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Review of Permitted Development Rights
Local Authorities
Aberdeen City Council: The principles of extending permitted development rights should be supported as there are many minor developments that can cause the expenditure of a disproportionate amount of staff time. As well as reviewing the permitted development rights for single houses they could be extended in particular to flats and widened for industrial/office development. Nevertheless, in compact, highly developed cities, such as Aberdeen, the scope for extension of permitted development rights may not be as large as anticipated.
City of Edinburgh Council: Support in principle but reduction of control over development in Edinburgh will be proportionally less due to the extensive coverage of historic environment restrictions. Welcome review of permitted development rights for airport development.
Dundee City Council: The Council agrees that the present Permitted development Order is over complex, easily misinterpreted by stakeholders and widely abused. A fundamental review is therefore welcomed subject to subsequent consultation.
East Dunbartonshire Council: If these proposals were implemented valuable staff resource could be switched to enabling a more thorough and timeous evaluation of larger scale proposals with potentially more beneficial gains to the Community as a whole. Whilst it is recognised that the Planning System was not established to resolve neighbour disputes, the withdrawal of an arbitration component from many household improvements could be potentially problematic for elected Members. The Scottish Executive proposes to draw up a permitted development handbook for householder in order to ensure that there is clarity about design standards but it is potentially concerning that unless this guidance is fairly exhaustive a significantly increased enforcement workload could arise.
East Lothian Council: The proposals deemed too minor to require an application should be excluded from the definition of development rather than being defined as permitted development. Retaining minor developments within the system will be confusing to the public, difficult to administer and lead to differing practice between councils via the use of Article 4 Directions.
East Renfrewshire Council: While increasing Permitted Development Rights is supported in principle this is dependent on the details of the changes. There is concern that this could remove control over householder developments where there are objections from neighbours. At present the requirement for Council determination provides an independent decision that in most cases is accepted by objectors. Consequently, the removal of this process for what may be minor developments, in terms of scale, but which can generate strong feelings, might not be in the general public interest. Furthermore this could significantly reduce the need for enforcement action and tends to diminish the benefits of strengthening enforcement procedures.
Glasgow City Council: Taking householder applications out of the planning system would remove the opportunity for the public to input to the determination of those issues in which they have most interest e.g. neighbouring extensions or alterations. This would appear to conflict with the SE's desire to improve public consultation and participation. SE indicates that there will need to be "appropriate limits and conditions associated with any extension of permitted development rights to ensure that environmental quality is maintained". This, recognition is welcomed as the wholesale removal of PD rights could lead to loss of amenity and undermine the SE's desire to improve design quality. However, clarification is required on the detail of the SE's proposals in this respect, particularly regarding how the system will operate in practice. If, as seems likely under this proposal, householders would still need to contact the Council to determine whether a planning application was required, and officials would require to undertake a site visit to do likewise, then it may be that the new proposal would entail little time or resource saving for the Council. The proposal could lead to confusion in the minds of the public regarding what would require planning consent and what wouldn't. This may have repercussions in the form of increased enforcement activity should it result in an increase in unauthorised development.
Midlothian Council; While the principle of trying to improve efficiency by taking some householder applications out of the system is worthy of support, it may prove more difficult in practice to achieve. Certain householder applications can be of considerable importance to neighbours, and care needs to be taken to ensure that their rights are not abandoned. Any review of permitted development rights by the Executive should involve a detailed input from senior planning practitioners.
North Lanarkshire Council: A review of permitted development would be welcome. Extending permitted development would result in a loss of fee income as well as a reduction in workload. However, it could also lead to an increase in the number of enquiries and enforcement investigations, for which there is currently no fee payable. Production of a householder guide should make it clearer for the public and for planning officers. Careful consideration will be needed to ensure widening permitted development rights does not compromise initiatives to improve design.
Perth & Kinross Council: "The devil is in the detail" as much will depend upon the definition of permitted development. It will release a significant staff resource, but may be unpopular with residents who regard the planning authority as a neighbour protection service.
Renfrewshire Council: The "bottom end" of the range of developments (householder developments etc) is responsible for a large percentage of the total planning applications. Taking these out of the planning system by widening the scope of permitted development would release resources for larger applications that are of greater significance to the community generally. Nevertheless householder applications can be controversial and cause real concern to residents. An expanded permitted development system must therefore include a comprehensive set of standard conditions to deal with matters of privacy, overshadowing etc. However it must be appreciated that additional enforcement resources will be required to ensure compliance with standard conditions.
