Planning Performance Framework - Annual report 2020/21

Introduction

This is a report to the Scottish Government on our performance within the Planning System during the period 1 April 2020 to 31 March 2021. It reports against a series of performance markers covering different elements of our engagement in the Planning System, and identifies priorities for improvement during the next reporting period from1 April 2021 to 31 March 2022. It follows a template agreed with the other Key Agencies and the Scottish Government.

Description of our service

Our planning service includes advice and associated guidance and capacity-building. It supports implementation of the Third National Planning Framework, and accords with Scottish Planning Policy and the Scottish Regulators’ Strategic Code of Practice. It helps deliver the Scottish Government’s commitment to tackling the twin challenges of climate change and biodiversity loss, and the transition to a net zero carbon economy that is fair for all. The service has a vital part to play in Scotland’s ’green recovery’ from the Covid-19 pandemic and ensuring a resilient nature-rich future.

Our Planning for Development service statement Planning for Great Places outlines our approach and the support that stakeholders can expect from us. It emphasises the connection between people, development and nature, and the importance of achieving the right development in the right place to make Scotland the best place to live, work, visit and do business. It focuses our efforts on upstream engagement in the Planning System; working together with business interests; and providing clear, early advice that is alert to other interests and provides certainty for investment. In summary, we:

• influence national strategic development policies and plans and associated Strategic Environmental Assessment (SEA);
• input to regional and local spatial plans as an active partner in Development and Marine Planning, master plans and action programmes;
• publish guidance and standing advice to help developers assess and minimise impacts on nature;
• provide pre-application advice to developers, and advice to decision-makers focused on matters of potential national interest;
• inform post consent monitoring at a strategic and project level to advance understanding of the impact of development on nature;
• build greater capacity amongst developers and planning authorities to identify nature-based solutions and make sustainable use of our natural assets.

Together with other public bodies and agencies we have embedded the Place Principle in the way we work, to help overcome organisational and sectoral boundaries, and encourage better collaboration and community involvement. The application of our balancing duties helps to make sure we are alert to wider social and economic interests when discharging our responsibilities for nature, and that we are helping to shape Scotland as an inclusive, fair, prosperous and innovative country.

The service delivers benefits that contributed to all four of the outcomes in our corporate plan Connecting People and Nature, around which our work is based:

1. More people across Scotland are enjoying and benefiting from nature.
2. The health and resilience of Scotland’s nature is improved.
3. There is more investment in Scotland’s natural capital and its management to improve prosperity and wellbeing.
4. We have transformed how we work.

2020/21 was a particularly challenging year with the impact of the Covid pandemic on staff wellbeing and availability, and on our ways of working. Despite the difficult circumstances we continued to provide a comprehensive service that has helped to progress key deliverables set out in our business plan for the 2020/21, including:

• Putting nature at the heart of the Planning System by influencing the new National Planning Framework and being an active, valued and influential partner in development planning and regional/city/island growth deals;
• Providing effective input to strategic sectoral and marine spatial planning, to guide sustainable use of our coasts and seas;
• Providing targeted and influential advice on proposals to enable good quality development that secures positive benefits for nature;
• Providing support to Local Authorities and others on how they can embed nature-based solutions to address Government climate change commitments;
• Engaging with key business interests and industry sectors to help them maximise the competitive advantage of nature and invest in the nature-based solutions required in response to the climate emergency and biodiversity crisis.

Organisational structure

The strategic direction of our engagement in the Planning System is provided by our Board and Senior Leadership Team. The service is delivered by Activity and Area teams. Our Supporting Good Development Activity coordinates our work within the Planning System. It leads onshore development advice, our input to development planning, working with Industry and strategic planning. To support this, our People & Places Activity provides advice on placemaking, green infrastructure and engagement with community planning; and our Sustainable Coasts and Seas Activity leads marine planning and development advice. Local delivery of the service across the country is through seven Area Teams (Northern Isles & North Highland, South Highland, Argyll & Outer Hebrides, Strathclyde & Ayrshire, Tayside & Grampian, Forth and Southern Scotland).

Resources

The service is funded through our Scottish Government grant-in-aid. Given the multiple benefits it achieves, we continued to invest a significant proportion of the grant-in-aid in planning and placemaking work. In 2020/21 this was approximately £4 million (8.6% of our £46.6 million grant-in-aid) and was made up of staff costs of about £3.5 million (76 full-time equivalents) and project costs of about £0.5 million.

