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Enhanced Role and Status for the NPF
Local Authorities
City of Edinburgh Council: The Council, together with the other three Lothian councils, has consistently stressed the need for the NPF and development plans to be supported by a firm commitment to delivering essential infrastructure. The proposals go some way to meeting these concerns, but the links remain weak. For example, the White paper suggests that the NPF should be informed by the National Transport Strategy, whereas a more logical approach would be for the Transport strategy to fit within the overall aims and objectives of the NPF as the primary spatial strategy for Scotland. Another issue is that of participation in the preparation of the NPF - the proposed consultation on a draft NPF and more stakeholder involvement in its preparation would allow the Committee to input its views at the appropriate stage on how national policies affect the City's development. Finally, there is an issue is about democratic scrutiny of the NPF content. There is a general proposal for Parliament to contribute to the development of the NPF but no proposal to allow detailed or independent scrutiny of its content. Without such examination there is an incompatibility with the principle of "front-loading participation" applied to other development plan processes so that they create a stronger framework and less delay for development decisions.
Dundee City Council: It is noted that the next review of the National Planning Framework will be reviewed in 2008 and will be the subject of extensive consultation. However it would appear that there is no provision for an examination in public of the NPF. Confirmed NPF proposals are to be incorporated into development plans at the local level. It would appear that in considering National Developments identified in strategic/local development plans the principle of the development may not be questioned although there would be debate on matters of detail.
East Renfrewshire Council: Strongly supported. Provided that it truly is a national, corporate plan that will dictate priorities and concerted action. Should also provide strong guidance on how national economic, including housing land allocations, and infrastructure targets are to be met. While it is right that any project should be the subject of receiving formal consents, as NPF projects their special status should be recognised. Ideally inclusion in the NPF should confer approval in principle otherwise the timescale for delivering the project is likely to be considerably delayed by the Public Inquiry process.
Falkirk Council: The NPF could have considerable impacts on local communities. Consultation is to be carried out 011 the NPF but very limited information is provided about the proposed scrutiny arrangements and, in particular, it is not clear how Councils' local communities and the general public are to be involved. Reference is made to the NPF also being subject to SEA but decisions on its content are to be made by Parliament without any apparent opportunity for objections through a public inquiry process. This then raises the prospect of NPF proposals with which the local planning authority does not necessarily agree having to be included in its development plan and presumably defended through the inquiry process, placing the Council in a potentially very difficult position at a hearing or inquiry. During earlier rounds of consultations the Council raised concerns that the NPF was weak in relation to implementation and delivery, particularly on how major infrastructure challenges were to be resolved. This deficiency appears to have been recognised in the White Paper with other authorities and agencies which have responsibility for these functions being required to link their investment programmes with the NPF and to have regard to the Strategic and Local Development Plans.
Fife Council: This is supported. The preparation of a National Planning Framework has been helpful in moving forward the debate on planning policy in Scotland over the past two years. The NPF will be subject to extensive consultation, including the processes required for its SEA. This should be welcomed, given the transparency of Assessment process and opportunity for scrutiny of decision-making
Glasgow City Council: Many of the Council's previous comments on the NPF have been taken into account by the SE in their proposals on its future role and relevance. Nevertheless, it is considered that the SE still requires to address the following issues on the role and operation of the NPF. An outline of the process for producing NPF2, and a clearer indication of expected local authority input, is required. Additional information on the practicalities of how the new system is expected to work is required. Recognition of the continued role of cities as the main drivers of the Scottish economy is welcomed.
Inverclyde Council: This is long overdue, although the consultation process leading up to the next review/update of the NPF will have to be more inclusive than last time. Importantly, here should be a mandatory requirement upon the SEDD to publish the NPF in draft before finalising the document, unlike last time.
North Ayrshire Council: It is essential that proper provision is made for consultation with local planning authorities in the preparation of the Second National Planning Framework. It is also imperative that commencement of the Second NPF does not allow the argument that any developments of national strategic importance or emerging structure plans are premature in advance of adoption of the NPF.