Shetland Islands Council's (interim response): As a Planning Authority that was recently required to deliberate on the future of a Wendy House, we cannot but welcome the review of permitted development. Whilst important to safeguard amenity and respect the reasonable expectations of owners and occupiers, the present accumulation of legislation in this area is so complex and confusing that we believe it brings the planning system into disrepute.
South Ayrshire Council: It should be noted that whilst this proposal may reduce the number of planning applications for such developments, there is likely to be a consequent increase in the number of applications submitted for a Certificate of Lawful Use or Development ( CLUD). Householders will continue to seek written confirmation from the Council that their proposal is permitted development and does not require planning permission. In 2004, 5% of all applications received by the Council were for lawful use certificates. It should also be noted that if the number of CLUD applications increases as a result of wider permitted development rights, this has resource implications for a CLUD application is half the fee of a householder planning application.
Non Departmental Public Bodies
Health & Safety Executive: The HSE does not believe that there should be permitted development in an area notified to LPA s by the HSE where these could lead to an increase in the population and thereby undermine the purpose of land use planning controls in the vicinity of MAH sites and pipelines. There is also an issue here as to fully implementing the Seveso Directive.
Highlands and Islands Enterprise: We would hope that a move towards increased subsidiarity would be reflected in the proposed review of the General Permitted Development Order ( GPDO), with the particular aim of reducing the planning burden on SMEs and contributing to their Productivity.
Historic Environment Council for Scotland: While HEACS welcomes in general the intention to review of Town and Country Planning (General Permitted Development) (Scotland) Order 1992 ( GPDO), together with the related mechanism of the Article 4 Directions, in terms of simplifying the legislation so that it is easier to use and interpret. There has to be recognition that current permitted development rights can already pose a serious threat to the historic environment, particularly in relation to archaeology. Extending those rights without a consequential duty of care for the historic environment would give rise to further concerns. Conversely, although cumbersome to use, Article 4 Directions have the merit of protecting the historic environment from inappropriate and damaging development in Conservation Areas and HEACS would not wish to see these measures being reduced in any simplified arrangement.
Scottish Enterprise Edinburgh and Lothian: We accept that smaller householder planning applications place a disproportionate burden on planning authorities and it makes sense that they are dealt with alternatively to allow more resources to be allocated to larger applications.
Scottish Environment Protection Agency: Seeks involvement in any review of the Town and Country Planning (Permitted Development) (Scotland) Order 1992 as amended ( GPDO). This is in order to ensure that the environmental impact of certain development types that may be subject to this review ( e.g. minerals development and industrial development are specifically mentioned) are fully understood and factored into decision making. The ERM research into the interaction between land use planning and environmental regulation (2004) identified that the GPDO should be extended to cover development required as a consequence of consent conditions applied to PPC, Waste Management Licenses and other environmental licenses. SEPA supports this recommendation and would wish to see this included in the review. In addition, SEPA would wish to see the review investigate the potential to re-consider permitted development rights for water body engineering and water management projects in the light of the Water Environment (Controlled Activities) (Scotland) Regulations 2005. It may be that permitted development rights may be extended to development which currently requires a formal planning application where the only issue under consideration is the impact of that activity upon water bodies.
Scottish Natural Heritage: It would certainly be possible to broaden the scope of Permitted Development with regard to many types of activity, including minor proposals by householders, with little adverse effect on natural heritage. However, it will be of considerable importance to ensure that this process does not compromise the management of developments which do have significant environmental impacts. There are a number of areas in which we would argue for the withdrawal of Permitted Development rights, including certain types of river engineering and bulldozed tracks in the uplands. Much of the difficulty relates to the complexity of the GPDO with respect to this type of development, as tracks associated with field sports require planning consent while tracks for agriculture or forestry are currently classed as Permitted Development. The Planning Bill would provide an excellent opportunity to address this long-standing issue by classifying all vehicular hill tracks as local development.
