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We are watching the situation closely. From conversations with industry and others, I know that it is more of a challenge for some local authorities than others. I will let officials talk to the provisions that are in place to support the specific issue that you mentioned, but I will say that there is a pipeline of land in place across the country to enable development to take place.

The whole point behind NPF4 is that it is a plan-led system, so you agree up front where you will build and then you build there. Moving away from that takes us back to having speculative opportunities come forward in the middle of the process, which causes problems around the other factors that must be considered.

The planning system must be robust, and all the policies, including the biodiversity and woodland policies that we talked about earlier, and flooding issues, which I am sure that we will come on to talk about, need to be considered in the round. The whole point is that you get the plans laid down, you make sure that there is enough supply in place and then you move forward on that basis.

Fiona Simpson will talk about the specifics of addressing some of the challenges.

As with everything else that we have talked about, the letter was intended to bring clarity—in this case, it was to bring clarity to how policy 22, in particular, should be considered. The point that we have made throughout is that NPF4 has been laid out to cover all the different aspects and policies that need to be considered and determined in planning applications. However, if we see the need to give clarification because of how a policy has been implemented, we are very willing and keen to do so to ensure that expectations are more fully understood.

As I mentioned, we are also progressing earlier work in order to do audits of the planning functions at key agencies, including SEPA, to understand specifically how the interplay between what advice SEPA is offering and what the flood teams at planning authorities are looking at is being considered, to ensure that we get the balance right.

Clearly, flood risk is real. For lots of very good reasons, the last thing that anyone wants to do is build somewhere that will get flooded. We are gathering more information all the time about the risks associated with climate change, and the situation is deteriorating over time because of that challenge, which needs to be considered in the round. Getting the balance right is really important, but we are working with all those involved to ensure that we do that.

That is a knock-on effect of the determination that SEPA has made. It is important to recognise that SEPA will take a view, and the planning authority will make the decision. As I said earlier, things are changing, so areas that were not previously at risk of flooding might be now or in the future. On your specific point about individuals who have properties adjacent to land where planning permission has been refused on those grounds, that is outside the planning system’s scope.

First, in terms of the premise, nothing has changed on the timelines for local development plans—the deadline is May 2028. As I said, we are monitoring the situation to understand any risk, and we will work with planning authorities to make sure that they hit the deadline. That has not changed.

I do not know why you think that local place plans would not be included—there is provision for them to be included. If anything, if local development plans were taking longer, there would be even more scope for local place plans to be included, because there would be more time to do that. As I said, the requirement is for planning authorities to consider local place plans as part of the process.

We have deliberately set quite a low bar in relation to what needs to be in a local place plan. It does not need to be a professionally prepared document; it just needs to be an indication from the community of what is important to it. That gets taken into account as part of the local development plan process.

Any communities that are looking at this should be assured that their local place plan will be taken into account. There is support out there to work with communities on preparing and producing a local place plan. Does Andy Kinnaird want to comment?

It is a valid point that goes back to what we said earlier about the high-level estimate of 164,000 stalled sites, which is made up of all kinds of units, from very big sites that are not being built over a period of time because there are commercial issues, for example, right down to very small sites that have individual units. The team is carrying out initial stalled sites work to understand the issues across the country. We will start with the bigger sites and work our way down, because that will have the most impact most immediately. That work is on-going and we have seen the first cut of it. We want to understand the issues that are holding up those developments. We encourage local authorities to look at small sites, particularly in rural areas, to try to understand whether there is anything that they can do to help to secure the build-out of those units.

Just to be clear, that is not a function of the planning system; it is a function of SEPA developing advice based on the guidelines that it has to follow to calculate the likelihood of flooding in any particular area. SEPA generates the flood maps and so on that feed into the planning system. In any given situation, the planning system would take a view based on the information that is fed into it, but any solution to the problem does not lie in the planning system.

We would need to separate the NPF4 document and the policies that are articulated in it, which, as I indicated earlier, we would not want to change. The guidance that sits alongside the NPF4 document gives clarification on whether it is required and how it may be interpreted, adopted and implemented.

The guidance is dynamic. If we identify that more information or more clarification is required, we follow that up. The suite of guidance is easily accessible for those who are seeking to review it. What we have in that regard is already dynamic in that the guidance changes to address challenges, concerns and more new information.

We would not want to go back through the NPF4 process, because that process gives us stability on the policies and it is important for people to have certainty on that.

As I said, it is for planning authorities to make such decisions, but we are very active in working with them to share best practice and put more resource into the planning system at a macro level across the country. As I have said, we have done so by increasing fees and taking steps to bring in more individuals to be trained as planners.

We are also working with some local authorities—particularly smaller ones—to explore opportunities for them to co-operate with other local authorities in sharing resources, particularly specialist resources that are in shorter supply. We are active in that space, but where there are opportunities to do more, we are very interested in pursuing them.

Those are pretty much in place on an on-going basis. There is a heads of planning group, a high-level planning group and specific groups on other issues. There is a lot of, and increasing, engagement with key agencies.

If we look at the numbers, we see that far more units are given planning permission every year than are started or completed. There is a significant amount of land out there for which there is planning permission but which is not getting built out. I do not think that the issue is that not enough planning permission is being granted; there is plenty of land that could be built on. There are other issues, and part of the work that we are doing is to understand why, once land has got planning permission, development is not being taken forward.

There are resourcing challenges that we will talk about, and we have done an awful lot of work to address that, but the evidence shows that although units are being given planning permission in significant numbers under NPF4, those numbers are significantly in excess of the number of units that are actually getting built.