Performance markers

Placemaking

Strategic planning

We contributed to strategic planning through our advice on a range of policies and plans, associated SEA and the development of plans for projects that are part of the Third National Planning Framework. Our contribution in 2020/21 included:

• supporting the implementation of the new Planning Act by inputting to the work programme for Transforming Planning in Practice as a member of Development Management Working Group and contributing to Key Agency input to other working groups;
• responding to Scottish Government’s position statement for the fourth National Planning Framework (NPF4) and follow up discussion with the NPF4 team;
• supporting the development of Regulations regarding the preparation of Open Space Strategies and Play Sufficiency Assessments as part of the OSSPSA Core Group;
• preparing a commissioned report for Scottish Government on options to deliver Scotland’s ambition for the planning system to secure Positive Effects for Biodiversity and sitting on the Working Group to consider how to take this issue forward in NPF4;
• issuing the ‘Green Recovery Offer’ to all local authorities in partnership with other members of the Key Agency Group Placemaking Sub-group, in order to encourage local authorities to work with the group in a more coordinated way to develop and inform evidence approaches for regional spatial strategies, local development plan preparation or for sites identified as a priority to support a Green Recovery;
• inputting to Scottish Government work to develop the Infrastructure Investment Plan;
• responding to Scottish Government consultations on Permitted Development Rights and regional economic zones;
• advising on 138 SEA consultations, from pre-screening to Environmental Reports (See Appendix, Table 1 for details), covering a wide range of policies and plans eg. Scottish Government’s Climate Change Plan, Infrastructure Investment Plan and Cleaner Air for Scotland strategy, Local Development Plans, Regional Transport Strategies, SG Hydrogen Action Plan and Basin Management Plans;
• responding to consultations on the National Transport Strategy and the second Strategic Transport Projects review, including Case for Change documents and advising Transport Scotland and its consultants on the Habitats Regulations Appraisal (HRA) process;
• inputting to the sustainability plans of energy transmission and distribution companies Scottish Power Energy Networks and Scottish & Southern Electricity Networks;
• continuing input to the work of the SCDI Clean Growth Leadership Group, including comments on the drafts of the Manifesto for Clean Growth which SCDI launched in December 2020;
• supporting Marine Scotland in their road map to deliver evidence needs identified in the Sectoral Marine Plan for Offshore Wind.

Development Plan engagement

We continued to be an active partner in Development Planning in 2020/21, supporting our commitment to a plan-led approach to development. Through engagement in the plan-making process, we planned for further investment in natural capital, helped to balance competing interests and guide development to the right places. Our contribution included advising on development frameworks, briefs and master plans, supplementary guidance, action programmes, SEA and HRA.

Appendix Table 1 shows the number of development planning consultations we received in 2020/21. We received a total of 64 statutory and non-statutory plan consultations. This was a significant reduction compared to previous years as consultations were delayed as a result of the Covid pandemic.

We responded positively to opportunities to engage early in the pre-Main Issues Report plan preparation process, for example:

• virtual charrettes held to inform the indicative Regional Spatial Strategy for Forth Valley;
• Edinburgh Council’s HRA of their emerging Proposed Plan;
• Highland Council’s trialling of a new approach to on-line engagement with their MIR for the Inner Moray Firth LDP;
• collaborative plan and policy making processes related to the Glasgow District Regeneration Frameworks, and contributing to the City’s policy response to the declaration of an Ecological Emergency;
• Phase 2 consultation for the West Edinburgh Spatial Strategy for Inclusive Growth (WE-SSIG) including advice on opportunities for nature networks, green active travel and nature-based solutions.

Development Management

We provided advice on 491 planning application consultations (excluding ‘no comment’ responses). We advised developers, local authorities and agencies on the impact of development proposals on nature, including advice on mitigation. This has enabled the delivery of development priorities across a range of industrial sectors including housing, renewable energy, manufacturing, transport, marine development, fish farming and telecommunications. We also provided advice and support to the Planning and Environmental Appeals Division (DPEA) as a member of the DPEA Stakeholders Group.

