| Description | Provides an overview of the responses from the consultation responses |
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| ISBN | N/A (Web Only) |
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| Official Print Publication Date | |
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| Website Publication Date | November 15, 2002 |
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REVIEW OF SPP 2 ECONOMIC DEVELOPMENT: OVERVIEW OF CONSULTATION RESPONSES
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INTRODUCTION
Background
1. On 11 January 2002, the Scottish Executive issued a consultation draft revision of the then National Planning Policy Guideline 2 (NPPG) Business and Industry. The revised draft, renamed Economic Development, set out the Scottish Executive's proposed new planning guidance on how land use planning can assist economic development whilst taking account of social and environmental agendas. It covers covered the following four themes:
- to provide a range of development opportunities,
- to ensure that development takes place in sustainable locations,
- to safeguard and enhance the environment, and
- to promote better dialogue between local authorities and businesses.
2. This report provides an overview of the findings from the consultation responses. No Regulatory Impact Assessment has been prepared, as it was considered that the proposals contained in the consultation draft would not increase the regulatory burden on businesses or the voluntary sector.
Responses
3 Approximately 1,200 copies of the consultation paper were distributed to all local authorities in Scotland, a wide range of public bodies, non governmental organisations (NGOs), industry and business interests. The document was also made available on the planning page of the Scottish Executive website. The consultation period closed on 10 May 2002, but a number of responses were received after the closing date. These were all taken into account.
4. In total, there were 69 responses from a wide range of interests which can be broken down into the following categories:
- Local authorities and structure plan teams
| 30 |
- Business and trade organisations
| 15 |
| 4 |
| 3 |
- Voluntary sector and the public
| 6 |
| 11 |
5. A full list of respondents can be found in Annex A. No one requested that their response be kept confidential and copies of all the responses are available for public inspection at the Scottish Executive Library, Saughton House, Broomhouse Drive, Edinburgh EH11 3XD. For an appointment, please contact Mr Alan Gold (0131 - 244 4552). Additionally, a fuller digest of the comments relating to each paragraph is available on the Scottish Executive Planning Homepage http://www.scotland.gov.uk/planning/.
ISSUES EMERGING FROM RESPONSES
General comments
6. The Executive has analysed the comments and, where appropriate, made amendments to the policy guidance. There was a clear message of support for the revised Scottish Planning Policy (SPP) from most respondents including business groups, such as the CBI and SCDI. Many also welcomed the change in title from 'Business and Industry' to 'Economic Development' reflecting the significant contribution made to the economy by non-manufacturing sectors. Whilst most comments on the consultation draft were positive, some thought that the guidance was too general, and did not provide adequate information on prioritisation. It was also considered by some that the document was attempting to accomplish more than the planning system is currently capable of delivering.
7. One issue in particular, which was considered by many, not to have been given adequate attention in the consultation draft was the provision of a clear spatial framework. The Executive has therefore improved the planning context for economic development. The intention is that forthcoming national planning framework will give further consideration to the spatial priorities.
8. Many respondents requested definitions for terms such as 'marketable land'. Decisions have to be made at a local level taking account of all factors relevant to the development. Providing definitions could in some instances provide clarity, but in other circumstances it could act as a constraint, allowing no flexibility for local factors. The Executive has sought to clarify on this point without necessarily providing a precise universal definition.
Key issues
9. Many comments received in the form of drafting suggestions or factual points have been given full consideration. Those issues which are currently outwith the scope of this particular guidance, and have not been addressed include, the role of infrastructure, developer contributions, amendments to the guidance on Simplified Planning Zones (SPZs) and the review of the Use Classes Order. Suggestions were made for future PANs to cover new areas, such as land supply audits and home working. These suggestions will be considered in due course alongside other Executive priorities.
10. Most of the comments relate to the following categories:
- Scope of the guidance
- Providing a range of development opportunities
- Encouraging development in sustainable locations
- Implementation
11. Each is discussed below in more detail, along with an indication of how they have been addressed. Where consultation responses relate to a particular section, the paragraph number referred to in this report is that of the draft guideline issued in January 2002.