North Ayrshire Council (Chief Executive): It is essential that proper provision is made for consultation with local planning authorities in the preparation of the Second National Planning Framework. It is also imperative that commencement of the Second NPF does not allow the argument that any developments of national strategic importance or emerging structure plans are premature in advance of adoption of the NPF.
Renfrewshire Council: National developments should be clearly identified in the National Planning Framework which should be subject to wide consultation prior to its approval.
Scottish Borders Council: While it is proposed that the next National Planning Framework will be subject to more extensive consultation than the first document, it is considered inconsistent with the underlying principles of the White Paper that the most significant national developments should be subject to less public scrutiny than more modest development proposals. It is also considered unreasonable that local authorities should subsequently be required to promote and approve the details of major development proposals which have effectively been approved in principle at national level but to which they may be opposed.
South Ayrshire Council: The extent of information to be contained in the NPF on outputs is not known, however given that at present Council policy driving the delivery of these services and facilities is often derived from research at local authority level ( e.g. housing needs assessment informing the Council's affordable housing planning policy), it is hoped that local authorities will be given the opportunity for full involvement in the development of this aspect of the NPF.
West Lothian Council: The proposal to strengthen the role of the NPF is supported particularly if it places greater emphasis on implementation and identifies delivery mechanisms. However, clarification is required on the status and scope of the document. It appears that the NPF will allow Scottish Ministers to determine the use of key strategic sites both through direction on land use allocations in development plans and subsequent call-in powers on planning applications. This could be viewed as circumventing local democratic control and, if implemented, would impact on the council's ability to determine future uses on key development sites. Similarly, it would be of concern to the council if developments of the scale of West Lothian's core development areas were identified as key strategic sites. Further clarification needs to be provided on this proposal before the council could offer full support.
Other LA Organisations
COSLA: We have always been clear that this document will need reviewed and updated regularly to ensure it keeps step with local priorities as well as being able to respond to sudden changes such as large-scale redundancies or indeed large-scale inward investment. If local planning authorities have to undertake a 5-year development plan cycle, then it would seem logical that a policy document which is expected to act as an 'umbrella' to such a cycle should be refreshed at least every 3 years.
Edinburgh and The Lothians Structure Plan Joint Liaison Committee ( ELSPJLC): Proposals for a strengthened NPF, particularly its proactive emphasis on implementation and delivery, are supported. However, it is essential that the NPF is itself supported by a firm commitment to deliver essential infrastructure. There must be a much closer link between the NPF and the investment priorities of infrastructure providers such as Scottish Water. The NPF should also give greater guidance on spatial issues such as the distribution of new housing, economic growth and renewable energy development and secure co-ordination with other plans and strategies, including the National Transport Strategy, Regional Transport Strategies and Area Waste Plans. There must be a clear commitment from all divisions of the Scottish Executive to support projects identified in the NPF, including required infrastructure provision.
Glasgow and the Clyde Valley Structure Plan Joint Committee: The Joint Committee had consistently argued for a clear long-term planning vision for the development of Scotland, within which its own work would be framed. It welcomed the publication of the first NPF in 2004, and argued that future NPFs should have greater clarity in defining national priorities, in providing a clear context for action at the metropolitan level and for a commitment from the Executive that the NPF would have clear and direct linkages to the spending programmes of the wider Executive and its Agencies. The White Paper proposals appear to be consistent with these demands, although there remains a question as to how, in practice, the NPF will link with the spending programmes. There remains also a question as to the process by which Strategic Development Plan Authorities such as the Joint Committee, is tied into the development of the NPF and how Development Plan priorities are evaluated and integrated into future NPFs. This aspect will be vital to the delivery of Development Plans if the NPF is to become the key tool framing strategic spending programmes.
Non Departmental Public Bodies
Defence Estates: Given the proposed enhanced role and status of the National Planning Framework ( NPF), we consider that further details are required about the procedures that are to be used to ensure that all parties are given the opportunity to become involved in the revision of the document. We consider that clarification is required as to how the Scottish Minister's will determine the need for developments that are to be included within the NPF. Some of the landholdings within Defence Estate's portfolio may be brought forward for redevelopment over the next 20-year period raising issues of national importance. We suggest that a consultation draft of the NPF should be prepared. A formal consultation period for the draft NPF should be introduced and that there should also be statutory timeframes set for its review and update. It is noted that, despite its proposed increased importance, the NPF is not proposed to be subject to public inquiry or hearing.