Pre-application engagement

Our early pre-application engagement aimed to support a more efficient Planning System. It allowed issues to be identified early in the development and planning process, and afforded time to try and resolve issues ahead of applications being submitted. We responded to 196 pre-application consultations, often in collaboration with other key agencies. This is a similar number to that in the previous couple of years. Examples of pre-application engagement in 2020/21 include:

• continued support for the Scottish and UK Government expansion of digital infrastructure, including the roll out of the Emergency Services Network, Shared Rural Network and Scottish 4G Infill Programme;
• advice on a mixed-use solar, battery and hydrogen proposal at Whitelee wind farm;
• liaison with landscape consultants to agree the National Scenic Area and wild land assessments (Chleansaid wind farm, Corriegarth 2 wind farm and Loch Liath wind farm, Corrievarchie pump hydro scheme);
• meeting with Simply Blue Aquaculture to discuss the site selection and constraints for semi-closed fish farms within the Highlands;
• advising consultants on gaps in ecological and landscape surveys for development proposals resulting from Covid travel restrictions;
• providing advice and support for Transport Scotland’s A83 Access project;
• improving plans for the development of the former Chapelcross nuclear power site as part of the Borderlands Growth Deal project, to make best use of the natural assets of the site and linking these with nature in the wider countryside.
• providing advice to Marine Scotland and SSE on scoping and pre application engagement for Berwick Bank offshore wind development proposal (Scotland’s largest offshore wind scheme to date).

We have continued to focus on Development Management advice cases with potentially the most significant impacts on nature; those that give rise to issues of national interest. Following the establishment of our service statement thresholds for consultations in 2015/16, there has been a significant reduction in the number of planning applications we are consulted on, though the numbers appear to be levelling off (Appendix Table 2.). The 534 planning application consultations received in 2020/21 is similar to the number received in 2019/20 (516).

The success of our pre-application engagement and advice to improve development outcomes is again reflected in the continued low number of application consultations resulting in an outright objection (Appendix Table 2). We objected to 8 planning applications in 2020/21 (1.5 % of consultations received). These were four wind farms (three in relation to impacts on Wild Land Areas and one regarding impacts on an NSA) and four other types of development; housing (NSA impacts), fish farm (NSA impacts), watchtower (SAC impacts) and clay pigeon shooting (SPA impacts). In addition, we objected to three Section 36 wind farm applications (in relation to impacts on an SPA, Wild Land Areas and peatland).

Consenting

Examples of where we have worked closely with developers in 2020/21 to successfully deliver improved development outcomes include:

• discussion with the developers of Strathrory wind farm that led to the removal of our objection on landscape grounds;
• providing advice on Pundeavon hydro track development to minimise sensitive landscape impacts;
• working with the salmon farming company Loch Duart on the production of an Environmental Management Plan to prevent impacts to freshwater pearl mussels within the Abhainn Clais and Alt Mhuilinn SAC;
• advising Scottish & Southern Electricity Networks during the construction of the Lairg to Loch Buidhe overhead powerline to ensure no disturbance to SPA breeding bird interest;
• providing advice and support for Knoydart community in relation to a replacement pipeline and new access track for the community hydro scheme to avoid impacts on sensitive species and landscape.

Delivery of development

We continued to lead the delivery of the following national infrastructure projects that provided further opportunities for active travel, improving health and helping communities to grow economic activity and employment:

• Green Infrastructure Strategic Intervention: The delivery of the GISI projects was significantly delayed during 2020/21 due to Covid-19. All active Phase 1 projects were paused, and Phase 2 projects delayed in starting. All remaining Phase 1 projects are now back up and running and Phase 2 projects will be starting delivery in 2021/22. We still expect to be able to deliver the GISI programme fully by the end of 2023. Fernbrae Meadows was one of the first Phase 1 projects to finish, and has already become a valued resource for the local community, particularly during lockdown when levels of use increased dramatically, underlining the importance of accessible, high quality greenspace.
• National Walking and Cycling Network: We spent £171K on NWCN related projects in 2021, with capital improvements again focussed on Scotland’s Great Trails; and a total joint investment in strategic route development over the lifetime of the project of over £30 million. As well as delivering projects, we have continued to input to policy development, leading several NWCN Steering Group discussions on how a strategic routes project can be taken further as part of NPF4.

Capacity-building

Our programme of capacity-building is integral to our commitment to upstream engagement in the Planning System. It includes training and guidance to support planners and developers, helping them to understand and take account of nature in designing proposals and decision-making.

