Scottish Government

SPP3: OVERVIEW OF RESPONSES TO CONSULTATION

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INTRODUCTION

Background

1. The draft revision of National Planning Policy Guideline (NPPG) 3: Planning for Housing was issued on 4 March 2002 for an extended period of public consultation. The consultation period ended on 28 June 2002.

2. This revision updates NPPG 3: Land for Housing which was published in 1996. The main changes in the revised Scottish Planning Policy (SPP) 3: Planning for Housing reflect the key planning policies in SPP 1: The Planning System (revised in 2002), addressing them in relation to new housing development.

3. Approximately 800 copies of the consultation paper were distributed to all local authorities in Scotland, a wide range of public bodies, non governmental organisations (NGOs), professional bodies, industry and business interests and members of the public. The document was also made available on the planning page of the Scottish Executive website. The consultation period closed on 28 June 2002, but a number of responses were received after the closing date. These were all taken into account.

Overview of consultation

4. The Executive received 82 responses to the draft revision. Responses were received from a wide range of interested parties including: amenity and community groups, both interest and area specific; nearly all Scottish planning authorities and structure plan teams; house builders and housing providers; the planning profession and other professional organisations; and private individuals. The numbers of responses can be categorised as follows:

A full list of respondents can be found in Annex A.

5. The Executive has analysed all responses received and, where appropriate, made amendments to the guidelines in the light of the comments made. Copies of the responses are available for public inspection at the Scottish Executive Library, Saughton House, Broomhouse Drive, Edinburgh EH11 3XD (contact Mr Alan Gold, telephone 0131 244 4552 for an appointment).

6. This Overview summarises the responses to the draft revised National Planning Policy Guideline 3 : Planning for Housing, referred to throughout this document as "the draft". The Overview by no means represents a comprehensive report of comments made on the draft, but is intended to cover the main points raised.

KEY ISSUES EMERGING FROM RESPONSES

GENERAL PRINCIPLES

7. This opening section of the draft outlined the main elements of the policy background to the document and overall these general principles were welcomed and supported by respondents. There was general agreement with the stated need for good housing to be developed in the right locations. Several house-builders recorded that in recent years they have consistently redeveloped brownfield land at a high rate for new housing. They also undertake conversion and refurbishment which by their very nature take place on previously developed sites.

8. In the draft, the Executive identified three key themes:

• Creating quality residential environments;
• Guiding development to the right places; and
• Delivering housing land.

9. Each of those themes were then expanded on in turn as the main headings of the paper. Virtually all respondents supported this approach, although one thought that they had been presented in the wrong order, suggesting that 'guiding development to the right places' should have been accorded a higher profile. Another suggestion was that 'affordable housing' should have been a key theme in its own right as a representative of social justice.

CREATING A QUALITY RESIDENTIAL ENVIRONMENT

10. The Executive has proposed that far greater emphasis be given to design quality issues than in previous versions of NPPG 3. The intention is to promote a more attractive and sustainable living environment for the people of Scotland and is consistent with SPP 1: The Planning System which stresses the importance of design considerations in reaching planning decisions.

11. There was widespread support for this change in emphasis, which was warmly welcomed by local authorities and other public bodies in particular. Many respondents expressed a wish to see further guidance/advice to assist in giving a higher priority to design issues. However, one respondent considered the draft as it stood gave local planning scope to be too prescriptive and that there should be greater flexibility.

Design, layout and architecture

12. SPP 1 already notes that planning permission can be refused on grounds of poor design and reiterating that message in the draft was also well received. There were some suggestions that it would be useful to show examples of circumstances where it might be appropriate to refuse planning permission.

13. One developer considered that this section laid too much stress on the 'urban' form and needed to recognise that developments on the periphery of settlements have traditionally been in the popular suburban form. This respondent was concerned that this gave the message of a shift away from suburban type developments in such areas, which it considers would not be attractive to purchasers. There were also comments from others that the text was too heavily weighted in favour of traditional local designs at the expense of encouraging good quality contemporary design.

14. The suggestion that planning authorities should adopt a more active role in the design of new housing developments was also very well received. Indeed a number of respondents considered that design guides, local design statements and development briefs should be more actively encouraged, as a 'requirement' rather than an option. There was some question though about the status of such guidance and about the subjective nature of defining what is good design, with opinions given that any guidance would need to be subject to consultation and that local authority planning officers would need to undertake suitable training. One respondent had commented that design guides had, in the past, resulted in mediocre, universal house styles.