Scottish Water: Would welcome involvement to minimise the number of minor application for which we must currently seek planning permission. We believe that the enhancement of Scottish Water's permitted development rights (under Classes 38 and 43A), subject to reasonable thresholds, is overdue and would significantly improve the efficiency of the planning system as well as being crucial to our development and operational needs. The review of permitted development rights presents an opportunity to consider the method of application for Article 4 Directions. Scottish Water would be concerned that the public health and environmental benefits from the investment in water and wastewater infrastructure compared to, for example, conservation objectives, could be unduly compromised if "blanket" withdrawals of Class 38 and 43A rights were to arise from the "simplification" of the Article 4 Direction process. We hope that this issue will be reviewed in terms of the wider industry and community needs, and Scottish Water would wish to see a mechanism for representation to applications for Article 4 Directions and a right of appeal against the withdrawal of statutory undertakers' permitted development rights.
Other Public Bodies
Central Scotland Forest Trust: We welcome the production of a handbook for householder development. There is a need for the public to better understand the planning system.
Strathclyde Passenger Transport: Suggests review of the appropriateness of the generous powers available to statutory undertakers. Some developments with major cumulative impacts are currently outside the planning system in terms of the assessment of their impacts.
The Development Industry
Bett Homes: The White Paper proposes that there is an increased role for permitted development for smaller scale developments, particularly for individual householder applications such as extensions, conservatories etc. We would support this approach provided that the Executive gives clear guidance.
EDI Group Ltd: Further consultation should take place on proposals to extend the scope of developments which do not require planning permission. It is unlikely that this proposal will significantly ease workloads. In any event to protect the quality of new, as well as older environments, there are arguments for withdrawing existing permitted development rights in certain cases.
Other Businesses
Aggregate Industries UK Ltd: We fully endorse the intention to review the extent to which applications for minor developments could be removed from the scope of the planning system altogether. An extension of permitted development rights would remove a substantial amount of the workload from Planning Officers leaving them able to devote more time to more complex applications.
Confederation of UK Coal Producers: A review of permitted development rights (para-5-1-5 refers) is clearly a sensible step but the Executive needs to be mindful that any reduction of such rights would increase the workload of planning officers.
Crown Castle UKLTD: We support the approach to reduce the burden on the planning system by a review of the level of all permitted development, including those for electronic communication and mobile phone developments. We have previously made representation in 2003 to the Geddes Institute of Dundee University to suggest that the current permitted development rights within Class 67 of the GPDO do not adequately steer electronic communication providers towards mast or site sharing in order to minimise proliferation. We remain of the view that the Class 67 rights need to be reviewed to better achieve the objectives relating to electronic communications.
Federation of Small Businesses: We look forward to seeing the results of the Scottish Executive's research on the possibility of removing certain 'minor' developments from the planning system. Whilst this may not affect the majority of business applications nonetheless there may be scope to exclude certain commercial applications, particularly for very small businesses
Lafarge Cement UK ( LCUK): Major industrial installations such as cement works and quarries for cement production rely on the general permitted development order for "fast tracking" minor development to facilitate production. Should the review of permitted development rights reach the conclusion that they be withdrawn or even varied on a parochial basis again this would be of concern to LCUK, as it would introduce unnecessary delay into the system contrary to the intentions of the white paper
Mobile Operators Association ( MOA: Permitted development rights, as they relate to mobile phone network development, were changed in Scotland in 2001. We believe that permitted development rights are an essential part of an efficient planning system and that they both encourage development that reduces the impact on the visual environment, and reduce the administrative burden on local planning authorities avoiding the need to process applications for minor and small scale development. For the most part, permitted development sites are the least controversial in terms of community opposition for the mobile network operators. The limited permitted development rights the operators now have were retained specifically to encourage this type of low-impact, low-opposition development. Permitted development is a vital part of an effective planning regime. The Executive should keep in mind that even small changes could have a significant impact on the planning system as a whole. Permitted development by its very nature has a little impact on neighbouring property and any moves towards the further removal of permitted development for mobile telecommunications developments would compromise the operators' abilities to effectively respond to growing consumer demand.
Orange PCS Ltd: Any review of permitted development rights for mobile phone equipment should accept that there was a major review only a few years ago. The changes made then are widely accepted as having been successful although they have increased the regulatory burden on operators and planning departments. We therefore believe that there should be no further removal of such rights for mobile phone equipment. We would be very concerned if there was any proposal to allow LAs to remove existing rights beyond the powers which already exist.
Quarry Products Association (Scotland): Should the review of permitted development rights reach the conclusion that they be withdrawn, again this would concern our members.
Scottish Environmental Services Association ( SESA):SESA believe that there should be greater encouragement for permitted development rights. The review of Development Plans needs to begin now. The Executive needs to provide much stronger support for applications at the bottom of the hierarchy, which are minor and non-controversial, to be permitted development. The introduction of permitted development rights will help to deliver the Executive's objective of a better match of resources to priorities.