Disability Rights Commission ( DRC): The definition of sustainable development with clear reference to accessibility should be explicit in the next National Planning Framework in order to effectively inform the policies and procedures of each development plan. The DRC would encourage a model of sustainable development that identifies how economic growth, the environment and social inclusion are integrated. In particular, we feel that social inclusion should also make reference to the physical and cultural barriers communities experience.
Highland and Islands Enterprise: However, the key to its successful operation in practice would be the development of the National Planning Framework ( NPF) and we believe that, while the first version is a helpful start, great effort will need to be put into building the Framework to comprehend fully the economic development drivers which will influence Scotland's future. The expansion of renewable energy is a very clear example from a Highlands & Islands perspective. The Framework will also need to develop greater insight into the linkages between planning policies and the Executive's enterprise development policies set out in A Smart, Successful Scotland. From an HIE point of view, this would be of particular importance in terms of the population growth aspirations of A Smart, Successful Highlands & Islands. We also support the need for the incorporation of a stronger geographical perspective: our plea here would be to ensure that the important differences between parts of rural Scotland - and their consequently differing development needs - are fully recognised.
Historic Environment Council for Scotland: While HEACS supports in principle the need for the continuation of the NPF and for its effective review, there is disappointment that the published version pays scant regard to the significance of Scotland's environment, let alone the historic environment. The planning process is about the interrelationship and interaction of different land uses, and about the effective planning of new investment that enriches existing communities and countryside. It is to be hoped that any further NPF will recognise these non-monetary benefits to the Scottish economy rather than just becoming an extension of service infrastructure programmes. The NPF is in a unique position to set the government's cross-cutting agenda between land use change, transport, environment and the social economy and the opportunity should not be wasted. It is also evident that large infrastructure projects will take many years to plan and implement. A potential drawback could be the degree to which the system is subject to short-term political interference during the normal cycles of electioneering for terms of government - it is recognised, however, that this could also be a strength. The reality is, however, that there is an overriding need for long-term stability in dealing with changes to the historic environment and it is doubtful whether the current legislative framework provides that basis. The NPF could provide a useful vehicle for the reinforcement of its importance.
NHS Lothian: It is considered that explicit recognition of the impact of housing developments on health provision within the planning process, policies and guidance at national level would assist in ensuring that local planning authorities are able to fully consider this issue. NHS Lothian therefore requests that the need to consider the impact on local and where necessary other health services is addressed by the modernisation of the planning system.
Scottish Enterprise: Scottish Enterprise has tailored its physical interventions to meet the spatial priorities outlined in the present Plan. Given the importance of the NPF, Scottish Enterprise believes that the Network should be a statutory consultee in the determination of future plans, to ensure that the needs of economic development are firmly articulated. The intention to prepare statements of policy on planning matters of national importance (including the NPF) is welcome; it would, however, be helpful to clarify the relationship between these statements and the existing Scottish Planning Policies ( SPPs).The statement that the NPF 'will be closely linked to…the investment programmes of public agencies', and we would welcome further discussion of the process by which this will be achieved. The strengthened role envisaged for the next NPF means that it will need to be more spatially explicit than the present version, and will need to identify natural heritage resources of national importance, including sites and areas designated for this purpose. We would also suggest that the NPF should take a broadly integrative approach and link to other national plans and strategies, where necessary extending beyond the scope of the planning system itself. These should include the Scottish Biodiversity Strategy and other national land use planning documents such as the Scottish Forestry Strategy. It is essential that the NPF, in conjunction with other 'statements of policy' from Ministers and SPPs, provide a sufficiently comprehensive and robust strategic framework to guide development, particularly in areas with single tier development plans. In view of the strategic importance of the new NPF, we strongly endorse the need for widespread consultation during its development. There will be limited scope to challenge proposed developments on grounds of principle so early and visible public engagement is therefore critical to ensure that local people do not become disillusioned.
