities in Scotland.

Equal Opportunities Commission: The EGG welcomes the invitation to respond to the consultation on the white paper 'Modernising the Planning System.' In light of the introduction of the Equality Bill we feel that it is appropriate to highlight the implications of this forthcoming legislation since it will have a direct impact on how the planning system operates and any future modernisation. We will also highlight what we consider to be fundamental implications of the Equality Bill in terms of sex equality.The Equality Act will mean that 'Gender mainstreaming' will be built into the core of business thinking and processes within an organisation. In terms of modernising the planning system it will be essential that planners consider how men's and women's needs differ and how this will impact on policies and practices. For example; women have less access to private cars than men and are the main users of public transport. They use transport at different times, in different ways and for different reasons, yet transport services and town planning rarely recognise this. The EGG expect that any resultant policy statement or future plans concerning the modernisation of the planning system will show an understanding of the different needs of men and women and demonstrate this in practical changes to the system and action.

Health & Safety Executive:HSE supports the increase in transparency and speed proposed in the White paper and welcomes the idea of development management and development plan led system with plans which are up to date. However this makes it essential that major accident hazards [ MAH] sites are properly considered in such plans. We are concerned that Health and Safety does not have the same importance accorded it as do Environmental matters.

Highlands and Islands Enterprise: Given the strategic context in the Highlands and Islands, the Executive's proposals for Modernising the Planning System are both timely and, indeed, essential to the realisation of our long-term development aspirations. At the Planning in Scotland conference in Edinburgh on 6 September, the importance of the proposals was reinforced by a succession of speakers and contributions from delegates, in particular identifying the crucial links between planning and economic development policies. Planning lies at the heart of achieving sustainable economic growth in Scotland, yet the current system is not serving us well. Despite the commitment and professionalism of the planners who operate the system, it remains bureaucratic and cumbersome, often focussing on detail when broader principles should reasonably be applied.

Historic Environment Council for Scotland: The present system is inefficient and cumbersome, and at the level of the local authorities it has suffered from a serious lack of investment in recent years. Scotland's historic environment is undoubtedly one of the country's major assets, and it would seem to have been a missed opportunity for this not to be recognised as one of the central arguments instead of being relegated to the end of the paper in a lengthy Appendix on procedural matters. It would be considerable concern if there was any suggestion that the historic environment should somehow be decoupled from the broader planning agenda. Too often the historic environment placed in the position of being seen as a constraint on development within the planning system, rather than the catalyst for it, and an additional layer to the development management process rather than as an integral part. If the proposals set out in the White Paper can be made to work, then HEACS anticipates that there will be opportunities to redress this fundamental misconception. The success of the proposed modernisation exercise, and the continuing levels of protection of the historic environment, will depend on all of the recommendations being implemented effectively, and not just those intended to speed up the process.

Scottish Committee of the Council on Tribunals: In general, members acknowledge the proposals as being part of a long-needed overhaul of the whole system. However, some of the assertions in the White Paper do foster a general concern that objectors' views, in a democratic process, are likely to be thwarted or overridden, especially in respect of dismissing requests for an inquiry. There is a significant amount of proposed centralisation of functions towards Ministers and the Department. My Committee will look more closely at this undercurrent when the Bill is published.

Scottish Enterprise Dumfries and Galloway: The focused approach on creating an efficient system which supports economic growth and sustainable communities is particularly welcomed in rural economies, such as Dumfries and Galloway. Delivery of the '2003-2008 Economic Development Strategy for Dumfries and Galloway' is a priority for Community Planning Partners, and in order to achieve this, a system which is both flexible to the needs of changing economic priorities and circumstances whilst rigorous and timeous in its delivery. The creation of the Regional Transport Partnerships ( RTPs), and the proposed involvement of Community Planning Partners on these Boards, is a positive step in ensuring connectivity is at the core of development projects. The RTP's interface with the planning system is vital in ensuring the effective movement of labour, freight and general connectivity.

Scottish Natural Heritage:SNH has a close interest in planning, which is of considerable importance in fostering development which is truly sustainable. This can be achieved both by promoting development which is consistent with more sustainable lifestyles and by ensuring that development safeguards, and where possible enhances, the natural heritage. An efficient and inclusive planning system is critical to the realisation of these objectives, and we therefore endorse the principles that underpin the White Paper and welcome the proposed modernisation. There is some tension between the desire for brevity and the need to ensure that Development Plans provide sufficiently explicit guidance to support development management. The effectiveness of the proposed plan-led approach will depend to a large extent on the resolution of this conundrum. The White Paper also rightly makes frequent reference to sustainable development, but this important underpinning principle is not carried through very strongly into the proposed reforms. One way of correcting this might be for the Planning Bill to assert the importance of this function through a new statutory definition of the purpose of the planning system.

Sportscotland: From our experience as a statutory consultee on development proposals affecting playing fields, making representations on development plans and assisting various bodies in developing new facilities for sport, it is apparent that many people find the current planning system to be over complex and lacking in transparency. There is a need for a simplified system which makes the decision making process easier to understand and hence easier to engage with.

The Crofters Commission: Welcomes the package of reforms in the White Paper "Modernising the Planning System". We applaud the ambition to set out a planning system that works for Scotland and provides a quicker, more transparent and more effective service.

The Theatres Trust: The Trust welcomes and supports the proposals for making it easier for individuals to become involved in the planning process

Other Public Bodies

Central Scotland Forest Trust:CSFT broadly supports the proposals for modernisation of the planning system contained in the white paper. We strongly agree that a key purpose of modernising planning in the twenty-first century should be to increase its effectiveness as an agent for delivering sustainable development and environmental justice. We agree with the importance of planning in the regeneration of deprived areas (including, from CSFT's point of view, encouragement through the planning system of quality woodland/greenspace for community benefit). We also agree with the importance of creating attractive communities where people want to live, work and visit. CSFT regards the creation of quality greenspace and woodland, by mechanisms including the planning system, as a crucial component of creating attractive communities.

NHS Lothian: Fully supportive of the central role of planning as set out in the Executive Summary. The delivery of sustainable communities with access to appropriate community infrastructure is an essential prerequisite for the health of the Scottish population.

Scottish Water: The objectives of 'making the planning system fit', 'improving efficiency', and 'widening inclusion', along with incorporating sustainable development into the planning system, are all concepts and strategies that Scottish Water would support. Scottish Water wishes to play an active role in the definition and implementation of the proposed processes. The paper confirms that "creating excellent public services requires investment in infrastructure and buildings". Since this is central to Scottish Water's role, it is imperative that we have a planning system that reflects and supports this responsibility. Throughout the document, a number of proposals are made for which greater clarity and explanation of terms is sought, particularly in relation to the proposed development management hierarchy. In general, whilst many proposals are supported in principle, until further explanation is provided the detailed effects these will have on the water and wastewater industry cannot be fully understood.

The Development Industry

Bett Homes: Bett Homes supports the Executive's aspiration for a more focused planning system, which has as its primary objective the delivery of sustainable development across Scotland for the benefit of all communities. Within this context it is our belief that a strong strategic vision for Scotland is important.

British Aggregates Association: We congratulate the Scottish Executive in producing this paper, which is clearly a substantial effort in improving the current planning system in Scotland In particular we note the positive comments concerning the speeding up of the whole planning system. We are disappointed that more mention has not been made in the White Paper of the work of " SPP4 Minerals Working". This would have been an opportunity for the planners to explain to the general public just what systems are already in place that concern minerals planning matters in Scotland.

Dawn Homes Limited: Confirms support for the submission made by Homes for Scotland. Also highlights some additional points. With regard to the purpose of planning, we believe as a housebuilder that the planning system should ensure that it provides through the development plan for the housing of the existing and future population of an area and that this should be written into the act to avoid any scarcity of housing land provision.

Glasgow Harbour Ltd ( GHL): In general we welcome the intention to modernise the planning system. However, we consider that a number of the proposals require to be removed, refined, or clarified in order to have maximum benefit to an improved planning system.

Grosvenor Investments: Grosvenor is supportive of the general economic focus and priority given in this White Paper. We are also pleased to see the emphasis shift from planning control to planning facilitation. The most important element of the planning system is that there is clarity of procedure and timescale. This, in turn, gives us certainty of outcome which reduces risk and increases confidence, leading us to increased investment. Speed is helpful, but certainty of timescale is more important. A major theme of our response to this white paper is our emphasis on the importance of implementation. In order for our planning system to focus on facilitation, individuals must have the necessary training and encouragement. This requires leadership from the Scottish Executive and local authorities. We would welcome a reassurance that the Scottish Executive has a strategy in place to ensure all officials have the required level of training to implement these changes and that the transition itself will be managed.

Homes for Scotland: We are content with the broad thrust and also support the intentions in the White Paper that provide for a more structured approach for engagement with local communities. Giving priority to investment is important but we recognise the value of engaging with local communities. There is an absence of sufficient detail regarding implementation and there is a need to put more "flesh on the bone" if the intent of the White Paper and the planning reforms are to be achieved. Homes for Scotland would be happy to work with the Executive on some of these issues. Homes for Scotland has an underlying anxiety whether and how the proposed changes can be achieved satisfactorily, noting that the delivery of many of the changes will not be achieved directly by the Executive itself but will be highly dependent on the ability and willingness of planning authorities to respond positively to the planning reform agenda. Delivery of the agenda will require a significant culture change in the approach by many planning authorities.

James Barr Ltd (on behalf of various development industry businesses): While there are many excellent suggestions for improving the current system, there are, unfortunately, numerous detailed proposals that give serious cause for concern. These proposals are dealt with individually in this response, but, in essence it appears that the Scottish Executive's enthusiasm for enhanced community engagement and strengthening the involvement of local people in the planning process has distorted much of the reasoning behind the current proposals without sufficient regard as to the practicalities of implementing many of the proposals and the resourcing implications for applicants. While our clients, and indeed most people involved with the planning system, welcome moves to make it a more transparent, fit for purpose and inclusive process, there is a feeling that these laudable objectives have not quite filtered through into proposed modifications. Instead the proposed reforms seem intent on introducing measures that, by and large, increase the responsibilities of applicants and reduce their own rights. As a result, it is considered that many of the proposed changes to the system will ultimately be impractical and in many cases unfairly disadvantage applicants. While increasing the involvement of local communities in development plan preparation etc is a laudable objective, it must be recognised that the vast majority of people who make representations upon development plans and/or planning applications are of a negative nature, objecting to a proposed allocation or particular development. Key amongst these concerns is the proposal to allow local people to bring alleged failures by the developer to engage with them to the attention of Ministers and the proposals to legislate for Good Neighbour Agreements, which effectively will allow local residents to act as enforcement officers.

Mactaggart and Mickel Ltd: The proposed reforms have been widely welcomed and we support the proposed Bill's main objectives, but have less confidence in how they might be delivered. As is so often the case, the devil is in the detail, which detail is lacking in relation to the key question of how will it be made to work, with particular doubts about the culture change required and achievement of up-to-date development plans and whether the change in attitudes required from local government will happen. There will be a time lag before the Bill's provisions will be introduced and before the first plans are up and running. This would be several years and the new local plans in the four City Regions will have to await the new SDPs being approved. Equally, the suggestion that the proposed Bill can only be accepted as a package runs counter to the consultation process and the statements, for example on third party rights of appeal, that the debate is not yet over. If the package is inflexible, that is a mistake since planning itself can only exist in an environment which is inherently changing and which demands a flexible approach. In particular, the interim stages need to be more thought through as they may last for some time. There is also no mention of the many other procedures that cause public concern, such as proposals under the Roads (Scotland) Act or even private bills presented to Parliament. There is a widespread view amongst many groups, both lay and professional, that the things that affect their environment- both physical and business - need a more holistic approach if people are to believe in a new system and that it protects their rights and allows for proper debate about their interests. Many local authorities are adopting a one-stop approach and so should the new Planning Bill. There is something of a dichotomy in the White Paper. On the one hand, the wrong that the proposed Bill would put right is the lack of engagement by communities in the planning process. The improved position on local plans should mean that the present reasons for third parties feeling that an appeal mechanism is required are therefore likely to diminish. On the other hand, there is a clearly held view in government that third parties feel oppressed by the present adversarial appeal system, which is spun out by planning consultants and lawyers, which therefore needs to change. However, there is ample evidence that third parties are quite capable of participating in planning appeals and relish the opportunity to cross-examine Council and developer witnesses.