Scope of the guidance
Aim of the SPP
12. There was concern from a number of respondents over the real influence that planning, and consequently the SPP, can have in providing for economic development. The Executive
recognises that the planning system has a limited role in influencing economic development, and that it is just one of many factors which have an impact. For this reason the SPP states that its focus has been to look at four key areas where planning can contribute to economic development.
Executive response - In order to set the context more clearly, a new section has been added titled 'Planning and Economic Development'. This section now also clarifies the role of other NPPGs in relation to retail development and tourist related development in rural areas. Whilst the consultation draft featured a background summary of recent economic changes and trends, it was interpreted by many to be policy. To avoid any confusion, it has now been omitted. |
Central belt focus
13. Some respondents considered the guidance had too much of a central belt focus. Many also felt that it failed to recognise the importance that medium and smaller sites have for regional economies.
Executive response - The Executive note this concern. It is considered that in part this reflects the existing geography of Scotland and its concentration of population and business activity. However, in recognition of these concerns, the section on 'Rural Development' is renamed 'Development in Rural Areas' and has been expanded to emphasise the pivotal role that small and mediums scale sites, small businesses, farm diversification, economic development in national parks and forestry clusters can have in these areas. |
Sustainability
14. There was a strong feeling from some respondents that references to sustainability throughout the guidance had been downgraded.
Executive response - This view is not accepted by the Executive, as it is considered that there is an overall recognition of the importance of sustainable development running throughout the whole document. However, in revising the SPP, references to environmental justice, the value of the environment and natural resources have been included. |
Providing a range of development opportunities
15. This section prompted a number of comments and questions. As a consequence, this section (paragraphs 9 to 28) have been amended.
Executive response - Overall, the text has been strengthened to emphasise that there is already an adequate supply of sites, and that the current requirement is now for a limited provision of new sites. Furthermore not all economic development will require similar locations or sites. The adjustments also recognise that while development plans safeguard sites. Action should be taken to identify new sites where deficiencies are identified. In addition, when monitoring and review exercises indicate that there is no longer a market demand for particular sites, they should be renewed and reallocated for particular uses. |
Structure
16. There were many comments which related to the structure of this section.
Executive response - The section on 'Nationally Significant Sites' has been simplified and renamed 'Planning for Particular Uses'. It now sets the context and indicates that a range of sites, influenced in part by the particular location, will support the development of strategic business locations. Other changes include the bringing together of high amenity sites, large industrial sites and large petrochemical sites under the heading of 'National Sites' and wider consideration of the 'Knowledge Based Economy'. |
Key sites
17. There were a number of comments on the list of key sites adjacent to paragraph 15, including the selection of the particular sites. Some respondents provided further suggestions for inclusion, but they were often of a much smaller scale.
Executive response - The sites listed are those that have been subject to engineering, marketing and planning appraisals by Scottish Enterprise working with the local authorities and Scottish Executive. The Executive is of the view that the list should be retained. Although the revised text acknowledges that these will be but one element in the range of sites available in an area and that other sites, including those sites of regional significance will have a contribution to make in supporting economic development. Those sites which have been reserved for Class 4 development have also been highlighted. Although there were some requests to map the sites, a list is considered to be more appropriate. |
Large industrial and business sites
18. Some respondents questioned why Hunterston had been singled out for special treatment in the form of an Annex. There appeared to be little benefit to treating it separately.
Executive response - The Executive accept this and has removed the Annex. The policy in relation to Hunterston remains unaltered, and the site should continue to be safeguarded. |
Large petrochemical sites
19. Some respondents identified omissions in the section on large petrochemical sites, and requested greater recognition of the importance of this type of industry.