15. The commitment to the joint working on a PAN to raise the standard of new housing was welcomed by respondents.

Energy efficient housing

16. There was support generally for the reference to energy efficiency as part of good design in new housing. However, while some respondents considered that the guidance did not go far enough in pursuing energy efficient principles, others felt there was some duplication between planning and the Building Standards Regulations. Comments were also made that adopting energy efficiency policies could have an impact on other aspects of promoting good design, siting and use of materials for new development and that housing layout must also be determined by good urban design.

17. Some points were raised in relation to the specific reference to district heating schemes as an example of energy efficiency. The principle of such schemes was accepted, but various parties had concerns about practical difficulties in the implementation.

18. It was suggested by some that, in addition to supporting the use of recycled construction and demolition waste, reference should also be made to minimising resource use and avoiding waste in the first place. One respondent sought clarification about whether planning authorities were to implement specific development plan policies on waste minimisation/re-use/recycling for housing developments and another queried whether there should be reference to this being a material consideration in development control decisions.

Form of development

19. The references in the draft to the importance of encouraging walking and cycling through the layout of developments were appreciated and welcomed by respondents. Some house builders, however, felt that the statement that "too many developments in recent years have been designed to give priority to the car" failed to recognise the increasing emphasis given to walking and cycling by most house builders.

20. Several respondents agreed that roads standards should serve as a starting point, but should not stifle innovative design, noting that often it is the standards that prevent flexibility and that Home Zones may not be implemented unless the standards can be relaxed.

21. A couple of respondents expressed caution about the application of lower maximum parking standards. They noted that good public transport does not necessarily reduce the need or desire to own a car and considered that restrictions on parking standards should occur only at highly accessible locations where parking controls can be enforced to avoid spill-over to adjoining areas.

Landscape and open space

22. Supportive comments were made in relation to the need to consider landscaping in new developments in the interests of environmental quality and creating a sense of place. One respondent added that well thought out landscaping could also contribute to energy efficient housing by providing shelter, windbreak and shade. Another noted however that, due to costs to developers, it could be difficult to ensure a ' robust, well thought out planting scheme' in every development and suggested that a definition of that term would be helpful.

23. Guidance in the draft about open space requirements as part of new housing developments was generally welcomed. While accepting the principle that new housing should not be located on established open space, a few respondents noted that there can be circumstances where it might be appropriate to develop, such as where compensatory provision of an equal or higher standard can be made.

Density

24. Comments on the density section of the draft were generally positive, although some respondents requested clarification relating to matters such as the level of detail to be contained in local plans and development briefs and the need to assess planning applications on their individual merits. It was also thought by some that, in addition to seeking higher densities at transport nodes, the document should recognise that there should be a range of densities throughout our towns and cities.

Providing a choice of residential environments

25. Relatively few comments were received on this section, but the reference to opportunities for self-build housing generated some response. Some welcomed the support for self-build and there was a suggestion that a percentage of any development site should be kept aside for self-build to give choice to the individual and support the role of local construction firms. One respondent raised a question about how to ensure that land can be reserved for self-build housing.

Mixed communities

26. The stated commitment to encourage mixed communities was well supported by most, although one respondent considered it to be a misguided attempt to be social engineers.

27. Comments made in relation to paragraph 29 of the draft on affordable housing related mainly to the delivery of such housing and are summarised later in this document.

28. The paragraph about sites for Gypsies/Travellers elicited very little comment. It was suggested that the paragraph should say more but some of the issues raised by commentators were outside the remit of the planning system.

GUIDING DEVELOPMENT TO THE RIGHT PLACES

Sustainable settlement strategies

29. The status of the Household Projections for Scotland was questioned by a couple of respondents, who requested clarification that the projections are a starting point for forecasting housing land requirements.

30. The statement that planning authorities should develop long-term sustainable settlement strategies was widely supported. One respondent suggested that there should be some requirement for developers to provide a 'Sustainability Assessment' in support of their planning applications to ensure that the implications of their proposals had been taken into account.

The efficient use of land and buildings

31. In the main the continued emphasis on the promotion of development on brownfield land was welcomed. The point was made however that in some circumstances existing infrastructure may have limited capacity preventing the re-use of some brownfield sites. Some respondents felt this section failed to recognise that there can be situations where it may be more sustainable to develop on greenfield sites.