Sharing good practice, skills and knowledge

We developed and shared good practice with a wide range of different stakeholders to help generate good development proposals. This included:

• continuing our series of ‘Planning for Great Places’ webinars to assist practitioners with development and planning issues, including spatial planning for green networks and delivering green infrastructure;
• improving the reading accessibility of guidance documents on our website in line with The Public Bodies Accessibility Regulations;
• a feasibility study to explore the potential to retrofit blue-green infrastructure around NatureScot/Key Agency shared office spaces;
• delivering a presentation at the Scottish EIA Conference on the role of EIA in enabling Nature-based Solutions;
• a joint Scottish Water/Dundee City Council/NatureScot landscape design commission to support the delivery of blue-green infrastructure in St Mary’s Park Dundee;
• delivering a seminar for DPEA and planning inspectors on our input to the planning system, including issues of natural interest and our balancing duties;
• advice to the UK Space Agency on environmental objectives under the Space Industry Act to inform the work of the regulator;
• developing guidance  to be delivered prior to ScotWind leases being announced;
• delivering a joint presentation with Marine Scotland at a ScotMer symposium  (MS-led Scottish marine energy research programme) on lessons learned from offshore wind development particularly post consent monitoring;
• developing guidance to assist regulators and developers in addressing risks of diving bird entrapment in top nets on fishfarms, and liaising with stakeholders to refine and monitor the results.

We continued to update and expand our range of standing advice and guidance to support high-quality development, including:

• standing advice for any developments potentially affecting beavers, including planning requirements, survey methods, mitigation and licensing;
• staff guidance on dealing with applications to vary section 36 wind farm proposals;
• Piloting landscape sensitivity studies in Moray and Highland Council areas to inform new guidance;
• developing guidance to help design forest buffers to protect rivers and wetlands and maximise their ecological value.

Evidence and data-sharing

Our programme of research and evidence gathering increased knowledge and understanding of development issues, helped to solve problems and improved the quality of development proposals; along with the sharing of our data and making information more accessible to stakeholders. Examples in 2020/21 include:

• a successful bid to CREW to fund research on sediment dynamics on run-of-river hydro schemes;
• creating a GIS layer of notable species for the River Tweed SAC in partnership with the Wildlife Information Centre to help with proposals affecting the River Tweed;
• ongoing engagement and sharing of our protected areas datasets with Network Rail to aid their electrification programme;
• continuing to help maintain the online Air Pollution Information System (APIS), an essential tool for developers and planners in assessing air pollution impacts on protected areas, including the development of a mapping interface for users;
• progressing our GovTech Challenge project to develop an automated online platform for developers and land managers to gain easy access to information and advice regarding protected areas; successful consultants have progressed to Phase Phase 2 and prototype development;
• working with other SNCBs to help develop the Offshore Wind Environmental Evidence Register (OWEER) - a UK initiative building on ScotMer;
• input to Project Steering Groups for marine energy research and evidence projects including ScotMer, ORJIP (Offshore Renewables Joint Industry Programme) and OWSMRF (Offshore Wind Strategic Monitoring and Research Forum);
• Supporting SEPA and Marine Scotland in work to assist the aquaculture sector during Covid to streamline the consenting process and improve accessibility of online map layers for sensitive seabed features.

Service

We aimed to provide an efficient service that kept our advice on plans and applications on track to meet timescales and key deadlines.

Decision-making timescales

We continued to perform well in 2020/21 in terms of response times, with 91% of responses to SEA provided by the required date, and 94% of responses to planning consultations within agreed service timescales (Appendix Table 3).

Joint-working arrangements

We have collaborated with the Key Agencies Group (KAG) and others on initiatives to support the ongoing reforms to the Scottish Planning System, and continue to work jointly with the other key agencies to provide integrated services wherever possible. For example:

• collaborating with Heads of Planning Services to help ensure effective engagement and function of Environmental Clerks of Works in the planning system;
• our ongoing membership of the Scottish Government/Local Energy Scotland CARES panel providing early planning advice on funding applications;
• working with the JNCC, the other country agencies, SEPA and Environment Agency on the UK AERIUS project to develop an integrated air pollution modelling tool to support the risk assessment of air pollution effects on ecosystems, statutory reporting requirements and decision making on individual plans and projects;
• input to the Salmon Interactions Working Group to produce recommendations to guide improved regulation of aquaculture and wild salmonid interactions;
• working with Marine Scotland to develop improved regulation for the use of Acoustic Deterrent Devices in aquaculture.