Scottish Environment Protection Agency: Welcomes the identification in the White Paper of strategic water treatment and waste management installations as national developments and the implication that these will be set out in the NPF. SEPA has been critical in the past regarding the ability of the existing planning system to set an appropriate framework for the delivery of facilities required to meet targets set in the National Waste Plan. It is hoped that the enhanced implementation focus of the NPF and the intention to include waste management priorities will address this problem. Accordingly SEPA supports the NPF and the focus to be given to its implementation. While SEPA supports the reference in the White Paper to ensuring that those with an interest are given "real opportunities" to express their views, it is not clear how those views, once expressed will be considered. A mandatory examination is being proposed for all other plans that will comprise the development plan network for Scotland, yet this does not appear to be extended to the overarching NPF. Further details of how stakeholder views will be considered and reflected in decisions should therefore be provided. Given the importance of the NPF and the scale and significance of the developments it will put forward, it is vital for the credibility of Scotland's planning system that stakeholders feel that they are contributing positively to a process that will fully take account of their views. It is important that communities that may be affected by large scale proposals have access to the process of scrutinising them. The Strategic Environmental Assessment process will, through its consultation requirements, assist with this, but SEPA would wish to see firm proposals that clearly set out how public and stakeholder views will be considered. Without an effective means for those with an interest in the NPF to challenge it and have views heard through independent examination, we are concerned that public scepticism about the Scottish planning system will remain. This is particularly the case given that the framework for major decisions that will affect the lives of many people will be set by the Executive in the NPF.
Scottish Natural Heritage: The proposed provision for Ministers disaffected from the new system. There may also be a case for building some mechanism for limited local challenge into the proposed reforms.
Scottish Water: We note the primacy of the National Planning Framework and the outline objectives to be incorporated into the production of the second NPF in 2008. We believe that there is a need for further definition of the National Planning Framework in terms of spatial planning. In terms of provision of water and wastewater services for National Developments we foresee a challenge in integrating our investment cycles and industry objectives with the strategic horizon likely adopted by these nationally important developments. This will need to be addressed in order to achieve the aims of the white paper. Whilst we support the principle of the NPF, we believe that the intention for the NPF to "set out the land use planning requirements for strategic priorities such as investment in water and drainage capacity and waste management facilities" could present a challenge for Scottish Water given the nature of our legislative-driven and Regulatory-controlled investment programme. We believe the rigidity of a land use planning regime in the context of our 4-year investment programmes and the proposed 5-year development plan-making cycle would give rise to conflict on occasion such as where, for example, in complying with NPPG 10, Planning Authorities are required to make specific allocations for "Sewage Treatment". Further, it would be a challenge for Scottish Water to make a commitment to strategic development proposals that fell outwith the Scottish Water's investment cycle, regulatory timelines and the 5-year horizon of development plans. We would require some flexibility to accommodate these challenges.
Other Public Bodies
Central Scotland Forest Trust: We support the establishment of the National Planning Framework as an instrument for securing the delivery of national policies and programmes. We propose that these should include key 'green' programmes with a spatial dimension, and in this respect would seek recognition of the Central Scotland Forest as a greening priority, as this will facilitate its support in development plans and subsequent delivery.
Strathclyde Passenger Transport:SPT welcomes the proposals for the second NPF to place more emphasis on implementation. We believe this is an opportunity to take account of further work done on transport projects of national significance. SPT would like to hear more on how the extensive consultation work currently being undertaken to inform the National Transport Strategy will feed into the NPF. The timing of the second NPF in terms of the strategic projects review is also an issue that should be addressed.
The Development Industry
Bett Homes: Our view is that if the NPF is to be more than just a "wish list", it is vital that the Executive works closely with the development industry and other key public bodies during its preparation in order to insure the deliverability of key strategic projects. Our primary concern relates to the proposed consultation and preparation process for the NPF. Considering the proposed statutory importance to be placed on the role of the NPF in planning decisions, we consider that it is of vital importance that the preparation of strategic policies and proposals is undertaken in an accountable and transparent manner. On this basis Bett Homes would promote the statutory requirement for the public examination of the NPF.