32. While some agreed that there is scope to re-use (for housing) land that has been identified for another purpose, where there is little prospect of it being developed for that purpose, others thought this could weaken the role of the development plan and could lead to renewed debate in relation to sites already tested at inquiry.

33. It was widely agreed that a national target for re-use of brownfield land would be inappropriate. There was some criticism however of the suggestion that planning authorities could set their own local targets. Some suggested that this should be done only where urban capacity studies were in the public domain for comment and scrutiny.

Accessible locations

34. Some respondents welcomed the recognition that there may be circumstances where some release of greenfield land accessible by a range of forms of transport could be more sustainable than the redevelopment of available brownfield sites. However, others noted that this could lead to developers undermining appropriate brownfield sites, leading to the unnecessary release of greenfield land.

Safeguarding environmental resources

35. Paragraph 44 of the draft, in relation to green belt and countryside around towns policies, attracted a range of comments. Some respondents supported the general principles along with the recognition that there could be justification for development on such sites in certain circumstances, following a realistic appraisal of the opportunities for development on sites within the existing urban area. Others however thought the policy was weakened and that the green belts around towns would become increasingly fragile. It was suggested that there was a need to update SDD Circular 24/1985: Development in the Countryside and Green Belts.

Other factors influencing the location of housing development

36. Several comments were received in relation to paragraph 48 of the draft, which noted that in making provision for new housing, planning authorities should avoid locations likely to be at significant risk from flooding. In particular, there were suggestions that the word "significant" be deleted to avoid development where there is any risk of flooding. Other respondents, however, sought some qualification that development on such sites could be acceptable if it can be demonstrated that effective mitigation measures can be put in place.

Extensions to existing settlements

37. Comments received on this section were generally supportive.

New settlements

38. There was general satisfaction with the principles in this section, although some suggested that there needed to be greater recognition of the long lead-in times associated with the creation of new settlements.

39. The funding of new infrastructure is a contentious issue. Most local authority respondents referred to the 1996 version of NPPG 3, which stated that "developers may be expected to fund all or most new infrastructure…" and were concerned that the references to developer contributions in the draft were weaker. They requested that the text from the previous NPPG should be reinstated. The final sentence of paragraph 54 of the draft was supported by developers.

Housing in rural areas

40. Most respondents were generally content with the approach in the draft to the needs of rural areas and the role of housing in supporting rural development. Various comments were made, such as a need to address specifically the matter of ribbon development and also to recognise the importance of maintaining rural character and amenity.

41. While some respondents were in favour of opportunities for 'low impact development', others expressed concerns about whether it would be achievable and also that it could send out an inappropriate message to the house building industry regarding what constitutes low impact development.

42. The recognition that particular problems exist with regards to affordable housing in some rural areas was welcomed, although there were suggestions that clearer guidance was needed to address this.

43. There were some favourable comments that planning authorities could consider specific development plan provision for summer home developments. However, others criticised the suggestion, arguing that development should be considered on the merits of its structure and location rather than its potential use as a particular type of housing, and also that it is questionable whether summer homes would be of any greater benefit to the local economy than housing available all year round. There were also comments about the potential damaging effect such developments could have on national parks.

DELIVERING HOUSING LAND

44. This section of the draft started with the statement that 'development plans' are the main vehicle for assessing future housing land requirements. Most local authority respondents found this general reference to the development plan unhelpful. They recognised that, following the Review of Strategic Planning, a two-tier development plan system would most likely exist only in the City Regions, but that this would take time to implement and therefore full structure plan coverage would continue for some time yet. These authorities requested more detailed guidance on the respective roles of structure plans and local plans in the meantime. The status of the development plan as the main vehicle for assessing requirement was, however, generally welcomed.

Development plans

45. The draft proposed that development plans should take a longer-term view on the provision of new housing, not only identifying the scale of requirement but also setting out a locational strategy indicating the likely direction of development over a 20-year period. It was thought that this would allow all stakeholders, including infrastructure providers, the opportunity to plan effectively for the future. This approach received positive comments from some local authorities and was welcomed by house builders. Other local authorities were concerned that it would not create greater certainty in the process due to the difficulty in forecasting accurately over the period.