Scottish Power: We support the principle of maintaining existing and extending Permitted Development Rights. The proposed widening of permitted development ( PO) rights would be most welcome as a means of 'freeing' the Development Management system. We would welcome the review of PO rights to benefit small scale renewables, including solar panels and domestic wind turbines. We also submit that statutory undertakers should at least retain their existing PO rights.
SITA ( UK) Ltd: We would wish to see permitted development rights extended to encompass "Minor Developments" in the sphere of waste management.
Tarmac Ltd: Note the proposed review of permitted development rights and would highlight the particular use of classes 55 and 56 for many minor changes to quarry installations. Changes in technology and use of semi mobile plant or buildings make this facility particularly useful to both operators and authorities where the effects are generally absent or negligible within the wider development.
Unison (Scotland): We agree that more householder developments could be covered by permitted developments and excluded from the requirement for planning permission. However, it has to be recognised that many of these issues are the cause of neighbour disputes and inappropriate deregulation could cause problems for other agencies.
WBB Minerals: Appropriate consultation should be carried out before any amendments are made.
Professional Organisations
Association of Regional and Island Archaeologists: Existing permitted development rights already pose a serious threat to Scotland's archaeological resources, as raised in the past in annual reports of the Ancient Monuments Board for Scotland until its abolition in 2003. Any increase in permitted development rights without a complementary introduction of a duty to further the conservation of the historic environment, and a requirement to consult statutory SMRs can only exacerbate this situation. The performance of the statutory undertakers in respect of permitted development rights and archaeology does not bode well for any extension of rights.
Institute of Civil Engineers Scotland: This is welcome as it should free up the Planning Authority to deal with Major and Local developments
RICS Scotland:RICS Scotland welcomes the review of the permitted development rights set out in the Town and Country Planning (General Permitted Development) (Scotland) Order 1992, particularly with the aim set out in this paragraph. We would also welcome a review of the Town and Country Planning (Use Classes) (Scotland) Order 1997.
RTPI Scotland: While extension of permitted development may reasonably eliminate a small proportion of minor developments from planning control, the need to avoid non material neighbour disputes should not be the main criterion for reviewing what should be controlled in the interests of proper planning. We are concerned that the possible extension of use of Article 4 directions will complicate rather than simplify matters.
The Law Society of Scotland: With regard to 'Minor developments', the Society considers that there are certainly some applications which could well be taken out of the planning application process. It suggests that applications in very technical areas might possibly be dealt with by the building control system, or through the reformed community burden system. The Society would welcome further discussions on this.
Planning Consultants, Architects and Lawyers
Humberts Leisure Consulting: Permitted development rights for caravans needs to recognise the changes taking place in the English system which is recognising the needs for energy efficiency in allowing caravans to have cladding.
Muir Smith Evans: We welcome the review of what categories of minor developments may be taken out of the planning system. However, we urge careful consideration of this: some minor developments are of little consequence by themselves but cumulatively can significantly alter the character of an area.
Warren Consultants: The "devil will be in the detail" of the GDO proposals. Permitted development rights were actually reduced by the Scottish Parliament in respect of telecommunications development because of public concern. Increasing PD rights is therefore not an easy thing to achieve. The other problems with increasing PD rights for minor developments are as follows:-
- a single extension to a single house may not seem a major development in planning terms, cumulatively a liberal policy, on allowing house extensions, can be very significant
- extensions can lead to overdevelopment on plots as well as resulting in houses which previously had a coherent design losing this because of the desire to increase floor space.
- The above points militate against the idea that the development management of small building extensions should be rolled into the building regulations system
Community Councils
Ardross Community Council: Whilst we appreciate the administrative burden of Minor Development it is exactly this type of development that affects people the most. We would ask the Executive to tread carefully to ensure that minor developments are done safely and sympathetically. However we would ask the Executive to expand the list of permitted developments to include carefully defined solar panels and micro wind turbines.
Balerno Community Council: With reference to permitted development rights, mobile phone applications and the suggestion that these would no longer require planning permission, notes that new masts are ever increasing due to the fact that Council planners cannot establish the need for new masts (when mast sharing might be an alternative) because they do not have information on coverage plots by existing masts. Questions how need can be established by Authorities if they don't have the facts in spite of following NPPG 19 and PAN 62.