Manor Kingdom Group: Views the Planning White Paper as positive move forward but continues to have major concerns on a number of issues and would trust that the Executive will give further consideration to such matters in advance of proceeding with new legislation. Whilst acceptable in principle, there is at present an absence of sufficient detail regarding implementation. The delivery of many of the changes will not be achieved directly by the Executive itself but will be highly dependent on the ability and willingness of planning authorities to respond positively to the planning reform agenda. Delivery of the agenda will require a significant culture change by many planning authorities. Manor Kingdom's general opinion is that this White Paper as a precursor for the new planning system will indeed be a vast improvement on the existing arrangements and many of the changes are to be welcomed. With improved management and resourced properly by each individual local authority, the change in the White Paper should in theory create a smoother and more efficient planning application process and hopefully install a confidence with developers in their dealings with local authority planning departments.

Persimmon Homes: The White Paper is generally considered as a positive step by the Scottish Executive in seeking to produce a Planning System that is clear, accessible, and able to respond to market and economic drivers, and most importantly, support investment.

Stewart Milne Holdings: This Company welcomes the Modernisation of the Planning System Document recently published by the Scottish Executive and in the main considers it both positive in content and tone. In this regard, the majority of the proposals put forward by the Executive are considered warranted and necessary if the system is to be improved for the benefit of all parties including not only housebuilders and the private sector but also local authorities and communities. Although the proposals in the main report by the Executive make encouraging reading, we have fundamental concerns over the delivery by Councils of what will to a large extent become a more positive proactive role for them. The inbred culture that prevails at most levels within Councils today will need to change and as a starting point this needs to be recognised. Moreover there is the issue of the additional workload that these changes will bring and as a consequence raises the question, can they cope? On present evidence this is considered extremely unlikely. In this regard, before consideration can be given to the solutions the matter of both culture and resources must be acknowledged. In short, without the right culture, training, level and quality of staff we believe these encouraging proposals will flounder.

Stewart Milne Homes: In general terms, we welcome the terms of the White Paper. It is however an ambitious document and requires to be supported the proper resources. Detailed guidance is required on many aspects of the implementation of the White Paper, not least on how the Planning System will function in this interim period. Stewart Milne Homes North would welcome the opportunity to become involved in this process. The new Planning Act should explicitly recognise the role which the planning system plays in the economic life of the Country. It should be a pre-requisite that the Executive make it a statutory requirement for all branches of Central/Local Government to be joined up. i.e., it is pointless directing development investment to a specific settlement if no infrastructure is in place.

Other Businesses/ Business Groups

Aggregate Industries UK Ltd: The White Paper contains a range of proposals which, it is claimed by the Scottish Executive, are designed to ensure the planning system is fit for purpose, more efficient and able to play its part in promoting sustainable development. It seems to us that the White Paper recognises a compelling need to balance the competing interests of the developer and members of the public and that this approach is to be welcomed. In particular, we welcome the fact that the Executive has decided, after detailed consideration and consultation, not to introduce Third Party Rights of Appeal. However, it is of concern to us that some of the proposals contained within the White Paper, whilst not at first glance seeming to be overly controversial, may, in fact conspire to make development more complicated and problematic than we would have hoped was intended.

Association of Electricity Producers: The Association broadly supports the proposals included in the White Paper. We commend the Executive on its forward thinking plans and clear objectives for the planning system. Whilst a number of concerns are raised, they are not meant to detract from the overall support the Association has for the proposals.

British Energy:BE is broadly in favour of the proposals contained in the White Paper. They present a welcome opportunity for improving the planning process in a number of key areas. We think the changes proposed to expand public participation and involvement in local plan preparation and development management decision making is particularly welcome. We also believe the changes proposed to the development plan process will bring greater certainty to development outcomes while retaining democratic accountability. The measures proposed such as changes to development plan preparation and public consultation will place greater burdens on planners at the local authority level. The issue of resource provision and funding is likely to be a pivotal part of the modernisation process if measures are to be effective and workable. We have some reservations over the amount of detailed work needed to underpin the White Paper and the time this will take. The proposals represent a major overhaul of the system and an indication of how long this process is expected to take would be helpful.

CBI Scotland: Warmly welcomes the broad thrust and tone of the White Paper. If the proposals are supported by all stakeholders and implemented with sufficient resources, the White Paper offers a genuine opportunity to create a dynamic and efficient planning system. A profound culture shift is essential. It is not just new processes and procedures that are needed but a shift in stakeholder perceptions about the underlying function of planning, and a willingness to interact with the planning system in different ways. If the Scottish Executive can encourage and facilitate such a culture shift, the proposals in the White Paper can deliver greater efficiency and genuine local participation, and support the delivery of the industrial, commercial, social, transport and health infrastructure that Scotland needs. Strengthening the synergy between the economy and the planning system, we are delighted to see the First Minister and the Deputy First Minister re-iterate that sustainable economic growth is the Executive's "top" priority. We are also heartened to see their acknowledgement that development is a requisite for growth and that planning has a key role in encouraging and managing development. We would like to see the same conviction and clarity of purpose explicitly framed in the Bill itself and in all the support and guidance materials issued by the Scottish Executive.

Cinema Exhibitors' Association Ltd: We believe it is extremely helpful to have the proposals that are linked contained in one paper even though many of the proposals have already been subject to widespread consultation.

Civil Engineering Contractors Association ( CECA):CECA broadly welcomed the White Paper as a pragmatic way forward in modernising Scotland's planning system. Scotland needs a robust and efficient planning system in order to develop and prosper but it also needs a planning system that safeguards the rights and wellbeing of its citizens. We believe the White Paper is a creditable attempt to balance these.

Confederation of UK Coal Producers: In general terms, CoalPro considers the White Paper represents a well balanced approach to achieving the twin objectives of a more efficient and more inclusive planning system. Some commentators have expressed the view
that these are incompatible. CoalPro does not subscribe to that view. In particular, CoalPro welcomes the proposals for greater inclusion and considers these far superior to the introduction of a Third Party Right of Appeal ( TPRA), limited or otherwise.

Crown Castle UKLTD: We are broadly supportive towards changes to bring forward a more modern and inclusive planning system. However, some changes suggested within the White Paper have the potential to directly impact on the provision of modern electronic communications in Scotland, which would not be in the wider public interest given that they could frustrate the attainment of core UK objectives.

Edinburgh Chamber of Commerce: In general supports the comments made by the Scottish Chamber of Commerce in their submission. In addition we welcome the modernisation process and in particular would applaud the statement that "sustainable economic growth" is the prime concern of modernising the existing planning system. It is our belief that the other social and environmental objectives of the proposals will be best realised by the growth of a vibrant economy, and that the planning system should encourage rather than hinder this growth. We welcome the stressing of Transport Assessments and Environmental Impact surveys in the process and encourage that modernisation of the planning process should be a whole system thinking process.

E. ONUK Renewables: We have been working closely with the Scottish Renewables Forum ( SRF) who has asked their members for comment on your consultation. We have contributed to this process and are keen to lend our support to SRF's consultation response to you. We will continue to work with SRF to respond constructively to this pivotal consultation on the Scottish planning system.

First UK Bus Division: There is little reference to transport in the paper. Transport and land use planning are inextricably linked, and it is fundamental that the development of local plans, and the determination of planning applications, take full account of this interaction. First considers that more emphasis should be given to the need to develop a planning regime which is served by a sustainable transport system. Location of development where it can be best served by public transport and a presumption against large out-of-town development away from major transport links are of key importance in achieving such a sustainable solution. Nevertheless the proposals to modernise the development plan process and the revised National Planning Framework are welcomed and should provide a clear and contemporary framework for development.

Forth Ports PLC: The planning system is central to successful, sustainable development and the setting of clear policy and an efficient system for considering and processing planning applications is fundamental to the Scottish Executive's priority of improving Scotland's economic growth. The planning system, whilst key to the development process, must operate in parallel with other important functions of Government in Scotland. It is imperative that policy is better informed through improved interaction both within Scottish Executive and between the Executive and agencies including Scottish Enterprise, Communities Scotland and Scottish Water. A 'joined-up' approach to policy formulation and implementation will ensure that efficiencies promoted through the White Paper are reflected and followed through in other key areas of government. Related to this is the issue of delivery of large scale projects. The planning system must ensure that the appropriate mechanisms are put in place to support a balanced approach to the level of private sector funding of public infrastructure, services and facilities. It is the role of the Scottish Executive and local authorities to deliver public infrastructure and services through the Council tax and central funding. It is of critical importance to the future delivery of large-scale mixed-use developments to recognise the limitations to the private sector funding of infrastructure normally provided by the public purse. Greater recognition must be given to the increase in local authority income through Council tax arising from significant housing growth, and how this should be utilised to cross-fund public infrastructure and services. The White Paper should also take the opportunity to clarify and expand the role of compulsory purchase in Scotland. At the time when the economy is a key priority for the Executive it is imperative that improvements in the ability to overcome land ownership constraints to the delivery of key developments are made. Forth Ports PLC would welcome the extension of CPO powers to the Scottish Executive to enable national and major development to proceed more smoothly.

Industrial and Power Association: We are delighted to note the opening statement in the Foreword by the First Minister and the Deputy First Minister, "The Executive's top priority is promoting sustainable economic growth to create a modern and vibrant Scotland". This is a clear and unequivocal message that the Planning System must become an important tool in the development of Scotland's commerce and industry, not only as an enabler but as a positive promoter. It is our hope that the modernisation of the system will address the failure of the planning system at present to lend materiality and weight to proposal-related "economic benefit" at national and local level. The Reporter chairing the enquiry stated that the potential economic benefit generated by the project was not a significantly material fact in approving the project. In short, although Moray Council was wrong in refusing the application, it was right in not affording weight to 400 jobs.

Institute of Directors: It is widely believed that the purpose of the planning system at present is to prevent growth - evidenced by the length of time people have to wait for planning consent, and the costs involved. Industry is turning away from development in Scotland due to the length of time and expense of obtaining planning consent in Scotland. Generally the white paper is very welcome in its positive approach to the process and to altering the culture of prohibition surrounding the process at present - the movement from "Control" to "Management" is fundamentally important and if it can be achieved will go a long way towards improving our communities and economies - local and national. The White Paper appears to look at the mechanism of planning not the policy. The growth of the economy is the number one priority of the Executive and planning is vital to delivering this - this could be even more clearly spelt out in the White Paper.

Orange PCS Ltd: Orange welcomes the broad content of the White Paper and agrees with the assessment of the need to modernise the planning system so that there is a more efficient system that reflects national guidance, delivers consistent high quality service, promotes sustainable development and serves Scotland as a whole. We also agree that the system need to be fair in order to allow developers to satisfy the needs of communities in a manner that can accommodate the opinions of relevant stakeholders.

Quarry Products Association (Scotland): The members generally welcome many of the positive proposals contained within the White Paper in seeking to improve the efficiency of the planning system. Our members are committed to the Association's sustainable development strategy and note with encouragement that the Executive's top priority is "promoting sustainable economic growth".