46. Within the 20-year strategy, the draft proposed that development plans should provide for at least a 7-year supply of 'effective' housing land (or agreed as likely to become effective). This represented an increase from the policy contained in the previous NPPG 3, which required a 5-year effective supply. The proposal to increase this to a 7-year supply received unanimous support from house builders. There were however numerous comments from local authorities expressing serious concern about the practicalities of identifying a 7-year supply. Comments included:

• It is already difficult to identify a 5-year supply. It would be impossible to do so over 7 years as uncertainty increases with longer time horizons.
• There was no clear justification was for the increase.
• Public funding, which might be necessary to make sites 'effective', is not programmed to such advanced timescales.
• There would be a tension between the local housing strategy (5-year period) and the proposed 7-year period for development plans.

47. The approach to defining 'effectiveness' of sites for development was also the subject of some debate. The draft Planning Advice Note 38 (paragraph 27) noted that the effectiveness of individual sites should be determined in the light of discussions between the parties. House builders welcomed this involvement and some requested that it be expanded to name 'Homes for Scotland' as the body planning authorities with which should agree effectiveness.

48. Most planning authorities on the other hand questioned about the intention of this agreement. It was suggested that the implication would be that land could be classed as effective only if agreed by house builders, in effect giving the industry a power of veto on sites, perhaps forcing the early release of additional land for housing. It was thought that this would only lead to increased dispute and an arrangement would be needed for some form of arbitration where agreement could not be reached.

49. Paragraph 71 of the draft proposed including a mechanism to allow planning permission for housing to be granted in advance of a local plan adoption where the development plan progress does not keep pace with the need to meet requirement for effective land. This received a level of support from both house builders and local authorities.

Local housing strategies and housing market context statements

50. The draft recognised that the Housing (Scotland) Act 2001 required local authorities to produce comprehensive local housing strategies following their assessments of housing needs and conditions in their areas. This would be done on a 5-year cycle in partnership with others in the public, private and voluntary sectors and with tenants and communities. Recognising the link with the development plan, the draft noted that, where a housing need is identified in the local housing strategy, the development plan should address that need.

51. Local authority planners generally supported the link between the local housing strategy and the development plan and recognised the need for close working arrangements with housing colleagues.

52. However, some respondents noted their confusion as to whether the local housing strategy or the development plan was to be the main vehicle for assessing housing requirements. Because the local housing strategy would follow a 5-year cycle, and it had been proposed that the development plan provide at least a 7-year supply of effective housing land, comments were made that they could potentially contradict each other and may not be able to inform each other effectively. Some developers suggested that the local housing strategy requirement should change to a 7-year cycle to match the expectations of the development plan.

53. Another concern raised was that local housing strategies, while being subject to close partnership working, would not be subject to the same public scrutiny as a local plans (in which objections could be heard at inquiry), but that the local housing strategies would be expected to have a large influence on the local plan.

Housing market areas

54. The draft included the statement that planning authorities should ensure that the housing land requirement for each housing market area is provided for in full. This was well supported by developers, although a couple of industry respondents believed that the provision should be met in full within local authority areas rather than housing market areas.

55. Some respondents commented that the delineation of a housing market area was not always clear and that there was therefore some uncertainty about the calculation of housing land requirement. One suggested this could have an effect on local authority resources through the need to carry out extensive survey work. Local authorities felt there was a need for further guidance, particularly in relation to 'mobile demand' and to structure plans giving a vision of the future shape of housing market areas. Developers considered that they were well placed to advise on housing market areas and sought consultation/involvement in the consideration of boundaries.

56. A couple of community groups objected to the statement that requirement be provided for 'in full' on the grounds that this does not take account of other considerations. They suggested that requirement be provided for in full only where other aspects of the SPP are met.

57. Other community groups were concerned that, where housing market areas crossed local authority boundaries, adjoining authorities might 'compete' for the same population within their areas, leading to a duplication of housing provision.

58. Several local authorities and planning professionals welcomed the allowance for exceptional circumstances (paragraph 79 of the draft) where the potential to meet requirement within a particular housing market area is constrained. One authority however questioned what might happen where a neighbouring authority did not agree to accommodate a proportion of the identified requirement, as in such circumstances it would not be possible to meet the full requirement.

Housing land audits and assessing future urban capacity

59. It has become established practice that planning authorities undertake housing land audits to ensure an adequate supply of land for housing is maintained. The draft proposed formalising these audits by stating that authorities should carry them out on an annual basis, working closely with housing providers. This was generally welcomed by respondents as bringing current good practice into policy.