Engagement with service users

Our independent customer satisfaction surveys gather evidence to support our commitment to continuous improvement. The 2020 Customer Survey provided positive feedback on our performance. The researchers’ key conclusions were:

• Overall satisfaction with the service we provide is high.
• We are seen to make a positive contribution to the planning process.
• Most respondents found it easy to contact staff.
• Views about our guidance and advice were positive.

The main areas where respondents would like to see improvements are in consistency of advice within NatureScot and across other agencies, clarity and conciseness of guidance and higher levels of collaboration with other agencies.

Our complaints procedure provides a further opportunity for customers to contact us over any issues. We received three planning-related complaints in 20201/21. Two from members of the public questioning our advice on a development proposal, and one from a member of Community Council regarding the withdrawal of GISI funding from a project. All three cases were resolved satisfactorily without the need for any escalation.

We circulated our twice-yearly e-newsletter to developers, planners and other stakeholders, keeping them informed of the work we are doing to address development issues and the publication of any new or updated guidance, as well as inviting feedback.

Other examples of engagement with service users included the capacity-building outlined above, as well as working closely with the renewables sector through our engagement with Scottish Renewables and through liaison meetings with individual developers, as well as attendance at key renewables sector events.

Changes to meet this year's improvement priorities

To meet the improvement priorities we had set for 2020/21, we:

• rebranded the organisation as NatureScot, to help raise our profile and demonstrate impact and value as leaders in biodiversity. As NatureScot we will be more recognisable to the general public as the organisation at the heart of how we deliver the transformational change needed to ensure a nature rich future for Scotland;
• responded to the Covid restrictions by transitioning quickly to home working, virtual meetings and online support; and adopting a 90 day planning horizon for prioritisation of tasks, which allowed us to adapt to changing circumstances and the variation in staff time available due to Covid;
• continued to seek to position nature at the heart of the planning system through further input to the development of NPF4, promotion of nature-based solutions, progressing Positive Effects for Biodiversity, and in supporting Scottish Government’s response to the climate change and biodiversity emergencies;
• further embedded the commitments and approach outlined in our service statement Planning for Great Places; taking a place-based approach and keeping the focus of our planning advice on issues of national interest, while maintaining support on issues of lower risk through new standing advice and capacity building with key stakeholders;
• continued to explore the use of digital technology to improve the way we work and to better share information with others;
• engaged further with key industries and business groups to help them deliver maximum benefits for nature and develop the skills required to help secure Scotland’s green recovery from Covid.

Service improvements for 2021/22

Our Business Plan 2021/22 is the fourth and final annual business plan in support of our Corporate Plan for 2018-2022 Connecting People and Nature. It sets out ten priorities for our work across the organisation in 2021/22:

• investing in action to reverse biodiversity loss and jointly lead the Scottish Biodiversity Programme;
• helping to transform use of land and sea so that it contributes even more to the future wellbeing economy;
• supporting a step-change in use of Nature-based Solutions to climate change and other problems;
• focusing effort on mainstreaming natural capital approaches/accounting in decision-making;
• helping to grow and diversify environmental green finance;
• investing in skills for a nature-rich future, especially in youth employment;
• facilitating the role of nature in transforming places where people live;
• supporting and encouraging access to and enjoyment of nature;
• accelerating peatland restoration through our Peatland Action Programme and collaboration with others;
• transforming as an organisation to meet the demands of the future, including accelerating its transition to a net zero emissions organisation.

All these priorities will shape our planning work to some extent, but of particular note we will:

• help to secure strengthened policy and spatial direction in NPF4 that puts nature at the heart of a planning system that embraces nature-based solutions, makes Scotland more resilient to climate change and accelerates the transition to net zero;
• invest in nature-based skills through a training and employment programme, and continue to work with businesses to develop the skills they need to help deliver a planning system that maximises the benefits for nature;
• support Scottish Government in mainstreaming natural capital accounting in decision making, developing new approaches to grow private investment in natural capital and connecting green finance with the emerging approach of Positive Effects for Biodiversity;
• continue to deliver Green Infrastructure investment, advice and good practice to improve urban environments, including spatial and locational planning, and building community skills and capacities to help to transform the places where people live;
• look to further streamline our involvement in development management casework, and free up more time for upstream engagement in the planning system and a greater influence on strategic and development planning stages.