Scottish Chambers of Commerce: The efficiency and effectiveness of the current planning system remains a key concern for our members, hampering business development and investment. In SCC's Quarterly Business Survey, respondents from the construction sector cite 'planning delays' as the third biggest impediment to the growth of their business, only surpassed by 'winning new contracts' and 'skill shortages'. What business wants to see is action that leads to a demonstrable improvement which does more to facilitate development and economic growth, rather than hinder it. Scottish Chambers of Commerce: The existing planning system could be significantly improved if the proposals in the White Paper are delivered and if managed and properly resourced by the planning authorities. On those issues which do not require legislative change, we look to the Executive to publish an action plan in early course, detailing the priorities and timetable for the early implementation of each of the various components. This is particularly important as many of the legislative changes will not come into effect for several years. SCC believes the proposals offer an opportunity to make life easier for firms to operate in Scotland and reduce the burden on business, provides a framework for stimulating investment and development, and help fulfil the Executive's desire to prioritise economic growth. Failure to deliver these changes could harm commercial investment and further undermine faith in the planning system.

Scottish Financial Enterprise ( SFE): As we have stated in previous submissions on planning to the Scottish Executive, it is clearly in the interests of the industry, the people who depend on it for their livelihoods, and the overall Scottish economy that Scotland provides a competitive business environment to retain existing and attract new financial services investment. To improve its attractiveness and competitiveness as a business location, Scotland needs a more efficient and effective planning system that encourages business development and economic growth. We welcome the recognition of this in the White Paper. The review of Scotland's planning system provides an opportunity that must not be missed to put in place a new approach that meets the current and future needs of business as well as those who live and work in Scotland. We welcome the undertaking to move to a quicker and more predictable planning process that is managed effectively with clear targets and milestones.

Scottish Rural Property & Business Association: The White Paper emphasises that the Scottish Executive's top priority is promoting sustainable economic growth. By definition therefore all other priorities are secondary. Sustainable economic growth requires development on all fronts including infrastructure, energy, waste management, health and education facilities, housing and industry. These types of developments may mean unpopular and difficult decisions will need to be made. But if sustainable economic growth is at the heart of the system, then it must be recognised that in certain circumstances local and other community concerns may have to be overridden. The Scottish Executive will have a major role to play in educating the general public that whilst greater and meaningful inclusion is a fundamental aim of the planning process, it is not overriding. We are concerned that conflicting messages are contained in the White Paper. The forthcoming Planning Bill simply cannot be all things to all people, and still achieve the fundamental reform the planning system needs

RWE Npower plc: Accepts the need for alterations to the planning system in Scotland and supports the general objectives of the proposed reforms. RWE Npower plc supports the representation submitted by the Scottish Renewables Forum and requests that SRF's comments should be fully considered in developing proposals for implementing the White Paper's proposals. We welcome the decision not to pursue a third party right of appeal, as we believe that the objective of widening public inclusion in the development management process will be far better and more constructively served by early public involvement as proposals are being prepared, for example via pre-application consultations. Many of our developments, including hydro schemes above 1 MW capacity and large wind farms over 50 MW capacity, fall to be considered under the provisions of Section 36 of the Electricity Act 1989 rather than via the ordinary planning system. The White Paper does not make clear how Electricity Act consent procedures will be affected by the proposed changes in the planning system and this needs to be clarified. This is also relevant to additions to electricity transmission infrastructure which in some cases (such as the proposed Beauly-Denny line upgrade) would appear to constitute "national" developments in the proposed planning hierarchy.

The Scottish Coal Company Limited ( SCCL): In general Scottish Coal welcomes the package of measures proposed for the modernisation of the planning system in a devolved Scotland and agrees with the five key aims of the white paper. However, there are certain aspects of the White Paper, that without the benefit of additional information on the detailed proposals, give rise to a number of concerns that I have set out below in a review of the proposals.

Unison (Scotland): Whilst it is the responsibility of the Scottish Executive to oversee the effective functioning of the planning system it is not their role to interfere with the decisions of democratically elected local authorities. Powers of intervention must genuinely be powers of last resort.

Universities Superannuation Scheme Ltd ( USS): In general we welcome the intention to modernise the planning system. However, we consider that a number of the proposals require to be removed, refined, or clarified in order to have maximum benefit to an improved planning system.

WBB Minerals: I would like to offer support for many of the Scottish Executive's principles, initiatives and objectives outlined to help modernise the planning system. The approach proposed is refreshing if at times radical and I await with interest further details behind the methodology for implementation of the proposed planning framework. I would add that it would have been helpful to have the paragraphs within the consultation paper numbered individually for ease of reference. Long term planning leads to developer confidence and subsequent investment which helps improve our quality of life. It is this need for investment which the planning system currently has lost sight of.

Wm Morrison Supermarkets PLC: Morrisons generally welcomes the main themes set out in the White Paper for the future of planning in Scotland. It supports the drive to modernise the planning system through a streamlining of the development plan system.

Professional Organisations

Association of Regional and Island Archaeologists: ARIA notes that there are several references in the document to the proposed modernised planning system protecting Scotland's heritage (p8, p12, p32, and p54), although various phrases are used for this asset - "built heritage", "heritage", and "historic environment". ARIA also assumes that protection of the historic environment is subsumed within the many references to environment and sustainable development in the consultation document, given that there is existing planning policy guidance ( NPPG 5 and NPPG 18) which stresses the significance of the resource. ARIA is therefore particularly disappointed that the opportunity has not been taken in the proposals for the Planning Bill to set out a more rigorous approach to protecting Scotland's historic environment, particularly in respect of unscheduled archaeological resources and designed landscapes. This concern is made more acute, when the absence of specific proposals is bracketed with a number of proposals for change which raise issues in relation to future protection of the historic environment in Scotland, namely use of Strategic Environment Assessment ( SEA) alone to address the environmental impact of development plans; the proposal to increase permitted development rights; and the proposal to confer consent in principle via development plans.

Chartered Institute of Housing: The CIH has been working jointly with RTPI and LGA to consider how to achieve greater integration between housing and planning within the system in England. Elements of this work can be successfully adopted in Scotland and have informed some of our response to the White Paper. Overall the CIH welcomes the proposals that will help to ensure that Scotland has the necessary infrastructure to enable sustainable growth.

The Faculty of Advocates: Inherent tensions in these aims and aspirations, and these may be formidable unless the system is adequately resourced. We are aware from discussions with the Executive that the budgets of local authorities for planning matters have in fact decreased in recent years.

Institute of Civil Engineers Scotland: Welcome review of planning system. Focus of response is on how proposals will impact on infrastructure provision.

RICS Scotland: RICS Scotland supports, in principle, the objective of modernising the planning system and making it more efficient, giving local people better opportunities to participate in the decisions that affect them. We would like to stress that consistency within the planning system is crucial. In order to achieve this, detailed guidance for applicants is required, as is training, on a national level, for planners and local authorities.

Royal Incorporation of Architects in Scotland ( RIAS): The paper is comprehensive in its proposals and shows the value of drawing out the views of the local authorities, the general public and those who engage daily with the system. The consultation process has been thorough

Royal Town Planning Institute in Scotland: The Institute has been pleased to note the degree of concurrence with its own views, developed over a number of years, across a wide range of the proposals. We have therefore been able to focus maximum attention on more controversial areas and areas which require further careful consideration before feasibility can be established. Despite the readiness of the Institute to engage with this exercise, we note with some concern the publication of the white paper immediately prior to the summer holiday period with only two and a half months for a response. The Institute fully supports the plan led philosophy in the white paper as the means of seeking to defuse the inevitable tensions which occur between the efficiency and inclusion themes. We are not convinced that the white paper does enough to:-

A significant concern we have about the white paper is that the transitional period to any effective change may be excessively long and may be counter productive to the aims of culture change where the attention span of many stakeholders may be limited

Scottish Society of Directors of Planning ( SSDP): The Society wishes to see a degree of flexibility in the proposals to allow the modernised planning system to develop and to adapt to change over time. The Society seeks to ensure that the changes to the planning system result in a simplification of the planning process rather than a repeat of the current over complication. It is felt that this would lift the bureaucratic burden to ensure true efficiencies and promote public confidence in the planning system. There must be a rigorous attempt to standardise the planning function and procedures throughout Scotland. The Society appreciates the need to develop the detail of a modernised planning system but in doing so wishes to ensure the proper balance between central and local decision making.

Scottish Association of University Directors of Estates: It is our view that the White Paper represents only a broad statement of the reforms intended by the Scottish Executive. A lot of detail still needs to be finalised from policy development, guidance, procedures, management and training. Consequently while the reforms presented in many aspects are encouraging it is considered that our response is one of caution until such time as this level detail is available.

The Law Society of Scotland: The Society welcomes many of the proposals contained within the White Paper in principal, although it takes the view that implementation of these will only be of benefit if they are supported by adequate investment in the capacity, skills and infrastructure of all planning authorities, including the Scottish Executive. The attempts to free up capacity by reducing or expediting the applications moving through the system are noted, but it is unclear whether these measures will make material savings and when any benefit will have impact. To work successfully at all levels, and to achieve good co-ordination and quality, and efficiency, the Society believes that proper allocation and ring fencing of resources to land use planning will be necessary.

Planning Consultants, Architects and Lawyers

Bell & Scott: In general terms we welcome the proposed reforms. However, we feel strongly that, whatever reforms are implemented, the system will be improved significantly only if:

• There is significant cultural change in the planning departments of the planning authorities.
• All planning departments are appropriately resourced.
• The training regime for planners and for Councillors is significantly improved.
• Planning authorities are able to compete successfully with private practice for the best planning talent.
• If the above four points are achieved, planners in local authorities are remunerated accordingly.

We recognise that some of these points are acknowledged in the White Paper but we are of the view that tackling the recruitment, training, cultural and resourcing issues are critical and accordingly must be given the highest priority. Other reforms will fail unless these matters are successfully addressed. The planning climate in Scotland must be changed from one which too often displays negativity and obstruction to one which is constructive and, where appropriate, imaginative.

Bruce and Partners: The current planning system is unfit for purpose and is a drag on the future prosperity and growth of Scotland. In general terms the White Paper proposals will go a significant way towards improving the social and economic climate to the benefit of all residents in Scotland. As the White paper indicates, "the primary role of planning should not be to stop development happening - it should foster development in the right places". This important shift in attitude is welcome. I would therefore urge that the previous presumption in favour of development be reinstated within primary planning legislation. A second concern is that without sanctions to ensure that the new system operates as intended it will continue to be criticized for delay and poor quality outcomes. Many of the proposals aim to encourage better efficiency and performance but legislation should make these a requirement. Finally, the present system fails where there are issues of dispute between applicants/users of the system and planning authorities/ Scottish Executive. Consequently, a new system of arbitration should be introduced which would allow such disputes to be determined by an independent third party.

Collar, Neil: While many of the proposals in the White Paper are acceptable in principle, the "devil is in the detail". More information is required. It is disappointing that there is nothing in the White Paper about making the law simpler, aside from the Permitted Development Order. Indeed, the proposals are likely to increase the law. There are many references in the White Paper to compliance with the development plan. Those references imply that compliance is a straight forward issue. In reality, determining whether a proposal complies with the plan requires account to be taken of many different policies, and deciding the weight to be applied to each. Windfall development is also a good example of how flexibility must be retained to deal with matters which could not have been anticipated in the development plan - there can often be sound reasons for granting permission contrary to the plan. Introducing a statutory purpose would bring more problems than benefits, because it would encourage more legal challenges, but clearer guidance on the purpose of planning would be beneficial.

Colliers CRE: In terms of an overview, we believe that many of the new suggestions for the Planning Bill to be considered in this term of the Scottish Parliament over the next 17 months are to be welcomed and that the Scottish Executive have to be commended for consulting widely on this 'White Paper' which will shape the future development of the nation. Once the 'Planning Bill' takes shape and is enacted, it is suggested that the period for consideration of the processes should be finished and there should be a fresh focus on the delivery of quality development, hopefully and ably assisted by the new Act.