60. It was suggested that it is not always relevant or easy to maintain an audit in some rural areas - the task is labour intensive even where there is a low level of development pressure. One rural authority suggested that it is more important that development plan policies are robust enough to deal with demand.

61. The proposal in the draft that planning authorities should carry out thorough survey work to assess future urban capacity for housing development was generally welcomed by respondents. Some, however, raised the issue about the confidential nature of some potential development sites, such as those where business exists at the moment. It was suggested that excluding such sites from the urban capacity study could give a false picture of the amount of land likely to be available for development, resulting in perhaps unnecessary greenfield land releases. Other sources of concern expressed included the pressure on planning authority resources of carrying out such studies and the need for guidance on the scope and content of studies to avoid dispute at public local inquiries.

62. It was suggested in the draft PAN that planning authorities should involve the private sector in the preparation of urban capacity studies. House builders were almost unanimous in their agreement to this, referring to the knowledge and information at their disposal. There were requests to make specific reference to involve Homes for Scotland in the process.

63. One body suggested that a 'realistic' assessment of windfall and small sites should be made, claiming that past experience has shown local authorities to over-estimate the contribution from these sites.

Delivering affordable housing

64. Although it relates to a relatively low proportion of new housing, the role of the planning system in delivering affordable housing is a contentious area and this section of the draft generated a significant volume of comment. In the main, comments centred on the definition of affordable housing, how it should be delivered and whether supply should be related to particular settlements, housing market areas or other defined areas.

65. A recurring theme in responses, particularly those from planning authorities, was a wish for clearer, more detailed guidance on a range of issues surrounding the role of planning in securing affordable housing, with several suggesting the Executive should publish a Planning Advice Note on the subject.

66. Paragraph 82 of the draft gave a broad definition of the term 'affordable housing', including some examples as illustrations. A number of comments were received questioning the terms of that definition. For example, it was thought by some that the draft was defining low cost housing for sale as 'affordable' only where there is public subsidy involved. Other comments included that it is 'cost' that determines whether housing is affordable, rather than the mechanism for securing it, and that the precise definition will vary depending on the market circumstances of individual areas. One respondent noted that, unlike the previous NPPG 3, the draft did not give any reference to who is eligible to be allocated affordable housing and suggested that this should be added. In general, several respondents believed that the definition in paragraph 82 was inadequate and needed greater clarification.

67. It was suggested that there should be recognition in the document that the availability or shortage of affordable housing varies in different areas of Scotland, as do the issues and solutions. Some respondents disagreed with linking the assessment of need to "settlements", noting that this could be too narrow a term taking into account the varying characteristics of settlements. The term "area" was suggested as an alternative.

68. A particular area of concern centres on the ability to retain housing in the low cost category in the longer term and there was a suggestion that there would need to be involvement of a public sector organisation to ensure that such housing would continue to be affordable.

69. There were also comments that the planning system's role should be to support an affordable housing strategy principally by means of the identification of the land required for such housing, and that uncertainty about land supply could be removed by allocating specific sites for affordable housing only. Several respondents also suggested that there was scope to have a separate 'use class', whereby planning permission could be obtained specifically for affordable housing.

70. The use of conditions and planning agreements to facilitate affordable housing is an area of contention and this was reflected in the comments received. The draft recognised that the housing market alone does not appear to provide sufficient affordable housing and that, in recent times, there has been pressure for the planning system to secure provision through planning agreements. The use of the planning system in this way was the subject of significant comment. There was clearly an expectation among certain respondents that the draft would increase the demands made of private housing developers in relation to the supply of affordable housing. Others thought that agreements were an inefficient means of doing so. There were also comments that such agreements are not relevant in small communities. Some respondents questioned whether planning agreements in relation to affordable housing accorded with legislation and guidance on their use. In addition to the calls for more guidance on affordable housing generally, a number of respondents requested specific guidance on when and how to seek developer contributions.

71. Several respondents recognised that Communities Scotland retain a significant role in the provision of affordable housing through their grant funding programme, but concerns were expressed about both the level of funding available and the short-term commitment. It was suggested that significant opportunities for securing affordable housing could be lost due to funding not being available. Some respondents also suggested that affordable housing should only be sought through the planning system where supported by adequate financial resources from Communities Scotland.

