The Key Agencies Rapid Planning Audit, commissioned through the 2025 Programme for Government, was led by former senior civil servant Paul Cackette. The review examined the planning roles of the five agencies with the greatest influence on development management: Historic Environment Scotland, NatureScot, the Scottish Environment Protection Agency (SEPA), Scottish Water and Transport Scotland.

In the report, Mr Cackette describes the system as “essentially good and effective”, but argues that targeted improvements are needed to meet the growing pressures on Scotland’s planning landscape, from climate change to increasingly complex regulatory demands.

A system under strain — but performing well

The report highlights that agencies consistently meet high response rates, with Scottish Water responding within its 10‑day target in 97% of cases and Transport Scotland meeting its 14‑day timescale for 95% of applications. NatureScot, SEPA and Historic Environment Scotland also report strong performance, though all acknowledge challenges in more complex or contentious cases.

Cackette notes that while outright objections are rare, just 2% for NatureScot and 1% for SEPA, delays often arise from “holding objections” triggered by incomplete or inadequate information submitted by applicants.

Five themes for reform

The review groups its recommendations under five broad themes:

1. Building capacity, capability and culture within agencies to strengthen their national role as centres of excellence.
2. Creating a more coherent, shared culture of continuous improvement, including closer integration between agencies and stronger alignment with the National Planning Improvement Champion.
3. Front‑loading engagement through a new fast‑track service for high‑profile or complex developments, supported by clearer information requirements and early triage.
4. Improving pre‑application, validation and consultation processes, including potential mandatory pre‑application engagement for major and national developments.
5. Enhancing digital and AI tools, with a call for more user‑friendly, consistent agency websites and regular reviews to keep pace with technological change.

The report also recommends a periodic review of progress to ensure momentum is maintained.

A call for shared responsibility

While the review focuses on agency performance, Cackette stresses that planning authorities and applicants also have a role in improving efficiency. He warns against adversarial approaches and emphasises the importance of legally robust decisions made at the most local level possible.

He also notes that the review was rapid by design and that further consultation will be required before any recommendations are implemented.

Recommendations

Centres of excellence

RECOMMENDATION 1

Each of the Agencies separately and collectively should develop strategies (or enhance existing strategies) in relation to specialist and professional staff recruitment, induction, skills enhancement, professional development and continuous improvement.

There should be a focus on openness and transparency and a culture of assisting in the constructive seeking of solutions. These strategies should enhance awareness and understanding of the perspectives and needs of all users of the planning system, beyond those of the agency.

All of these should have the purpose of achieving a coherent and focussed objective in the creation of an increasingly effective centre of excellence for the agency, designed to enhance the professional reputation of the agency and to incentivise the effectiveness of the fast track system suggested at Recommendation 6.

National Planning Improvement Champion

RECOMMENDATION 2

The National Planning Improvement Champion (NPIC) should be assigned a role in engaging with the Agencies to-

a) develop a consistent set of data on the performance of the Agencies across a range of criteria in service delivery in their planning functions;

b) develop a range of criteria of best practice in Agencies as part of an Improvement Plan for Agencies in their planning functions; and

c) undertake strategic co-ordination between agencies, including attendance at cross-agency strategy meetings as a member ex officio of the Key Agency Group.

Strategic co-ordination between agencies

RECOMMENDATION 3

Formalised arrangements should be put in place through a new or refreshed Key Agency Group to ensure regular and frequent all-agencies meetings, engagement and delivery of outcomes on common issues of strategy and public service delivery.

The Key Agency Group should, within its remit relating to planning functions, include the desirability of securing inter-agency consistency (where appropriate) in the content and design of their own respective websites. This would identify areas of improvement across all agency web pages and other external facing modes of public communication.

Single Point of Contact or Chief Planning Officer

RECOMMENDATION 4

Each agency should appoint a person to the role of being a Single Point of Contact (or a Chief Planning Officer) in the agency to deliver the advantages identified in this Report.

Accountability to stakeholders

RECOMMENDATION 5

Each agency should establish a proactive stakeholder group, inviting key users of their services to meet regularly with them, under an agreed remit to share developments in practice and concerns.