Drivers Jonas: In general we welcome the intention to modernise the planning system. However, we consider that a number of the proposals require to be removed, refined, or clarified in order to have maximum benefit to an improved planning system.

GVA Grimley LLP: Generally welcomes the main themes set out in the White Paper for the future of planning in Scotland. Principally supports the proposed drive to modernise the planning system through a streamlining of the development plan system and the introduction of a hierarchy of planning applications. Also supports the intention to focus public participation in planning on the development plan system and planning application process, rather than the introduction of a third party right of appeal.

Hargest & Wallace Planning: In general it is considered that the proposals represent a significant improvement to the current planning system making it more "fit for purpose" creating a more efficient and accountable system. However the White Paper debate needs to move forward to consider the process of implementation - on how long the process of step change will take; the steps by which it will be achieved; what resources are required and how we know when the process has been achieved.The planning system should incorporate within it a clear statement of the policy priority ( e.g. as per SPP8). Our preference is that this should be, as stated in SPP8, to support economic growth. However, whether or not this, or environmental sustainability, is identified as the top priority it is important that the national planning system states this priority clearly - it is time for the Executive to come to terms with this and set clear guidance otherwise excessive resources/time will be wasted by all parties trying to assert that their objectives are those that are the "top" priority of the Executive.

Humberts Leisure Consulting: HLL support the thrust of the foreword of the First Minister on the basis that some of its clients who own mobile home parks are providers of modern affordable homes and its members represent a key element of the tourism economy of Scotland. HLL support the thrust of policy of a fair, transparent and equitable planning system outlined by Minister for Communities.

Keppie Planning Ltd: The white paper has much to commend it, subject to the caveats outlined earlier, however as in all statutory procedures much is reliant on the operating efficiency of the system rather than its set aims and objectives.

Ledingham Chalmers: A thoroughly modern planning system is what we need. We should not squander the opportunity of making a real difference to our future. The White Paper is one of many building blocks on the way to creating a new planning system but, as ever, the devil will be in the detail and we do not have much of that, at present. There is concern over the achievement of the stated objectives and fear that there will be some disappointment along the way. Streamlining the system should lead to financial savings but efficiency in terms of "end result" is what matters and is surely the measure of success rather than bean counting. Some Planning Authorities are under resourced and their staff is spread too thin. This means that some tasks which Planning Authorities should address are not receiving the attention they deserve. There is little point in penalising Planning Authorities which fail to meet certain benchmarks, if the planning system itself is at the route of the problem. I do not agree with penalties for non-performance by themselves - that needs to be balanced with a system of benefits for improved performance. I appreciate in the public sector that may be difficult to achieve but some thought ought to be given to this.

Maclay, Murray & Spens: The Scottish Executive consultation paper, "Modernising the Planning System", examines the scope for modernising the planning system in Scotland and proposes various new reforms with a view to introducing a planning system which is fast, efficient, inclusive and transparent. This intention is to be welcomed. However, we do have some serious concerns about the potentially negative effect on sustainable development and the resourcing implications of the proposals and these, along with other comments, are considered below. It seems to us that the White Paper recognises a compelling need to balance the competing interests of the developer and members of the public and that, in theory, this approach is to be welcomed. However, it is of concern to us that some of the proposals contained within the White Paper, whilst not at first glance seeming to be overly controversial, may, in fact conspire to make development more complicated and problematic than we would have hoped was intended.

Paull & Williamsons: Thank you for the opportunity to comment on the White Paper. In our view it contains the most significant proposals for change to the planning system in a long while, and changes that we believe to be appropriate for Scotland. We appreciate that the White Paper is attempting to balance a number of different and sometimes competing priorities. We think it does this successfully and that the proposals should go a long way towards achieving a better balance between development, community and the environment while at the same time speeding up the system and making it more open, efficient and accountable. While we have a number of comments on the individual proposals, we would emphasise that we broadly welcome the White Paper.

Roberts GM: Most of the reforms proposed for a system which is currently perceived to be 'creaking', are to be welcomed: However 'the devil may be in the detail' and in its application. This may however become clearer, when further draft consultation documents -such as reform of the GDO, Listed Buildings & Conservation Areas legislation etc are published.

Warren Consultants: It is implicit that the Scottish Ministers believe that the Scottish planning system, derived as it is originally from the 1947 Planning Act, is still robust and appropriate. If this is the unspoken conclusion of Scottish Ministers, we agree with it. The negotiation and "trading off" nature of the British planning system reflects the sophistication of British society with its tradition of fair play and impartiality and the general ethos of trying to accommodate all different viewpoints in a consensus. This degree of sophistication puts heavy demands on a planning system, but the British planning system has long proved itself capable of dealing with this. Whilst giving generally support to the White Paper, we are critical of its failure to acknowledge and "grasp the nettle" of inherent and long standing conflicts and dilemmas in the system e.g.

• public participation and a speedy efficient planning process are incompatible
• there will always be many situations where there are winners and losers
• more public participation might well lead to more dissatisfaction because if groups lose at the end, their frustration will be all the more
• There is an essential conflict between the dynamism of the development process and the static snapshot nature of Development Plans
• there is never an easy fit between strategic and more local plans

It was a feature of the 1947 Planning Act that there was a presumption in favour of the applicant i.e. the presumption was that the application would be approved unless it was in the public interest for the planning authorities to intervene to refuse the application or subject it to conditions. We think this presumption should still apply. We think the whole issue of neighbour consultation and dispute is a genie which has long since come out of the bottle and from a political point of view has to be an important feature of the planning system.

Academic Bodies and Individuals

Lloyd, Greg Professor: The proposals for modernisation do not radically transform the essential structure of the land use planning apparatus (in terms of its constituent parts), but taken as a whole the proposals do seek to make the practice of land use planning in Scotland more efficient, inclusive and dynamic. This is to be welcomed, and this concern reflects the contemporary political priorities and societal concerns to make governance arrangements work more effectively. Land use planning falls into this process of change. The proposals also serve to re-politicise land use planning, and expose it to greater openness, debate and political engagement. This will take place at a number of scales - from the Scottish Parliament through city-regional relationships through to local hearings by elected members. All are important, and furthermore each will also demand active cultural shifts in practice. This demands responsible and active political engagement, as planning serves to influence future patterns of development across Scotland. The translation of the modern system into an agenda for national territorial management will be the next step with clear priorities laid down for patterns of sustainable development that are appropriate to urban, rural and island Scotland. The emphasis on delivery and enforcement will also help raise a broader understanding of the spirit and purpose of the land use planning system by the public at large.

Macaulay Land Use Research Institute: There is much to welcome in this White Paper, particularly the focus on equity, sustainable development ( SD) and public involvement and the desire to create a more streamlined and fit for purpose planning system. It is the detail which seems to underlie many of the most potent conflicts between planners and their respective publics. The main thrust of our reservations concerns the fundamental tension between the aim to increase efficiency ( i.e. the speed at which decisions are made) and the aim of increasing public involvement. Efficiency, as the paper acknowledges, requires certainty and predictability, and is underpinned by a neo-liberal philosophy of the enabling state which aims not to control or prevent development, but to guide development to ensure economic prosperity (p.14). This focus on economic prosperity is at odds with the drive for equity and environmental protection, which are hinted at elsewhere in the paper. However, more time, more complexity and more iterations are counter to the principle of efficiency above. Given the importance of landscape considerations to the planning system and the determination of specific planning policies it is somewhat surprising that this issue has been neglected in the planning White Paper. We consider that issues relating to landscape need to be considered as part of a strategic planning framework which sets the context for future development. Such questions are now posed in the revised science strategy of SEERAD, which may provide opportunities for linking across departments of the Scottish Executive. We feel that the White Paper could make more mention of the Strategic Environmental Assessment ( SEA) Directive. The requirement for SEA of all plans and strategies imposes an extra burden on local authorities. It is not clear that this has been formally recognized with respect to the extra resources required and it is surprising that more information is not contained in the Chapter on sustainability. The White Paper should do more to help minimize the administrative burden by providing a PAN on SEA. The Executive's top priority is sustainable economic growth which, in our view, does not equate with sustainable development. Development is much more than economic and the White Paper needs to acknowledge the fundamental importance of the planning system in generating "sense of place", quality of life and other forms of social development. We support the aim of 'focusing public involvement in planning at the front end of the process' and we will endeavour to design relevant at the Macaulay Institute to inform the protocols and procedures that can aid in the delivery of this objective.

Universities Scotland: It is our view that the White Paper represents only a broad statement of the reforms intended by the Scottish Executive. A lot of detail still needs to be finalised from policy development, guidance, procedures, management and training. Consequently while the reforms presented in many aspects are encouraging it is considered that our response is one of caution until such time as this level detail is available.

Community Councils

Ardross Community Council: We welcome the main thrust of this paper, but in an effort to speed up the Planning Management process we believe that local input is going to have less importance rather than more importance, the professed aspiration. This is grave as although Local Officers seem very good at listening to the local view, members who are not from the local area and are not voted in by the local community seem to still have too much say in the Planning Process in our local area.

Auchtermuchty & Strathmiglo Community Council: We are as a 'community council' pleased to see the emphasis which is placed within the White Paper on 'public consultation'. We concur with your stated intentions to make the planning process 'transparent and fair'. We believe however that in many senses it will be a missed opportunity if the Executive does not in some appropriate manner, capitalise on its already existing resource of the 'community councils'.

Balmerino, Kilmany and Logie Community Council: In general the proposals in the White Paper are very welcome. The underlying objective to make the planning system more accessible to the ordinary person is the single most important objective of the White Paper. Only time will tell whether the measures suggested will succeed in doing so.

Charlestown, Limekilns & Pattiesmuir Community Council: The aims of the Scottish Executive in this matter are laudable. There is, indeed, a need to restore confidence in Scotland's planning system. There is a need to make it fairer and more balanced, and it has to become more accessible and transparent so that increased public participation is encouraged. The capacity of the planning system to contribute to sustainable development is vital. However, we have very grave concerns that the proposals in this document fall short of what is necessary to achieve these aims.

Croy & Culloden Moor Community Council: Our Community Council feels that the White Paper which has been produced does not accurately reflect the previous consultations. We are also concerned at how the consultation process took place.

Culter Community Council: Community councils in Aberdeen and no doubt throughout Scotland, have found the present planning system incredibly time consuming and unequal. We find it often contentious and frustrating and leaving us feeling we are continually fighting a rearguard action, usually without success, and therefore failing our community. The members of CCC were therefore pleased to find so much to agree with in your proposals. We are encouraged that the proposals will include increased public
participation from an early stage. We are also encouraged by the extra steps being put in place to make the system fairer.

Currie Community Council: We see little in the document to indicate the importance of the environment or recognition that communities need recreation space and good amenity, but we do see a good deal on the need for economic development. This does not represent a balanced approach to the places where we live, work and recreate. We agree that the planning system is slow to respond to commercial and economic needs, is unduly complex, intimidating (to which include unduly legalistic), unresponsive and lacking in transparency. We note that economic development receives a mention with no reference at all to preservation, conservation and improvement of the environment. Taken at face value, amenity appears to have no place in these proposals. We found the page numbering presentation unnecessarily confusing (and almost illegible). Paragraph numbers would have helped to identify specific text. Likewise, Appendices are not numbered consistent with the chapters they refer to. The combination of these points made for a more difficult assessment of a complicated document than was necessary. We noted only two references to "Community Councils", yet these are statutory bodies whose local knowledge and potential input could be of great benefit. It should be noted that there are other organisations such as Local amenity groups and Residents' Associations that have no less an interest in the community and may have been in existence longer than Community Councils. These should be allowed an "official" say in the shaping and alteration of Development Plans. Since TPRA has been dropped by Scottish Ministers, one would have expected a reference to the Commissioner for Local Administration in Scotland (the Ombudsman) but there is nothing.