Craiglockhart Community Council: While recognising that much time is spent on detail it is not all wasted time. On design it can make the difference between banal and delightful. It can also have practical implications as demonstrated currently by the loss of garden ground to parking space and conservatories with in many cases a diversion of resultant run-off to already over-stretched surface water systems. This is a situation which we see all around us and we think should be addressed in any review of permitted development rights to prevent the loss of too much garden ground.
Currie Community Council: Permitted development are a source of confusion and regarded as a trick to expand a property without going through a proper planning process. Any amendments to the Permitted Development rights should reduce the scope for adding habitable accommodation to an existing property. It should also consider the percentage of 'garden ground' that may be developed under such rights before a Planning Application must be submitted. Applications for electronic communication (telecoms masts, for example) are controversial and should not be included within schedules of Permitted Development Rights.
Dunblane Community Council: We would ask that very careful consideration be given to any proposals to increase the number and scope of Permitted Developments contained within the proposals for Minor Developments.
Gatehouse of Fleet Community Council: The proposal to issue a handbook for householder developments is an excellent idea and we hope it will be written and illustrated in simple, clear, and easy to understand language.
Grange-Howard Community Council: Few minor developments cause concern but there are a number which can impinge substantially on environmental quality and diminish the enjoyment of adjacent properties by their occupants. Individual applications on their own can appear relatively innocuous but in combination with others they can adversely affect the environment. By the law of averages, it is likely that some determinations would have detrimental effects as deprivation of daylight and diminution of privacy can frequently result among the cases that cause concern. The safety net of objection would be lost in such cases deemed as permitted development.
Hillhead Community Council: We are absolutely opposed to any extension of permitted development rights. Even windows and dormers can have a huge effect on their neighbours, the neighbourhood and the quality of place. Again, scrutiny is necessary. It is not safe to assume that private individuals will have a concern for their neighbours and neighbourhood in matters affecting their own property. We ask you to look more closely at the rights which already exist, for 'statutory undertakers' such as hospitals and railways, which in our view abuse their rights often without any justification. Many are now private companies based outside the area and with responsibilities to shareholders rather than the place affected. Some actions have been damaging and unnecessary. Hospitals are required by the NHS to maximise their return on their property portfolio, which is not necessarily in the interest of the area or in line with city policies and development plans.
Kennoway Community Council: It is of great concern that Minor Developments are to be removed from Committee consideration and instead subject to determination by planning officials. Whilst planning officials have knowledge of policies, they do not have the local knowledge or local empathy to recognise the ideals expressed in the document "it must be the right development, in the right place, of the right quality and at the right time". Furthermore, it undermines the "transparency" ideal mentioned so frequently in the Paper when decisions are removed from Committee meetings that the public may attend. It is also a concern that "minor" is a subjective word and the scale of applications to be determined by planning officials has not been fully explained nor if the rule may be applied differently over Local Authorities.
Largo Area Community Council: It is considered that very careful attention should be followed before definition/criteria of permitted development is finalised. In addition to Community Councils, neighbours to a proposed property improvement should have an assured opportunity to see the plans, if not it could be regarded as an imposition. Once the Executive have completed their general review of a re-definition there should be further consultation with Community Councils.
Strathblane Community Council: We have strong reservations about increasing the scope of permitted development. Even small household developments can have a serious visual impact, particularly if the household is large. We also understand that this would mean that neighbours would not be notified in advance and we anticipate that this could lead to an increase in neighbour disputes and could undermine confidence in the planning system. Another way to deal with these applications is to give Community Councils a role in the approval process. We understand that there is greater local (parish) council involvement in England.
The Royal Burgh of Cupar & District Community Council: It is not possible to comment on the case for increased Permitted Development as thresholds have not been drawn up, however, there is concern that planning as it is seen today as a 'neighbour protection service' would be virtually finished.
Ythan Community Council: We would wish for a clear definition of 'Permitted Development' where this relates to small developments. We support the proposal to streamline the process but are concerned that this may lead to ad hoc, poorly designed building extensions which may not fit with the character of the area.
Voluntary Organisations
Colinton Amenity Association: We agree that the removal of certain householder applications from the planning process could improve the efficiency of administering the system. But there is still a need to protect the interests of neighbouring householders, especially in regard to privacy, overshadowing, design of structures and matters affecting their quality of life. These important matters for residents cannot be abandoned to the interests of improving efficiency. We support the simplification of legislation dealing with permitted development rights.