Elphinstone Land: The White Paper is not specific as to what the "enhanced status" of the NPF will involve. However it is clear that if it is to set national priorities, indicate the location of "national developments" and the means of implementation, then it will be necessary for the NPF to have to have statutory status. It would then be a "material consideration" in planning terms and would have to be taken into account by planning authorities in plan making and in reaching decisions on planning applications. This would also assist its role in setting housing or other regional targets. However, the preparation of the NPF should be done in consultation with stakeholders.
Glasgow Harbour Ltd ( GHL): Given the proposed enhanced role and status of the National Planning Framework ( NPF), it is considered that further details are required about the procedures that are to be used to ensure that all parties are given the opportunity to become involved in the revision of the document. We consider that clarification is required as to how the Scottish Ministers will determine the need for developments that are to be included within the NPF. We suggest that a consultation draft of the NPF should be prepared. A formal consultation period for the draft NPF should be introduced and there should also be statutory timeframes set for its review and update. It is noted that, despite its proposed increased importance, the NPF is not proposed to be subject to public inquiry or hearing. We consider it extremely important that areas currently identified as being priorities for regeneration and renewal, such as the Clyde Waterfront, are identified in the revised NPF.
Homes for Scotland: Homes for Scotland is supportive of the NPF as a guide for development in Scotland and welcomes therefore the statement that the Scottish Executive will develop further the NPF, "enhancing its role and status". We are unclear, however, what this statement will mean in practice. We note that there is no reference to a statutory basis for the next NPF, either in section 5.1.2 or appendix 8 of the White Paper. We consider this to be a serious omission and we recommend that a statutory basis for the NPF should be provided in the forthcoming Planning Bill (Regional Spatial Strategies in England have statutory basis). Without a stronger statutory basis, the NPF will continue to be only a material consideration and, in some cases, carry less weight than local development plans on the assumption that Section 25 will continue to give them primacy. Furthermore, this status should extend also to other Scottish Executive published national planning policies which at a minimum should have equal weight to development plans. Our experience is that Reporters can give greater weight to development plans over national policies The preparation of NPF 2 should be more inclusive, subject to greater consultation and have greater input and involvement from stakeholders, including house builders. Without such changes, NPF 2 will not be seen to be sufficiently open and transparent and will not carry the confidence of the development industry. Homes for Scotland is of the view that the move to single development plans through most of Scotland could lead to a possible weakening in the strategic component in the new local development plans, hence the need for a stronger role for NPF 2 in setting out the strategic scale of new housing required. The contents of NPF2 to be published in 2008 need therefore to be overhauled and extended to provide a stronger strategic component for the new development plans by including housing numbers and targets, linked where appropriate to priorities for economic investment, and advise on pressured areas such as the Edinburgh housing market. An improved process for addressing the quantitative issues is therefore essential but, as SPP 3: Planning for Housing recognises, the overriding objective must be broader, giving stronger weight to qualitative issues. As SPP 3 acknowledges, the completion of quality dwellings and the creation of sustainable, mixed, residential developments of high environmental quality are important. While the new Planning Act will be important in providing for the more efficient preparation and delivery of new development plans, it is only part of the planning process. Of equal importance is the nature and location of new development and how it contributes to sustainable economic development including the quality of the built environment. This reinforces further the need for the Planning Bill to set out the purpose of planning.
Manor Kingdom Group: The size of the country in relation to the existing development pressures requires a strong lead context such as the National Planning Framework ( NPF) in order to target investment in infrastructure and to maximise private investment. Manor Kingdom is supportive of the NPF as a guide for development in Scotland and welcomes the statement that the Scottish Executive will develop further the NPF, "enhancing its role and status". We understand in principal how this concept operates but in practice we are unclear as to how this will function. This status should extend also to other Scottish Executive published national planning policies which at a minimum should have equal weight to development plans. Our experience is that Reporters can give greater weight to development plans over national policies. The need to provide a clearer statutory basis for NPF2 should be accompanied by other major changes, both in the approach to its preparation and in its contents. The preparation of NPF 2 should be more inclusive, subject to greater consultation and have greater input and involvement from stakeholders, including house builders. Manor Kingdom is of the view that the move to single development plans through most of Scotland could lead to a possible weakening in the strategic component in the new local development plans, hence the need for a stronger role for NPF 2 in setting out the strategic scale of new housing required. The contents of NPF2 to be published in 2008 need therefore to be overhauled and extended to provide a stronger strategic component for the new development plans by including housing numbers and targets, linked where appropriate to priorities for economic investment, and to advise on pressured areas like the Edinburgh housing market. An improved process for addressing the quantitative issues is therefore essential but, as SPP 3: Planning for Housing recognises, the overriding objective must be broader, giving stronger weight to qualitative issues.