Earn Community Council: Revision of the existing planning procedures is a welcome step forward. Cognisance of the declared need to protect the natural environment and local amenity is important - it is assumed that designated greenbelt areas are included. The proposed changes are welcome but will remain as ideals unless a more pro-active and transparent approach is taken on local community participation - in actuality by listening rather as 'tick box' monitoring.

Errol Community Council: We strongly endorse the Ministers' emphasis on social justice and fairness, and we applaud their determination "to build a planning system that balances the right of individuals to develop their property and the interests of the wider community". We do not, however, share their presumption that these proposals "will restore confidence in the planning system" among the population at large. We strongly endorse the Minister's assertion that "we need a system that is fairer and more balanced between different interests than has been the case so far." We strongly endorse the statement that we need "to allow local people to know exactly when key decisions which affect them are to be made, and how they can influence them."

Firth Community Council: Firth Community Council, Orkney would like to make the following comments in respect of the White Paper:

• to note that once an elected authority has made a decision, only in exceptional circumstances should it be overturned with reasons given, and;
• that 3rd party right of appeal should be continued, and;
• that Scottish Natural Heritage and Scottish Water are not publicly accountable bodies.

Fortrose & Rosemarkie Community Council: The Community Council is fully in accord with the Partnership Agreement (2003) commitment to strengthen the involvement of local communities, reflect local views better and to speed up decisions. The Community Council still has reservations that the emphasis on speedy decision making gives too much influence to developers, and indeed to the planning authority to push through plans which could be detrimental in the long term to local interests and aspirations. This tension is highlighted in the analysis of consultation responses to Getting Involved in Planning. Nonetheless, the proposals and action to be taken will alleviate the majority of the concerns of the many communities that responded to the earlier consultations.

Foulden, Mordington & Lamberton Community Council: Agree that the White Paper introduces some new and just improvements to the present system of planning applications. The large majority of residents are slightly relieved that there would be more certainty on what uses would be acceptable within this community's boundaries and would know what developments may be expected (or rejected) in the future.

Garioch Area Forum of Community Councils: The Garioch Area is much affected by the proximity of the City of Aberdeen which results, among other things, in a great demand for land for houses for commuters. While we recognise the need to provide housing, we do wish to preserve the character of our rural communities and the opening of the paper, we feel, gives an impression that the planning system is there to provide land for development. Much is made of the involvement of other authorities, but the impression remains that a never ending supply of land has to be made available to be built on. We feel that a more balanced approach needs to be stressed at the outset

Gatehouse of Fleet Community Council: We welcome the proposals that development takes place in the context of a long-term and inclusive vision for the future. We wonder what is meant by 'long term' as the proposed development plans are to be renewed every 5 years. The proposal to make it easier for people to get involved and help shape the future of their communities is welcomed, as is the aim of giving locals the confidence that their views have been properly considered. The requirement for planning authorities to give reasons for their decisions and to notify those who have made representations is an improvement on the current position.

Grange-Howard Community Council: The Community Council supports the aims of the Scottish Executive to secure a planning system that is efficient and balances the respective needs and interests of development, the environment and the community. It is particularly pleased to note that the system will provide for communities to be heard on planning and development issues and that their views will be taken into proper account in the interests of social justice and fairness to all concerned. Inclusion and transparency in the system and in the determination processes are welcome features. There is little reference in the document, however, to economic planning although demand levels; political decision and macroeconomic forces will be the major determinants of the nature, extent and location of future developments.

Greengairs Community Council and Greengairs Environmental Forum: The aspiration outlined in the White Paper gives the impression of a much more inclusive, integrated and forward looking planning system but the contents lack the specifics, power and control measures to deliver the vision. As the major stakeholder in the planning system we would be the first to agree the need for accessible public services, appropriate housing, an integrated transport system, varied recreational facilities and most importantly the need for sustainable development that provides sustainable employment, secure investments and a healthy economy for Scotland. The reforms outlined in the White Paper appear to be based on the myth that the public want to stop development and, as a consequence, have failed to deal effectively with the issues that are of most concern. The reforms do not include adequate measures to improve the quality of developments based the principles of, honesty, accountability, social and environmental justice and sustainability. There is no provision to reward Local Authorities and Developers who, on principle, apply good practices while penalising those who do not and cumulative impact has neither been defined nor given priority. The measures outlined will not improve the effectiveness of public involvement or make the system more inclusive, it will reduce the opportunity for genuine inclusion and opportunity to influence the development of our local area. Without TPRA we have no real resolution to the issues that are of greatest concern to us. We are concerned that the planning bill should include proviso for all of the systems that are still to be put in place to support the detail of the planning reforms outlined in the White Paper.

Helensburgh Community Council: The main structural proposals of the White Paper - especially the Hierarchy for Planning (p. 19), the National Planning Framework ( NPF p. 20), removal of the Consultative Draft Local Plan (and, for rural authorities, the Structure Plan), introduction of a main issues report (p. 70) -seem to have sound logic in outline, but much will depend on both the nature of content (especially of the NPF) and how the procedures are carried out. The HCC also considers that too little attention is given in the White Paper to the potential role of community councils in planning.

Hillhead Community Council: There are 5 major concerns over this premature white paper. It is not coordinated. The supporting provisions intended to make it work are not in place before this bill is to be effected. It does not accord with EU, UK and other Scottish legislation. Scrutiny and accountability are essential but absent. Delegation is problematic. Extension of permitted development is problematic. Some already permitted need to be reviewed. Numerous practical obstacles to achieving the stated ends are evident. The underlying assumption is that economic growth and development must take precedence over any other consideration. It fails to recognise that the environment in which those developments take place is an important factor in producing beneficial and successful development. Conservation areas are major contributors to the economy and attractiveness of a city yet do not receive any recognition of their significance in this paper. Cumulative development impact is not given sufficient attention. There is no coherence with complementary legislation such as EU, UK legislation and other Scottish Legislation (discussed passim), including The Listed Buildings and Conservation Act. Development and economic growth are necessary but need to be controlled if the best is to be forthcoming. Jobs and economic development are frequently abused and unaccountable reasons given to justify otherwise disputed developments. Has the Executive considered removing the presumption in favour of development? It was a post-war emergency measure. To remove this presumption does not mean that development will not take place, nor imply that it is not desirable. It might encourage better design, certainly better urban design, and a better sense of place by giving a bit more room for local authorities to dismiss designs which they consider inappropriate or poor pastiche. Scrutiny at all levels is essential, as is the right of communities to have some say in the developments directly affecting them. Both need to be addressed in the interests of restoring public confidence in the planning process and promoting good relations between governors and the electorate.

Kiltarlity Community Council: In general we welcome the emphasis on community involvement at early and all stages of the planning process, individual applications and local plans. However, we remain to be convinced that this can easily be achieved. Details provided of the Community Council's experience with Highland Council in relation to a local planning application, where we felt our views as a Community Council had been given no serious weight by either councilors or professionals. We can see the arguments for greater delegation to professionals, but we are afraid that this could make it easier to ignore community views and concerns. We would not wish to see any reduction in the role of community councils.

Kinghorn Community Council: Planning should be seen as the safe guard and a Means by which communities and populations see a balance between commercial development and the needs of the community. Where consultation is Transparent and honest there would be no need for planning to be seen as an 'obstacle'. Confusion in the Community arises from who's purpose is being Addressed. The cognisance of Local views is paramount to the validity of planning, as much 'local knowledge' and considered opinion may enhance the final outcome, especially in the affect on infra-structure and local environments, which are often forgotten in the 'big picture' of national aspirations or commercial gain.

Knightswood North Templar Community Council: It is the conviction of this community council that this Bill, whilst appearing to promote sustainability, fairness, inclusiveness, transparency and participation, in fact achieves quite the opposite. We also believe that rather than improving efficiency, achieving fairness and reducing bureaucracy, the overall effect of the bill will be to reduce democracy and bring into question the independence of the system.

Largo Area Community Council: I regret that although advised extra copies of "Modernising the Planning System" could be obtained, when a request was made I was told none was available. This suggests widespread consultation is restricted.

Liberton Community Council: We were most interested in this paper, though we are not sufficiently expert to do it full justice. We note that some of the proposed improvements have already been implemented in Edinburgh, eg published Planning Lists (also available by email) and 3 weeks (rather than 2 weeks) for objections/comments. We have been particularly helped by the availability of plans on the Council's web-site and the similar availability of the officials' reports three working days before the planning meetings. It puzzles us that some local authorities (eg South Lanarkshire) do not allow even the copying of plans. It is difficult to take these in during a visit to council offices.

Linlithgow Community Council: We feel the present planning system fails to respond to genuine community concern. If the Planning Bill delivers a plan-led system that is open and account, a fairer system, a sustainable system and a more inclusive system then it will have taken into account our concerns. We would say, however, that the appropriate resources would need to be made available to ensure that the above objectives are met.

Newburgh Community Council; The White paper has many attributes of which, we, on the whole, are in agreement. Newburgh Community Council recognises that planning is in real need of improvement and modernisation.

New Cumnock Community Council: This White Paper is written in fuzzy language with heavy reliance on jargonistic and 'buzz' phraseology that all sounds very nice although with little substance but it does not outline in practice any advantages for communities such as ours where planning procedures are heavily weighed against us for large scale applications. Whilst the comments in this document alluding to greater opportunity for community involvement in the planning process are welcome it is not at all clear how this is to be implemented in practice

Pitlochry & Moulin Community Council: How much, if any, notice will be taken of comments that ourselves & others will make. We say this after seeing a large majority of respondees request TPRA yet it is conveniently stated that it will not happen.

Portobello Community Council (and Amenity Society): The White Paper is quite difficult to interpret and very repetitive. It is hoped that the actual new planning legislation itself will be easier to follow and understand.

Royal Burgh of North Berwick Community Council: The general drift of the document is about planning directed towards the Executive and macro planning carried out by local authorities individually and grouped in specific areas. We ourselves already see one of the unfortunate consequences of this approach here in East Lothian with respect to our "Local Plan. Our plan is not structured by community hence there is little incentive for individuals to read it or understand its consequences We think that this is wrong and that the structure of the plan should be aimed at the consumers of the product and not the authors.

Salsburgh Community Council: The White Paper has much to commend it, such as the introduction of a National Planning Framework, new procedures for various types of planning applications, introduction of a single proposed plan for Local Authority areas with regular reviews avoiding the need for indulgent interim alterations, greater use of e-planning, requirements for authorities to give reasons for their decisions, the ability to decline repeat applications where amendments are introduced solely to circumvent opposition to the original application, making the planning system more inclusive to give local people confidence that their views have been properly considered as part of the decision making process, delivering a fairer, more balanced system, diminishing the sense that applicants have an inherently privileged position in the planning system. The community council would concur fully with the White Papers statement that 'the credibility of the system depends on the fairness and transparency of the process, and the quality of the decisions and their outcomes. Securing this credibility is the challenge that this White Paper seeks to address.' It is doubtful if the White Paper for all its good intentions and positive features will bring about a sea change in public participation at the front end of the planning system. Many people do not become involved or take an interest in local government matters until developments or changes are staring them in the face. It is not unusual for members of the public to be unaware of many issues even though some would suggest, developers and local authorities especially, that information regarding the issues, whether planning, development or whatever have been available and widely advertised.

Strathblane Community Council: We welcome the opportunity to comment on the white paper and hopefully bring influence to bear on the bill when it is published. The paper is full of warm words of community involvement and once in a lifetime opportunity to influence change in the planning system. If that is to be the case why is the consultation period of 10 weeks overlapping with the peak holiday period during which members of any community group will have limited availability to read, digest, consult and agree a reasoned view of these proposals? If this is the beginning of real community involvement it does not bode well for the future. We need a planning system that will enable us to live in a much more settled and happy environment where decisions have been taken after a full, free and frank discussion that is completely transparent. On the face of it this appears to be what the white paper is trying to deliver but it is short on how this will be done.