Executive response - The text has been amended to clarify which sites should continue to be safeguarded in the development plan. |
Headquarters
20. The paragraph on headquarters resulted in a large number of responses from a wide range of parties. In particular, there were concerns about the apparent emphasis on greenfield sites, and suggestions that other locations be mentioned.
Executive response - Given the potential contribution to the Scottish economy, the Executive has retained this paragraph but additionally acknowledged the potential contribution of sites and locations within town centres and cities. |
Encouraging development in sustainable locations
21. Respondents indicated that the key areas of concern related to the ordering of the paragraphs from 29 to 34.
Executive response - The Executive accepts the comments on this section and has re-ordered the paragraphs. Every effort has also made to give more emphasis as to how transport can support economic development, in particular by strengthening connections with NPPG 17. In addition, the importance of ports as economic generators as well as airports is acknowledged. |
Brownfield development
22. There was some concern that the consultation draft did not give sufficient support to brownfield development.
Executive response - The SPP now further emphasises the potential for brownfield development to support economic development and the Scottish Executive's commitment to social and environmental justice. |
ICT and home working
23. Consultees welcomed the acknowledgement of the contribution of ICT and home-working, but sought more guidance.
Executive response - Additional guidance has been provided on the implications of home-working and residential amenity. ICT allows for new methods of working, such as satellite offices and working from home. It has a role in meeting Scottish Executive objectives for sustainable travel to work patterns and social inclusion. Home working, in particular, is expected to have increasing potential. New homes must provide facilities to allow this to take place. |
Implementation
24. Consultees sought additional guidance on the mechanisms available to ensure deliverability. The view was that the planning system needed to be more proactive. With regard to the section on development plans, there was a request to clarify the bullet points at paragraph 57. For development control, there were differences of opinion. The criticism that the planning system was causing delays was not accepted by local authorities, but this was not shared by the business community.
Executive response - The paragraphs on development planning and development control have been amended to provide stronger guidance. |
Scottish Executive, November 2002
Annex A : List of Respondents
Aberdeen and Aberdeenshire Local Economic Forum | Aberdeen City Council |
Aberdeenshire Council | Angus Council |
Architectural History Society of Scotland | Argyll and Bute Council |
Avecia Ltd | Ayrshire Joint Structure Plan and Transportation Committee |
Bowman Planton Associates | British Airports Authority |
Cala Management Limited | Central Scotland Countryside Trust |
City of Edinburgh Council | Clydeport PLC |
Coal Authority | Colinton Amenity Association |
Confederation of British Industry | Confederation of Scottish Local Authorities |
Dumfries and Galloway Council | Dundee City Council |
East Ayrshire Council | East Dunbartonshire Council |
East Lothian Council | East Renfrewshire Council |
Falkirk Council | Fife Council |
FirstGroup PLC | Garden History Society |
Glasgow City Council | Glasgow and Clyde Valley Structure Plan Team |
GVA Grimley | Highland Council |
Highlands and Islands Enterprise | Homes for Scotland |
Hunterston Development Corporation | Institute of Logistics and Transport |
Inverclyde Council | Keppie Planning |
Law Society of Scotland | Lithgows Ltd |
Loch Lomond and the Trossacks Interim Committee | Marks and Spencer |
Midlothian Council | Moray Council |
North Lanarkshire Council | Orkney Islands Council |
Perth and Kinross Council | Renfrewshire Council |
G M Roberts | Royal Fine Art Commission |
Royal Institute of Chartered Surveyors | Royal Town Planning Institute |
Scottish Borders Council | Scottish Civic Trust |
Scottish Council for Development and Industry | Scottish Enterprise |
Scottish Enterprise Dumfries | Scottish Enterprise Grampian |
Scottish Environment Protection Agency | Scottish Landowners Federation |
Scottish Local Authority Economic Development Group | Scottish Natural Heritage |
Scottish Society of Directors of Planning | South Lanarkshire Council |
Stirling Council | VisitScotland |
West Dunbartonshire Council | West Lothian Council |
Western Isles Council | |