Fast track system

RECOMMENDATION 6

Agencies should consider, with a view to adopting, a “fast track” system in complex (including national and major) applications that would be prioritised over the more routine involving faster consideration, by a specialist team in the Agency, focussed on such cases.

If adopted, they should publish a Protocol of how it would engage with the applicant in assessing for the interests of the agency, giving consideration of the facts and policies, developing an early indication of likely response (or early identification of any missing information), undertaking to assign the case to their specialist team to prioritise engagement and undertaking close liaison to the outcome desired.

The Protocol would include guidance as to the approach of the agency to the application or otherwise of the fast track system where the requirements of guidance under Recommendation 8 are not satisfied.

Complexity and content of applications

RECOMMENDATION 7

Each agency should take steps (in a manner of, or similar to, Standing Advice) to develop, consult on and publish criteria of the sorts of factors, based on complexity, engage the need for rigorous analysis based on their expertise and responsibilities to identify which pre app discussions and applications, to trigger the availability of fast track procedures referred to in Recommendation 6.

RECOMMENDATION 8

Each agency should develop (or review and update) bespoke guidance setting out in detail the key information as will be required in relation to all applications (including in particular complex applications) about what information is required, in what form or levels of detail and identifying key agency or other relevant policy documents or other materials as are necessary in order to allow the agency to respond effectively and in a timely manner.

This would include the need to identify the agency asset or interest affected and the information needed to assess the impact.

Key Agencies joint statement

RECOMMENDATION 9

All Agencies should renew their commitment to the Key Agencies joint statement on pre-application advice.

Mandatory pre app

RECOMMENDATION 10

Once Recommendation 7 is completed (and subject to the outcomes from that recommendation), the Scottish Government should consider an amendment of the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 to make pre app requirements mandatory where (a) the potential application will meet the tests (as defined in the Town and Country Planning (Hierarchy of Developments) (Scotland) Regulations 2009) of being national or major as a class of development (bringing this into line with community groups) and (b) the requirements of consultation in terms of Schedule 5 to the 2013 Regulations are triggered.

Schedule 5

RECOMMENDATION 11

The Scottish Government should carry out a review of the Schedule 5 requirements as to the content of Schedule 5 to the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 and its continued accuracy as factors to be consulted on.

Consultation on less complex applications

RECOMMENDATION 12

The Scottish Government should consider providing guidance to local planning authorities recommending a change to practice on consultation where it considers that no material need to consult or where the circumstances are not designated as complex, to create a two tier consultation process, where full consultation under the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 is not required in those circumstances, supported by a mechanism for Agencies to provide their full consultation response (where considered necessary).

Consultation generally

RECOMMENDATION 13

On time periods for consultation with Agencies, all local planning authorities should work together to align their timings of consultation requests with Agencies, in accordance with, and meeting, the statutory period under the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013.

Triaging of consultations by agencies

RECOMMENDATION 14

Agencies should review the way in which they triage planning application consultations (including pre app) in the way that they co-ordinate prioritisations in workloads, to reflect the changes recommended in this Report.

Training Requirements for Elected Members

RECOMMENDATION 15

In the development of their programme on training requirements for elected members of authorities, in furtherance of section 45 of the Planning (Scotland) Act 2019, consideration should be given by the Scottish Government to including modules addressing and explaining the functions and inter-actions of all key agencies with planning functions of local authorities.

External faces of agencies - websites

RECOMMENDATION 16

Looking forward, Agencies should establish cross-agency arrangements to maintain consistency, develop continuous improvement and carry out regular reviews of their websites to retain ongoing accuracy and relevance. In particular, subject to the outcome of consideration of agency websites (by the Key Agency Group under Recommendation 3 or otherwise), all Agencies should explore the option, and if agreed, take steps collectively to engage with a duly procured provider of expertise in the constructing or modernising of websites to refresh the webpages of the agencies.

Review of progress

RECOMMENDATION 17

The Scottish Government should make arrangements for a one year review of progress on recommendations in this Report, to be carried out by PARD or another appointed person, as would consider the need for a further annual review or reviews.