Muir Group: The NPF will require to address the existing development pressures to permit the necessary investment in general infrastructure to promote and maximise private investment.
Persimmon Homes: Statutory weight to the NPF is welcomed but it also imperative that this linked to the spending and investment programmes of public bodies and other infrastructure providers.
Stuart Milne Holdings: This Company recognises the Executive's proposal to increase the importance of the National Planning Framework and as a consequence would endorse this position. However we would wish the Executive to go a step further and would therefore endorse a statutory status for the National Planning Framework. This proposal should also increase the extent and content of the Framework to include policies to direct major household growth in line with other policies relating to economic development and major infrastructure investment. With regard to the future preparation of the next Planning Framework, this Company would endorse the position of Homes for Scotland that it should be subject to greater consultation and have greater input from relevant stakeholders. This approach is similar to the preparation of regional spatial strategies In England and would seem to offer a possible model which could be replicated.
Stewart Milne Homes: The existing National Planning Framework for Scotland ( NPFS) was in our view a disappointing document and if NPFS2 is to have a statutory basis it needs to be the subject of greater consultation and have greater input from stakeholders. We propose that the NPFS2 is the subject an examination in public to ensure this is achieved. It also needs to focus more on economic growth and planning for economic growth. Further information is required on how the NPFS will influence the new generation of development plans. It is identified in the White Paper that the NPFS2 will be published in 2008. However, if Development Plans are to be based on this the delay in its publication may hinder the first round of development plans. This should be addressed in early course.
Other Businesses
British Energy: We note that the criteria for determining which developments should be treated as National have yet to be clearly set out. We would suggest that guidance be issued on the nature and scale of developments, which would fall into this category, recognising that there may be some need for discretion and flexibility. With specific reference to energy development, UK Energy Policy should, in our view, play an overriding part in determining the type and location of developments proposed in the National Planning Framework ( NPF). Focusing on electricity, with some 50 % of Scotland's demand being met by two nuclear power stations the ongoing provision of this component should, in our view, be a key consideration for the forthcoming NPF.
British Nuclear Fuels Ltd: We believe it is vital to have a coherent and effective delivery of national strategic developments such as energy projects. We therefore welcome the proposal that developments of national strategic importance be set out in a National Planning Framework and that it be cascaded down into regional development plans. This should be a very helpful step in facilitating progress of energy developments and providing a clear focus at every level. The requirement to regularly update these plans is also welcomed. We are also encouraged to see the encouragement of cooperation between adjacent local authorities for major and national developments that naturally affect a wide area.
CBI Scotland: We particularly welcome the proposals to enhance the role and status of the National Planning Framework so there is better alignment between national, strategically important infrastructure projects and local development plans. There should be a statutory requirement on the part of local authorities to make provision for national developments in their local plans. Local communities should be able to influence the design/environmental impact of national infrastructure projects, but they should not be able to prevent them going ahead once Ministers and Parliament have approved them in principle.
Federation of Small Businesses: The FSB has long called for a more strategic approach to economic growth in Scotland. A National Planning Framework ( NPF) is an essential element of this type of approach. As highlighted in the White Paper, the next NPF must have clearer links with the Framework for Economic Development in Scotland and the existing Infrastructure Investment Plan. There must be a transparent process of consultation and analysis. Recent criticisms from the Finance Committee regarding the lack of analysis by the Scottish Executive of identifiable outcomes from economic development spending should be a consideration in assessing future infrastructure priorities. Businesses look forward to playing their part in these discussions. We note the comments about city regions but would comment that many small businesses - which make up 98% of all Scottish firms - are not based in, or near, cities and their needs in relation to infrastructure should not be ignored.