Hamilton Natural History Society: We agree that you must ensure that for householder developments "adequate controls remain to deal with developments which might unduly affect the environment". This should include not being allowed to cut down, or lop branches from, trees with TPOs on them. On the whole we are in favour of removing smaller household applications from committees as this must make the whole planning process faster. However, we would request that an audit is done to ensure these changes are staying within the "rules" as laid down in your Bill and the Development Plans.
Mountaineering Council of Scotland: There may be scope for increasing efficiency in one area of permitted development rights, but in terms of protecting mountain and other landscapes, we would like to see a fundamental review of permitted development rights and for the planning system to give far greater protection to Scotland's mountains
Peebles Civic Society: We disagree with any proposal to extend permitted development rights for small scale developments. This would contribute to incremental damage of the built environment and be contrary to the White Paper's aim of 'striving for high quality design in all new development'.
Pollokshields Heritage: We are opposed to any extension of permitted development rights. We recognise that most of our concern relates to development within our Conservation
Area, and in that context we suggest that, at least in Conservation Areas, the scope of Article 4 Directions should be increased. Furthermore we consider permitted development rights should be curtailed. We especially consider that this applies to the so called "statutory undertakers". We consider that these no longer exist. Those that were are now private companies with obligations to their shareholders to make profits. It is our experience that they abuse the rights they have for their development purposes.
Portobello Campaign against the Superstore: Care has to be taken in defining which are the unnecessary controls on individuals that should be removed. Some individuals will introduce creeping changes that could significantly alter a building or land use over a period of time. And what about a neighbour, say, using their residence to commercially entertain others? These controls have evolved for good reasons and in most part are required in our crowded country. Any change to permitted development rights should in itself be subject to full consultation. I do not believe, judging by the planning profession's aversion to planning enforcement, that extending permitted rights will be controlled by greater enforcement. But the increased emphasis that is to be placed on enforcement of planning conditions is welcomed. Professional planners often seem to think that once an alteration takes place or a use condition is flouted then the harm has been done and the time consuming procedure of making an owner comply is not worth the effort.
Rambler's Association: Review of permitted development rights in the countryside is now required in order to deal with hill tracks. Tracks can be visually very intrusive, and can open up vehicular access to the more remote areas of wild land. We ask that all hill tracks be covered by planning legislation. Inappropriate fencing can also cause significant intrusion in areas outwith the urban envelope and these too should come under planning law. This includes deer fences and any other fences greater than the normal height of stock fencing.
Scottish Civic Trust (and Civic Trust Network): We are uneasy with the proposal to increase the scope of PDR. Indeed, the Trust believes that there is considerable scope (and need) to limit the extent of PDR as it stands today. Whilst we support a review, this must be predicated from the perspective of improving quality in our towns, cities and countryside and not from an efficiency view of simply getting more out of the system as is stated in the Paper. It should be noted that from a historic environment perspective (especially from the archaeological point of view) PDR could result in a significant impact on the heritage resource. Many small-scale changes can have a considerable impact on an environment. We would object to any increase in either the scale or number of PD classes.
Scottish Renewables Forum: Scottish Renewables is active in the microgeneration renewable energy sector and we welcome the proposed minor development permitted rights review and would anticipate microgeneration is considered as part of that review. We note that general permitted development has been extended to microgeneration in England and as such we would urge a similar move in Scotland. We would also like to add that statutory undertaker's permitted development rights should be retained.
The Grange Association: The review of permitted development raises some concerns. What may in isolation appear to be 'minor' matters could have a major cumulative effect on an area. We would not welcome an increase in permitted developments in conservation areas. The compilation of a handbook for householder development might be useful to clarify what is regarded as permitted development, and special requirements within conservation areas.
The John Muir Trust: The John Muir Trust would ask that the Scottish Executive review "permitted development rights", particularly in relation to such things as vehicle hill tracks. With the increasing use of all-terrain vehicles these are becoming increasingly prevalent and encroaching on wild land.
Private Individuals
Turner, Barry: The White Paper recognises that if PD rights are extended we must ensure that adequate controls remain to deal with developments which might unduly affect the environment or amenity of the area. Local organisations will have views on what changes might be acceptable if any. My worry here is that further changes to PD rights are being proposed simply to reduce workload, not to meet any of the aims of the White Paper or better the environment.
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