Executive response: The SPP now states that the need for new affordable housing varies within Scotland. The draft had taken that point as read but we realise from the comments received that it needed to be stated explicitly. In response to comments we have also outlined the requirement for development plans to ensure adequate land provision for all housing including affordable housing, where possible in relation to housing market areas. We have maintained the point that it is essential for prospective developers of affordable housing to be clear at an early stage about local needs. In addition we refer to the importance of establishing a clear understanding of the deployment of public subsidy. In the light of the strongly conflicting comments received about the role of planning agreements in securing affordable housing we concluded that it was necessary to remind users of the SPP about the existing guidance which must be followed and which seemed to have been overlooked by some. The SPP also mentions a decision that has been taken to produce advice on good practice in relation to affordable housing.

Planning agreements

72. Paragraph 89 of the draft was intended to highlight the guidance relevant to planning agreements, which can be used to overcome obstacles to the grant of planning permission. Some respondents expressed disappointment that this section was unduly restrictive and did not go beyond Circular 12/1996 on planning agreements. There were suggestions that the guidance should state that developers will be required to finance the infrastructure needs arising from their proposals. It was also suggested that the guidance should give stronger support to development plans that identify infrastructure requirements that would be sought through planning agreements.

73. Other respondents however were satisfied that the paragraph acted as a reminder to the terms of the Circular. There were comment from some that, while planning agreements can be useful instruments and are an accepted part of the planning system, they should meet the six tests of reasonableness set out in the Circular, particularly that they should be related to the development.

74. Another respondent suggested that the guidance should also indicate the circumstances under which public private partnerships might be appropriate to fund development infrastructure.

Determining planning applications

75. A few comments were made that this section emphasised the relationship between the planning authority and the developer and that greater recognition of the role of other stakeholders was needed.

Monitoring

76. Comments were generally positive on the role of planning authorities in regular monitoring of housing completions, availability of effective land and future land requirements. A couple of authorities were concerned about the suggested need to speed the review of policy and possible release of further land where completions were not keeping pace with identified requirements. It was suggested by them that there could be a variety of reasons for this.

77. Other respondents suggested that the SPP should specifically state review periods, with some supporting a biennial review of land requirements. Several suggested that to ensure completions kept pace with identified requirement, there would be a need for 'over-allocation' of sites.

Scottish Executive, February 2003

Annex A: List of Respondents

Aberdeen City Council

Aberdeenshire Council

Acton, Joan

Angus Council

Architectural Heritage Society of Scotland

Bett Homes

Bryant Homes

Cala Management

Chapter 7

City of Edinburgh Council

Clackmannanshire Council

The Coal Authority

Colinton Amenity Association

Comhairle nan Eilean Siar

The Commissioner for Local Administration

in Scotland

Community Self-Build Scotland

Dumfries and Galloway Council

Dundee City Council

East Ayrshire Council

East Dunbartonshire Council

East Lothian Council

East Renfrewshire Council

Edinburgh College of Art

Elphinstone Group

Faculty of Advocates

Falkirk Council

Federation of Master Builders

Ferryhill Heritage Society

Fife Council

Fordham, Dr Richard

The Garden History Society

Glasgow City Council

Glasgow & Clyde Valley Structure Plan Team

The Grange Association

Health & Safety Executive

Helensburgh Community Council

Helensburgh Greenbelt Group

Highland Council

Home in Scotland

Homes for Scotland

Inverclyde Council

Keppie

Kincardine Estate

Lattice Property Holdings

Loch Lomond and the Trossachs Interim

Committee

McNidder, D (for Mr & Mrs John Anderson)

McTaggart & Mickell

Midlothian Council

Moray Council

Morrison Homes Ltd

North Ayrshire Council

North Lanarkshire Council

Orkney Housing Association

Peebles Civic Society

Persimmon Homes (East of Scotland)

Perth & Kinross Council

Redrow Homes

Renfrewshire Council

The Royal Fine Art Commission for Scotland

Royal Institution of Chartered Surveyors

Royal Town Planning Institute

Scottish Borders Council

Scottish Coal

Scottish Enterprise Grampian

Scottish Environment Protection Agency

Scottish Landowners Federation

Scottish Natural Heritage

Scottish Parliament Equal Opportunities

Committee

Scottish Society of Directors of Planning

Scottish Water

Shelter Scotland

South Ayrshire Council

South Lanarkshire Council

Stark, Alistair G

Stewart Milne Holdings

Stirling Council

Sustainable Communities Network Scotland

Tosh, Murray MSP

Unite

Walker Group

West Dunbartonshire Council

West Lothian Council