During the course of 2021/22 we will be preparing a new Corporate Plan for 2022-2026. This will further establish the direction and challenge we are setting ourselves in helping to address the climate change and biodiversity emergencies, and the changes we need to make to the way we work in order to meet that challenge.

Appendix: Consulting Statistics

Table 1

Development plans

Number of consultations	14/15	15/16	16/17	17/18	18/19	19/20	20/21
Statutory consultations on MIR	10	14	9	8	6	7	4
Non-statutory consultations on MIR1	18	8	19	15	10	9	3
Statutory consultations on Proposed Plans	46	58	15	10	42	66	45
Non-statutory consultations on Proposes Plans2	59	37	72	51	25	14	12
Total no. of consultations	133	117	115	84	83	96	64

 

SEA

Number of consultations	14/15	15/16	16/17	17/18	18/19	19/20	20/21
Pre-screening and screening	185	150	106	176	166	197	102
Scoping	37	38	31	25	34	27	16
Environmental Reports	51	51	40	28	36	40	20
Total no. of consultations	273	239	177	229	236	264	138

 

Planning applications

Number of consultations	14/15	15/16	16/17	17/18	18/19	19/20	20/21
Applications subject EIA	254	152	110	103	97	104	111
Non-EIA application consultations	788	568	535	594	655	412	423
Pre-application consultations	356	333	313	250	219	186	196
% of all applications subject to pre-app advice	30%	32%	27%	25%	25%	27%	31%
Total no. of consultations	1042	720	645	697	752	516	534

 

Table 2

Planning application response types	14/15	15/16	16/17	17/18	18/19	19/20	20/21
Outright objection	9/0.9%	5/0.7%	6/0.9%	5/0.7%	2/0.3%	3/0.6%	8/1.5%
Conditioned objection	61/6%	40/6%	47/7%	48/7%	65/9%	47/9%	57/11%
Holding objection	34/3%	36/5%	41/6%	35/5%	32/4%	23/4%	37/7%
Advice only	782/75%	592/82%	499/77%	564/81%	591/79%	400/78%	389/73%
No comment	156/15%	47/7%	52/8%	45/6%	62/8%	43/8%	43/8%

 

Table 3 

Development plans

Average response times (days)3	14/15	15/16	16/17	17/18	18/19	19/20	20/21
Statutory consultations on MIR	61	53	46	75	35	78	55.5
Non-statutory consultations on MIR1	28	27	25	19	8	28	17
Statutory consultations on Proposed Plans	25	30	16	17	40	26	29
Non-statutory consultations on Proposes Plans2	17	19	25	32	17	19	30.5

 

SEA

Average response times (days)3	14/15	15/16	16/17	17/18	18/19	19/20	20/21
Pre-screening and screening	11	11	7	6	9	9	11
Scoping	23	24	25	22	26	29	30
Environmental Report	40	45	39	44	40	49	56
All SEA consultations	18	20	14	7	16	13	17
% of responses by required date	99%	98%	100%	98%	96%	98%	91%

 

Planning applications

Average response times (days)3	14/15	15/16	16/17	17/18	18/19	19/20	20/21
EIA consultations	21	27	21	24	28	21	25
Non-EIA consultations	13	13	12	11	13	13	13
Pre-application consultations	16	15	16	15	15	18	16
All planning consultations	14	14	13	12	13	13	14
% of EIA responses provided within 28 days	70%	60%	68%	65%	55%	63%	67%
% of non-EIA responses provided within 14 days	64%	64%	66%	66%	63%	64%	61%
% of responses provided by required date (incl agreed extensions to statutory deadlines)4	96%	95%	96%	95%	94%	95%	94%
% of all responses subject to an agreed extension to statutory timescale	15%	16%	15%	16%	18%	15%	18%

 

¹ Includes consultations on topics such as calls for sites, topic papers, research, HRA, SEA and draft supplementary guidance.

² Includes consultations on documents such as draft Proposed Plans, HRA and SEA draft supplementary guidance.

³ Median used to calculate the average.

⁴ Required dates include those where a new extended deadline has been agreed with the planning authority and where they have given us an initial deadline which is greater than the minimum 14 days.