Tarves Community Council: The White Paper appears to be a step in the right direction, albeit not far enough. The general view of our Community is that there should still be some form of third party appeal. There have been many cases in our area where planning applications have been granted against both Local Authority policies and public opinion (including MSP's). The proposals in the white paper don't appear to be strong enough to deter or control the level of inappropriate development we seem to be having thrust upon us in rural Aberdeenshire. The theory of seeking more community involvement and strengthening this will never be born out if communities' opinions are continually ignored.

Torphins Community Council: We saw little evidence in the report that attention is being paid to future economic prospects and the need for there to be greater equality between developing countries and ourselves. We believe that the planning system should accept that at least a diminution in growth will occur as this process takes place and should be making it possible for people in Scotland to live their lives in a more self-sustaining and self-reliant way in response to this.

Voluntary Organisations

Avondale Civic Society: The White Paper makes many of the bland comments one would expect. The devil will be in the detail of the bill. It is therefore difficult to disagree with much of the paper.

There is no doubt that there are failings in the way the planning system in Scotland operates. However it is slightly simplistic to merely blame the system. A considerable part of the problem arises from the demand placed on the current legislation and procedures to deliver political rather than planning outcomes. The prime example of this is the continued pressure on speed of decision making rather than its quality. In addition, there are continual demands for public participation. Until a reasonable balance is struck between speed, quality and public involvement in the planning process, it will continue to malfunction.

Cockburn Association: On the whole the Association supports the Executive's ambition to create a less adversarial planning system. We do however believe this is more likely to be achieved by introducing a limited Third Party Right of Appeal and have proposed a way forward which we hope you will find constructive. The Cockburn Association supports the Executive's ambitions to: allow for the planning system to secure good places to live; develop a system that is fast, inclusive and transparent; build trust between communities and developers; develop a system that takes a long-term strategic overview seeking to secure sustainable development as well as control local detail; and serve a national purpose, as well as helping local communities to shape their own future at a local level. While the Scottish Executive's top priority is promoting sustainable economic growth, Geddes ambition was much more holistic, in encouraging local people to take charge of their own built environment. The Association believes that Geddes' vision for citizen involvement has been lost in a reactive and over-bureaucratic planning system. The Scottish Executive's ambition for fairness in the planning system we believe will only be achieved by a culture change in the planning system and creating a power balance in bringing decisions closer to local people. The White Paper Modernising the Planning System is a good starting point and needs to accommodate the introduction of a limited Third Party Right of Appeal.

Colinton Amenity Association: We welcome the general thrust of the White Paper in seeking to make the planning system more efficient, transparent, and easier to understand and to foster the greater inclusion of local communities in the process. Many of the proposals will provide a more level playing field for all parties involved in the various procedures of the planning system but more are needed. There is considerable emphasis upon the expedition of decision making in planning to facilitate the priorities for growth. There is a non sequitur between this primary aim and the oft repeated statements of seeking more balance in the system. We strongly support a more balanced approach, but how this is to be achieved, relative to the primary growth aim, requires to be made more explicit.

Dumfries Friends of the Earth: As an overview we would comment that although there are criticisms of the current planning system, any change to it means a loss of accumulated community knowledge about planning as well as a need for the community to 'learn' about the change and what it means. This is difficult for community groups and individuals with few resources and limited or no access to professional advice. Therefore, any major change has to be justified by comparison with improvements to deal with the defects of the current imperfect but tried and tested system. In this case, we are far from convinced that the new system will, even after a lengthy bedding in, mean any net improvement. We recognise the two main criticisms of the current system, that it is not effective in delivering planning decisions and that it does not take due account of the views of local people. We think that the Executive is naive and mistaken in its view that a modernised system can be designed to it satisfy both of these complaints.

East Kilbride History Society: The proposed changes to the planning system in Scotland have merit, to a greater or lesser extent, and are certainly required and welcome.

Energy Saving Trust: We are keen to see a planning system in Scotland that fosters the aim of reducing carbon-emissions and mitigating climate change.

Friends of the Earth Scotland: We note that the White Paper contains a number of positive reforms to the planning system, such as the statutory provision to require development plans to be reviewed every 5 years and the requirement for local authorities to give reasons for all of their planning decisions, and we welcome these. We also support in principle the aim of establishing a hierarchy of planning decisions within a development plan-led system. We see this as an opportunity to ensure effective subsidiarity and devolution of as much authority as possible to communities. There are, however, three highly significant areas in which Fo ES believes the proposals represent a major missed opportunity for making Scotland's planning system a more efficient, fair and just one that enables high quality, sustainable development in line with the needs of Scotland's people and its environment. The first three sections of this response cover those three areas: the National Planning Framework, widening rights of appeal and sustainable development.

Galloway Preservation Society: Planning policies suited to Central Belt cannot respond to situations in Galloway. We strongly advocate that the planning system should be designed to take account of special circumstances in SW Scotland. Instead of being a burden the system should encourage and make positive contribution to the environment. Galloway, an area of low investment, requires planning to respond to and facilitate small scale developments, be flexible to react to local situations and circumstances, and adopt procedures to encourage rather than inhibit development

Garden History Society: In general the Garden History Society supports the Scottish Executive's aims to modernise the existing planning system, and considers that the White Paper will go some way to achieving these objectives. However one of our main concerns is that "streamlining" the system will be at the expense of achieving quality on the ground, when one of the main goals of a modernised planning system for Scotland should be for a higher quality outcome. If this is to be achieved it is only too clear that the planning authorities must be properly resourced in terms of staff and skills and from the current level this is going to require significant additional resources.

Gatehouse Development Initiative: An excellent paper. Making sustainable development the top priority is just what we need.

Greenhill and Church Hill Amenity Association: In our opinion, "growing the economy" has to be done in a fashion which spreads opportunity as widely as possible throughout the country. We think that the central planning function has yet to give sufficient emphasis to this. In our opinion, the "national purpose" will not be served by allowing headlong and unsustainable business expansion within the Lothian Region. It requires that the maximum effort is made to divert significant amounts of it to other areas of greater need in Scotland. If higher quality design is to be achieved, all major development proposals in environmentally or culturally sensitive areas will have to be subject to some form of "peer review". These should be carried out by panels of accredited representatives drawn from a wide range of professions and experience. "Regeneration of deprived areas" should be at the head of the planning priorities list - not last but one. It will not be achieved by the injection of public funds alone. It will require firm policy guidelines by Central Planning to support local planning authorities in their determination of - and attaching conditions to - planning permissions. The stated aim in modernising planning to facilitate rather than obstruct high quality appropriate development looks to us like another pious expression of intent. Who is to be the arbiter of what is "high quality appropriate development"? Past experience shows that the public's lack of confidence in the judgement of planning officials is amply justified. Real quality assurance in planning applications has been provided up till now by public-spirited citizens, either individually or through their community bodies. Without such contributions, much recent development would have been of significantly lower quality, and in many instances, much more intensive. How will the conflicting aims of developers to maximise the returns on their investments and local planners to raise development quality to be reconciled?

Greenspace Scotland: The proposals represent the potential for a significant advance in making planning relevant to local people and communities. We see in our work, and it is generally recognised, that under the current planning system the general public is largely disengaged and usually only interacts at the stage when an application is made for planning permission or when permission has already been granted. We therefore strongly welcome the intention expressed in the White Paper to engage local people "at the front end of the process" and "at the right point in the system to be able to influence outcomes". In summary, we broadly welcome the proposals in the White Paper for a plan-led system with an increased emphasis on the involvement of local people at the front-end of the process. However, whilst we welcome the intent of the proposals, we have reservations about the ability of the established planning system to deliver 'meaningful' public involvement without significant culture change, training and resourcing; to deliver significant step change will require more than legislative change.

Helensburgh Green Belt Group: Our main area of concern relates to implementation of the White Paper's intentions about public and local community involvement in planning. We support for many of the proposals for greater inclusiveness, but while several technical and valid opportunities for the public to be consulted are listed in the White Paper, it tends to be consultation (late and reactive) rather than involvement (early and proactive), .there is inadequate back-up envisaged for the public, and for local voluntary organisations, and .the proposals have been conceived from the planner's point of view and not with the difficulties of the public and local community groups in mind. The White Paper refers often to 'balance' and 'fairness' but we discern in it an imbalance towards commercial development at the expense of local wishes and long-term environmental benefit. That seems to us to constitute unwise imbalance.

Helensburgh Study Group: The White Paper is rather awkward to read and we sensed some political spin. The lack of paragraph numbers makes cross-referencing more difficult. In our view, the Bill will need to be clearer and to have a glossary defining all terms, especially those concerned with inclusion. It is our understanding that work on the Planning Bill is already well advanced. Comments, if so, the White Paper would not seem to be fulfilling the usual whitepaper function of generating open debate. Also, the time scale for comments is very short for such a complex and important document. Our special concern is inadequate recognition of the practicalities of local community involvement in planning, much though we welcome the principle. To assist in this important aspect, we have prepared a separate paper on this one aspect since we believe that there are ways to help rectify this problem. The White Paper does not sufficiently acknowledge that there can be bad as well as good commercial schemes, proposals insensitive to community and environmental aspects as well as those which are sensitive. The White Paper does not seem sufficiently to deal with the issue of what we call "civic conscience".

Highland Perthshire Communities Partnership: We support the Scottish Executive's aims to restore confidence in Scotland's planning system and secure a fairer and more balanced system. In general we support the measures to improve efficiency, achieve a greater sense of equity in appeals systems and ensure that development is sustainable.

Inveresk Village Society: The Society shares the view that there is a major problem of confidence in the planning system at present and is looking for measures to address this. It feels that there is much in the White Paper to be commended, notably neighbour notifications becoming the responsibility of the local authority, the requirement that reasons be given for planning decisions and making it easier for local people and organisations to get involved in the plan making process. However, it has doubts that what is proposed in respect of development control/management procedures will, in effect, make a difference unless developers and councillors alike actually listen to what local people have to say and then act upon it.

Kilmacolm Civic Trust: We are struck by the strong emphasis placed on facilitating development in the executive summary. Of the six points featured as "proposals for modernisation" all but one concentrate on development -the exception being devoted to making it easier for people to get involved. We see a shift in favour of development and developers in general. Concerns such as accountability, straightforwardness, and making the system less intimidating appear to have been dropped, at least in terms of vocabulary. This is regrettable -the stated objective to achieve a wider measure of interest in members of the public is now less convincing.

Lister Housing Co-operative Ltd: We are a small housing co-operative with 184 flats in Central Edinburgh, with a strong record of involvement in community and planning issues. WE urge the Scottish Executive to revise their proposals to reinstate full democratic involvement with National Developments.

Mountaineering Council of Scotland: The introductory line to the Executive Summary claims that the "White Paper sets out the way forward for Scotland's planning system". There is a certain "fait accompli" ring to this sentence and the impression is given that this is a legitimising exercise for a way forward that has already been decided. We hope this is not the case and that this consultation exercise is genuinely looking for public engagement with a view to influencing the Executive's thinking, and developing a workable and efficient Planning Act that will contribute to Scotland being regarded as modern and vibrant.

Peebles Civic Society: We certainly agree with the proposal to 'strive for high quality design in all new development'. Accordingly, we believe that the new Planning Act must provide a more effective planning system for producing quality development which respects the environment - i.e. the right design in the right place. Only if it does so will the Scottish countryside, towns and cities continue to be an attractive and sustainable environment for residents and also a magnet for the visitors that are necessary to sustain an essential tourist industry.

Planning Aid Scotland: PAS welcomes the objectives of the White Paper to improve the efficiency of the planning system and to widen inclusion. These are all changes that will be more effective if citizens and community groups have an understanding of the objectives of the changes and the procedures applied. The new Planning Bill will be an opportunity to facilitate and empower citizens and community groups to become involved in planning decisions, not to frustrate development but to arrive at more inclusive and sustainable decisions. In this respect, PAS is pleased that its work to train community groups and to provide advice on individual cases is acknowledged in the White Paper. The package of proposals is ambitious and successful implementation will require a focus on two aspects: firstly, cultural change amongst all stakeholders in the system, and secondly, the resources available to facilitate these changes.

Pollokshields Heritage: The thrust of this White Paper is the achievement of economic growth and development. It is a fundamental attraction for economic development that there exist areas of high environmental value and excellent design quality. We suggest that Conservation Areas are attractive jewels, indeed a fundamental asset to the Scottish economy. They are attractive as places to live, for leisure and culture to many of those who activate Scotland's economic development. We are concerned that historic environments are not given any priority in this White Paper, thus many of our comments seek to enhance the recognition of Conservation Areas status within this new proposed Planning legislation. We found the structure of your White Paper difficult, in particular, insufficient paragraph numbers, the lack of a clear contents page and index, has made it challenging to structure our comments thereon.

Portobello Campaign Against the Superstore: The White Paper is to be welcomed as it does give communities some say in the future of the areas in which they liveHowever, as with many things, the devil is in the detail and the good intentions of the primary legislation may be watered down by subsequent guidance as to neuter the original intention. Guidance needs to be reworded in language that is simpler to understand and more specific so that convoluted interpretations cannot be advanced by those developers who seek to gain the slightest advantage from playing with words. Without this simplification, greater inclusion will not come about. It has been reiterated that this is a package and has to be taken as a whole. Does that mean that if some part is not accepted then the whole fails and you end up throwing out good improvements. If it has to be a package, then why are you consulting in this White Paper? The need to educate communities is paramount to the efficacy of the proposed planning regime. Certainly planning authorities are so risk averse that even with very good cases they back away from taking legal action. Anything that can be done to guard planning authorities from the threat of legal actions is to be welcomed. In conclusion, the White Paper does offer communities an improvement in how they are treated by the planning system. The new system should enable more local people to engage in an effective way but much still has to be done in developing guidance on consultation. Existing planning guidance is not addressed in this document and if these are not understood by communities the Executive's intention of greater inclusion will not be achieved.

Quarry Traffic Monitoring Group: We note and agree with the First Minister and his Deputy that a key priority must be a 'fairer, more balanced system '. Our experiences suggest that this will be difficult to achieve without a fundamental change in attitude by Council officials. Local views are currently not being listened to. There is overwhelming public support for TPRA. A manipulative tweaking of the existing discredited system as proposed in this White Paper will do nothing to restore public confidence.

Ramblers Association: Concerns that the interests of people and communities will be less well served than at present. The proposals represent a centralisation of decision-making that we do not consider to be a positive development. The Planning White Paper is a much needed revision of our planning system; however, the emphasis appears to be squarely on economic development, and the social and environmental aspects are more weakly represented. In addition, the document appears to be addressing the needs of the built environment, while the rural environment is influenced by a raft of various other legislative and financial instruments. The Development Plan for any area should take account of other measures which affect how the area is developed and aim for a more integrated view of how these forces shape the land.

RSPB: We welcome the publication of the white paper and many of the proposals it contains. We agree with some of the analysis in the Paper, for instance, that planning has sometimes been slow, lacked certainty, and resulted in out of date plans. Some aspects of the system need attention. However, planning has also served us well as a nation over the last 50 years, including helping to protect important assets such as our countryside and wildlife habitats. It is essential that whatever new planning system is created it addresses existing weaknesses and it is capable of delivering improved planning for the next 50 years.

Rural Scotland: The White Paper covers a number of complex and interwoven messages. It is very difficult to follow. Many of the important issues are confined to the Appendices and these are poorly signposted in the text. It would have been helpful to have made a clearer distinction between changes and procedures to which commitment already exists and completely new proposals requiring more detailed comment. The inclusion of a glossary would also have helped in the understanding of the document. Any future planning legislation should take careful account of the forthcoming sustainable development strategy for Scotland with careful balance of economic, social and environmental objectives. Having a stated top priority of economic growth is incompatible with achieving that careful balance and sustainable development. The Purposes of Planning listed should specifically mention protection of the environment. RuralScotland is particularly concerned to ensure that whilst the planning system deals with matters expeditiously it should not be at the expense of the quality of decisions. The proposed increased emphasis on a plan led system is clearly to be welcomed though there is a lot of detail to be added to ensure that laudable sentiment becomes reality. Greater recognition is also needed of relations between planning and other policies e.g. energy policy at the Scottish level, with community plans at the local level. The White Paper lacks explanation as to how the planning system in future will integrate with other legislation/policy e.g. energy, waste and transport. We are particularly concerned that more attention should be paid to the links between rural resource development, land management and spatial planning in achieving sustainable development in rural policy.

Scottish Civic Trust (and Civic Trust Network): The Scottish Civic Trust broadly welcomes most of the ideas set out. Many of the proposals are long overdue (such as a statutory requirement to keep development plans up to date), and we fully support the intention to keep the development plan at the centre of the planning process. The Trust has serious reservations with regard to specifics. Indeed, we believe that some of the proposals as set out should not be supported, and need considerable reflection and review. We are also concerned with the number of areas in the Paper that are to be the subject of further study but where definitive proposals are made. The review (or lack of) of the historic environment and Permitted Development Rights come to the fore in this regard. Finally, we accept that the review of the Planning System is necessary and timely. The Trust is very concerned with how little there is in the White Paper aimed at improving the quality of development on the ground, as noted elsewhere in this letter. Indeed, the Partnership Agreement highlights the improvement of the urban landscape by a more effective system of conservation and design. The Trust is very concerned with regard to the level or capacity and resources available to deliver the proposed "front loading" of public input at the development plan preparation stage. There is a concern that the Executive has grossly underestimated the interest and capacity for local people to be engaged in the development plan process. It is also felt that the LPAs are currently ill equipped to undertake this type of participatory consultation.

Scottish Council for National Parks:SCNP welcomes the opportunity to respond to the White Paper consultation. Much has changed since the first introduction of Town and Country Planning legislation in Scotland and as such this effort to modernise the system, into which a great deal of work has clearly gone, is to be commended. SCNP welcomes the recognition that planning is at the heart of promoting sustainable economic growth, plays other vital roles in the communities and is a key contributor to environmental quality and pursuing the case for high quality design throughout the built and natural environment. Good Planning Authorities operating a modernised system which is fit for purpose, efficient, more inclusive and sustainable will not achieve the desired end product alone. It is fundamental that all the other public sector bodies and skills have to be applied to the same end. SCNP wishes to see that greater efficiency is more concerned with quality of decision making rather than merely speed of decision making. This desirable aim is obvious to the public but does not feature as it should in the White Paper.

Scottish Council for Single Homeless ( SCSH): Welcomes the Executive's commitment to reform the planning system and agrees with the overall aim(s) set down in the White Paper. We feel, however, there is a need for greater emphasis on specific measures to resolve Scotland's lack of available affordable housing. The SCSH and CIH report "Is Anyone Home?" estimates that approx. 7,000 affordable rented homes are required each year to meet the need for affordable rented housing. Currently, approx. 5000 are planned each year which we believe will be insufficient, especially in light of the forthcoming introduction of new powers as stipulated in the Homelessness (Scotland) Act 2003, and the continuing loss of rented accommodation through the Right to Buy. In addition, SCSH is keen that any new planning system should not unreasonably hinder the development of specialist and supported accommodation projects.

Scottish Council for Voluntary Organisations: contends that the current planning system is failing for three reasons outlined under the following headings: local development plans, representing the community, symmetrical rights of participation and appeal.

Scottish Badgers: Scottish Badgers have grave concerns regarding the current planning system and repeatedly come across examples where poor planning has led to damage to badger setts, loss of foraging resources and in at least one case to the complete loss of a social group. We constantly come across the situation where planning has been consented without the application being referred to statutory authorities such as Scottish National Heritage for comment.

Scottish Environment LINK: The Planning System plays a key role in protecting and enhancing urban and rural environments. However, experience of working with the existing planning system leads us to believe that unless specific changes are made to it, it will increasingly fail to deliver for the Scottish people and their environment. We are looking for Scotland to have an efficient, fair and just planning system that enables sustainable development in line with the needs of Scotland's people. The system should be fair in how it treats different applicants and in how it balances the interests of those benefiting from development and those impacted adversely. The system should promote quality development through open, fair, participatory and accountable decision-making processes. The Scottish Executive's commitment to reforming the planning system is welcome, as are some of the specific measures within the Planning White Paper. We believe the White Paper seeks to re-focus the planning system on development planning, which should increase certainty and efficiency for all of those involved with, or affected by, the planning system.

Scottish Federation of Housing Associations:SFHA welcomes the Executive's commitment to reform the planning system. We welcome the proposed changes to the system and reforms, particularly proposals relating to sustainable development and strategic planning. However, with the acute shortage of good quality affordable rented housing in so many areas, we have been disappointed that as it stands the practical implications of the proposals contained in the White Paper are that the Executive's Bill will not address the issue of the availability of land for the development of affordable housing. The introduction of a comprehensive Planning Bill provides an excellent opportunity to address those problems and bring forward mechanisms to speed up and facilitate the release of land. Yet the issue was barely mentioned in the White Paper. SFHA is calling for a reformed planning system to operate effectively at both strategic and operational levels, with policies that are locally informed, locally owned and locally accountable. Most importantly, a reformed planning system must be effective, enabling and proactive, whilst being user friendly and productive.

Scottish Health Impact Assessment Network: Many of the proposals in the white paper, such as streamlining the development planning system and the proposed hierarchy of plans, are welcome. More public consultation and the decision to make neighbour notification part of the planning authority responsibility are also desirable as is the commitment to sustainable development. It is essential, however, that the time set aside for comment on development plans (as outlined in the 'consultation statement'), particularly the 'proposed plan', is sufficient to enable meaningful input from all stakeholders. Our comments focus on how health issues can be considered in planning, a topic which is of increasing interest to professionals working in the NHS and other organisations. Health issues are notably absent from the white paper.

Shelter Scotland: Shelter welcomes the overall objectives in the Planning White Paper, particularly the aim of improving the efficiency of planning and creating a positive and dynamic system. However, we feel that too little emphasis is placed upon meeting the needs of those most acutely affected by the shortage of affordable housing in particular areas. The Executive's Review of Affordable Housing acknowledged that the planning system has an important role in supporting the housing market and development of new housing including affordable housing

Private Individuals

Anonymous: It is correct to say that the present planning system is in tatters, in a state of disarray and held in disrepute. This is because: - (a) the revision, updating or modernisation is long overdue; (b) the social mores have changed and any revision must take this into account. The present day deliberate and studied defiance of planning laws can be controlled only by making a breach a criminal matter; (c) the enforcement of planning control has been and is derisory; (d) The arbiters of planning - mainly councillors - have been unqualified, untrained and not monitored; (e) there has been no national application of principles in the planning development control system, (f) the inquiry reporter system of appeals is seriously flawed and should be terminated immediately; (g) the control exercised by the Scottish Executive and its predecessors, over the operators of the planning system has been lacking in coherence (h) the serious verbosity, the lack of specification, the lack of concise and unambiguous descriptions of control in most of the publications, circulars and PAN documents (i) the failure to study superior planning systems, for example in Sweden, Denmark and the Netherlands (j) the irresponsible extension and distension of the Human Rights Act in allowing special group pleadings, which defeat the most important principle of that Act, namely, equality among groups of people; (k) the failure to insist on only persons professionally and academically qualified in planning to head the relevant local council departments. The key to a satisfactory new planning system is to have effective control of the participants, in a manner which consists of: (i) treating breaches of the planning system as a criminal offence; (ii) giving Councils instructions to fine substantially both perpetrators and their agents and any body supplying goods or services to these perpetrators; (iii) barring these perpetrators and their agents from applying for any planning permission for 5 years; (iv) and ensuring only professional and academic and educated persons operate within the planning system.

Anonymous: Modernising The Planning System does include several proposals that are very unwelcome in a democracy. The detachment of the National Planning Framework from the appeals procedure is quite undemocratic in that community involvement (trumpeted throughout the document) is completely excluded from the largest projects i.e. those that might impact most on communities. The whole ethos of the document tends towards centralisation and stereotyping ( e.g. introduction of model plans) which will tend to stifle local and regional differences across Scotland. There is a very real danger that developments will be imposed from above and outwith local influence and those developments, by their very scale and scope are the ones which will have major impacts on communities - a right of appeal ought therefore to be available for all proposals. Democracy is worth a little delay. As far as other appeals are concerned, where a proposal is rejected by the local authority it is far more satisfactory to hold a PLI rather than rely on written submissions so that local opinion can be expressed in an open forum, albeit a daunting one. The public perception of planning matters (and for those matter public consultations) is that the powers that be and the developers have made up their minds what they want. They will take part in the required process and carry on their own sweet way. I am afraid that I do not see anywhere in this document anything that changes this perception. There is to be no right of appeal in the nationally important proposals, and further down the line I do not find any concrete suggestions as to how communities are to be motivated, inspired or trained to take part in consultations about Development Plans. It is my experience that communities only take an interest in planning affairs when their own environment is threatened and not until then. It will take a huge sea-change to alter this.

Anonymous: The White Paper is very welcome. Revision is long overdue, but it seems to miss some important points

Armstrong, Pam: I agree with the White Paper view that," In a modern and environmentally responsible Scotland the environment and sustainable development must be at the heart of the planning system." I hope this is reflected in planning practice.

Barham, Paul: The most positive aspect of the modernisation proposals would appear to be the emphasis given to sustainability. This ought to give a sound basis both to national planning policy and to the preparation of local guidelines. However, the White paper also contains much that should give cause for concern.

Bramley, EM Mrs: Planning and the Planning system is the unsung hero both of and for environmental protection. It does offer the opportunity to bring communities together: it still includes as was stated following the 1947 Act that 'Planning law is not an end in itself, but the means by which are regulated the activities of public and private enterprise alike, in the development of land'. It does provide a degree of certainty and direction: however, the emphasis has often been on the need for a balancing act (business/people and the environment) -should not the challenge for 2005 be for planning to be led by the need to integrate need and reconcile differences, so that rural areas and landscapes are protected from damaging development, that urban regeneration is made apriority, that planning continues to become more accessible and a tool for serving both the public and the public interest by sustainable and beneficial land management.

Bryce, Ian: The White Paper appears to concern the urban and suburban areas of Scotland only. There is no recognition of the value to the nation of the scenic and wild land qualities of sizeable parts of Scotland, nor any corresponding recognition that developments which impact upon those qualities should be less freely allowed than others. These qualities do have value, both an economic one in fostering recreation and tourism, especially to areas with few other resources. These qualities are of significant value to Scotland's populace in allowing them to take leisure or recreation in unspoiled surroundings and generally promote a healthy lifestyle. Moreover, under biodiversity legislation, Scotland has international commitments which are not adequately dealt with in the White Paper.

Dalgleish, Karen: It is a major concern that throughout this White Paper there is no recognition, in delivering an improved Planning System, of the key role minerals has to play in the provision of the base materials to those 'building block' elements identified in Section 4.2. Natural resources in Scotland may often occur in areas of natural beauty and of ecological interest. However such natural resources are vital to the provision of industrial minerals and aggregates into society. Unless the important primary role of minerals provision is recognised at the outset by all involved in the production of Development Plans, then all that flows from such provision is in jeopardy. It is also noted with concern that where minerals are referred to it is in the context of bad neighbour developments. Minerals can only be worked where they are found. There must be significant raising of awareness in the public mind and within the planning system of this fact. It must also be understood that not all minerals are worked in the same way and that any related impacts may be quite different. Policies applicable to opencast coal should not be applied to quarrying. Blanket policies and exclusion zones should not be applied. We conclude that the Planning White paper takes inadequate cognisance of the role played by minerals in our society. There has been a failure or reluctance for Planning Authorities to identify minerals resources on Development Plans and to safeguard these from encroaching development. This is also manifest by Statutory Consultees. Reform of the planning system to deliver development as set out in the White Paper must address these matters.

Francis, Ian: Developers should not have more rights than third parties, including individuals, communities and others, in the planning system. The current inequality must be addressed.

Graham, Bob: Underneath all the gloss and spin this white paper merely represents a further erosion of the democratic process.

Greenlaw, Mrs Floris H.: While the tone of the White Paper appears to favour development as against conservation, there is much to be commended in the document, especially in relation to speeding up the planning process, delivering relevant up-to-date development plans and strengthening enforcement. While I have reservations about procedures for dealing with developments of national importance, and the Executive's wish to deny even a restricted third party right of appeal, I will leave detailed arguments to others and confine myself to the comment that a great deal more publicity and consultation is needed in drawing up/reviewing the National Planning Framework than was evident prior to the adoption of the first one, and utilities must be required to commit themselves to relevant infrastructure investment. The planning system must do more to assist in the delivery of affordable housing. Without more/improved facilities for planning education at Scottish universities, and an increase in planning staff and other related resources, much of the vision in the White Paper will not be realised.

Henriksen, Neil: I have engaged with the planning system for only five years. Three major proposals, all thus far unsuccessful, cited as evidence that developers 'play' the system. Explains that these have involved local people engaging with the process in many hours of our time and much expense on newsletters, meetings, phone calls, etc. In each case there has been (possibly routine) manipulation of the planning system. Hence my feeling that special pleading by battalions of big developers has resulted in a marked bias in the white paper.

Hopkinson, Sue: I am pleased at the repeated emphasis on environmental considerations, as at "whilst protecting our most important natural assets" "recognising the need for development plans to respond to requirements to meet our wider environmental obligations at European and international level" "Our aim...to protect our heritage and environment" and "development plans will be prepared in a way that.....ensures environmental concerns are taken into account"

Lauder, Alistair J: I agree with much of the content of the Paper and am delighted to see some long needed reforms coming forward. There are a lot of good proposals that will have the desired effect of making the planning system better for local people and users of the planning system. I appreciate that obviously much will depend on the detailed wording in the forthcoming Bill.

Macadam, Ian: Excellent report

McDougall, Duncan: I welcome your acknowledgement of the primacy of Development Plans; a matter which seems to have 'slipped' under present circumstances. There is much mention throughout the White Paper of public consultation. This is commendable but political correctness can lead to over-emphasis of third party rights, which may suffocate the whole process.

McLeod, Mona: I wish to express my concern that the in the report on Modernising the Planning System it is proposed (1) to remove nationally important developments from the Public Inquiry process (2) there is no provision for Third party Rights of Appeal (3) there are no provisions for improved protection of the landscape.

Oliver, Jean: Whilst wholeheartedly supporting your stated aims, I question that everyone has the opportunity to participate in the planning procedure. I had difficulty in accessing a copy of the White Paper. It was not available in my library, nor did they have any knowledge of it.

Quinn, D Mr: The White Paper seems to me to strike a fair balance between competing pressures in the planning process and in placing emphasis on 'plan-making' rather than 'planning control', gets back to the positive case for planning of all kinds rather than perpetuate the negative practice planning has become.

Reeves, Dory Dr: A key weakness of the White Paper, which can be redressed, is that it fails to identify the targets and tools which would ensure that planning delivers sustainable economic growth which addresses social and economic as well as environmental issues. The White Paper makes an effective link between sustainable economic growth and the environment by supporting growth which promotes the prudent use of natural resources; encourages energy efficiency and protects key environmental resources. These are SMART objectives. They are specific, measurable, achievable, realistic and timely. Environmental tools such as environmental assessments have been developed over the last three decades. Since planning is also about achieving social justice for all, there is a need for a parallel set of targets and tools. The White Paper should show the links between sustainable economic growth and the social as well as environmental dimensions. It should flag up the need for future work to develop the appropriate tools and the necessary information base and this could usefully be built into the work already identified on the accessible environment. It is possible to envisage SMART social objectives which relate to public involvement and equality between women and men.

Sangster, Ann C Mrs: I am in favour of the aim to restore confidence in the Planning System, particularly through increased public awareness and participation in a more balanced and effective system. However, I feel that this White Paper falls short in some areas in being able to achieve these aims.

Smart, Douglas G: I accept that there is a need for modernisation and there are some good proposals. However I wish to object to some aspects of the White Paper.

Smith, RL: My major comments are based around the impression that the review is a centralizing measure, despite remarks to the contrary in the body of the paper. Page 18 shows that in all types of development, except local developments, the right of appeal is basically to the courts and in one case to the Scottish Ministers.

Thomas, Vic: I am deeply concerned about the democratic deficit and anti-community attitude running through the Planning White Paper. This document is unjust and an affront to local community participation in developments that impact on folk in their community. Super quarries, roads, fish farms , large scale wind farms etc will go unopposed by the people whose lives will be most affected.

Turner, Barry: From the perspective of the local community and its dealings with the system, I think we should be looking for three things from the modernisation: transparency, fairness and quality of outcome. In this context, there are many proposals in the White Paper which are to be welcomed.

Urquhart, Graham: I appreciate that this is a White Paper and that much detail will be fleshed out in the Planning Bill. However, from a lay reading the overwhelming impression I have gained is that once all the cuddly noise is removed, the beneficiaries will continue to be the business/developer lobby with the economic tail wagging the sustainable development dog. I am unclear as to how this will rebuilt trust in the planning system.

Wall, J Mrs: I support the SE's aims to try and get a fairer Planning System etc, but there appear to be omissions of great importance in the present proposals. While your proposals are in general better than current ones, several fall short of achieving opportunities to create an effective, participatory planning system based on sound development principles.

Walls, John: The intentions of modernising the planning system and increasing the emphasis of development planning are to be commended. However, it does involve greater centralisation, increased regulation and micro-management. This will increase the need for more staff and higher costs not only in the public sector (government and local government) but also in the private sector in terms of staff resources and increased costs. One key factor which I believe undermines perceptions of the planning system is the failure to recognise the extent to which ownership of land is a major determinant in where and when development takes place. At the present time the pressures on developers, especially in respect of large developments, have never been greater. In addition to applying for planning permission, they have to contemplate having to pay for new infrastructure, undertaking Environmental Impact Assessments, Traffic Assessments, etc. The basic point is no matter how much the measures improve the system, they add delays and increase overall costs to secure the sought after outcomes. Finally I should like to express concern about the way in which the White Paper expresses the opinion that '…..key political objectives such as affordable housing, public infrastructure and waste management are often frustrated by the planning system. There is no acknowledgement that local government has not been allocated resources to make good infrastructure deficiencies and even whether they should shoulder the burdens

Wolff, Sula Dr: This is a splendid paper clearly setting out the admirable aims of the proposed new arrangements. However, I would have liked to see more emphasis on the importance of good design and architectural merit when new developments are being considered.

Politicians

Councillor Kennedy, Margaret: Generally I welcome the document as there are many issues which will improve the planning system both for elected members, Council officials and members of the public.

Scottish National Party: In broad terms welcomes the modernisation of the planning system and indeed the minister's intention to democratise a system which has fallen into some disrepute, and lost the confidence and trust of communities. It would in our view be appropriate to place on the face of the bill a statement of purpose of the legislation which should not simply be about process but about purpose-to aim for sustainable/integrated development within a democratic and transparent framework. In respect of resources we have concerns about sufficient planning professionals to implement the proposed legislation together with the funding required, not simply for Local Authorities, but for communities and 3rd parties. The Scottish National Party looks forward to a positive contribution to this important debate on an issue not only of national and local significance, but an issue which touches the lives of many communities and individuals requiring a credible, trustworthy, democratic and understandable planning system.

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