Forth Ports PLC: Welcomes the proposal to enhance the role and status of the National Planning Framework ( NPF) to make it a more effective tool in delivering projects of national importance. Forth Ports PLC would however wish to have a clearer understanding of its statutory status particularly in relation to local development plans and in determining planning applications. If the NPF is to have equal, or higher, status to the development plan, this requires to be confirmed in the Planning Bill. The NPF must make the difficult choices involved in prioritising developments of national importance, and these developments need to be carefully defined. In particular there should be a clear priority for major infrastructure improvements to the transport system in Edinburgh, in recognition of the role this will inevitably play in the continued and accelerated economic growth of the Capital City. Similarly the focus throughout national planning policy guidance on re-using brownfield land justifies the NPF prioritising major brownfield developments ahead of other locations. It is recognised that the White Paper will not address the content of the NPF, but we would urge the Executive to recognise the importance of a significantly strengthened NPF by focusing resource on its earlier delivery, and by addressing some of the policy issues which will inform the content.
Orange PCS Ltd: We welcome the intention to provide guidance on policy for delivering major infrastructure needs of national importance. Telecoms developments although small have significant economic and social benefits and policy needs to continue to be determined at national level.
Scottish Chambers of Commerce: The NPF will require to address the existing development pressures to permit the necessary investment in general infrastructure to promote and maximise private investment.
Scottish Rural Property & Business Association: The National Planning Framework affords an opportunity to acknowledge the role planning must play in addressing the issues surrounding affordable rural housing and put affordable housing in the countryside onto a national platform. The SRPBA also believes that national planning policy must recognise the value of rural exception sites. We would urge the Scottish Executive to use this opportunity, in conjunction to make it explicit in planning policy that rural exception sites can be appropriate, and indeed commendable, method of delivering affordable housing in rural areas.
SITA ( UK) Ltd: The White Paper refers to waste management installations as being an example of the category of development likely to be considered to be a "National Development". Without more detailed definition as to the nature of a waste management installation that would be viewed as a "National Development", the Company feels that this may subject applications for development for comparatively modest facilities to an unwarranted level of determination. Furthermore, the Company is wholly opposed the withdrawal of the right of appeal to Scottish Ministers, for "National Developments" and "Minor Developments", as this would be wholly disproportionate to the scale of development. This aspect of the Executive's proposals would also withdraw an applicant's right to an appeal against the determining authority's decision on the basis of the planning merits of an application, given that the Courts' will examine solely the legalities of the decision. It is possible that such an approach may have Human Rights implications.
Tarmac Ltd: Support the need for national policy to be incorporated into local plans and decision-making. As suggested this will act to reinforce protection for communities but it is also essential to set a fairer system for development proposals where wider needs must be taken into account. This is particularly relevant to development plans, which can presently pay limited, heed to national policy and, once approved form the principal planning text.
Unison (Scotland): The National Planning Framework has to be about more than land use. It must incorporate wider public policy issues and reflect the need for long term development - beyond the normal political time scales. We are also concerned over the absence of detail on how parliamentary scrutiny will be undertaken on the National Planning Framework. It is essential that proposals be robustly tested given the implications for local communities. There should be clear statutory procedures for the involvement of local planning authorities.
Universities Superannuation Scheme Ltd ( USS): Given the proposed enhanced role and status of the National Planning Framework ( NPF), it is considered that further details are required about the procedures that are to be used to ensure that all parties are given the opportunity to become involved in the revision of the document. We consider that clarification is required as to how the Scottish Ministers will determine the need for developments that are to be included within the NPF. We suggest that a consultation draft of the NPF should be prepared. A formal consultation period for the draft NPF should be introduced and there should also be statutory timeframes set for its review and update. It is noted that, despite its proposed increased importance, the NPF is not proposed to be subject to public inquiry or hearing. West Edinburgh Planning Framework identifies the geographical area of the west of Edinburgh as being unique and important in terms of its existing status and future potential as an internationally significant economic area. The main details of this nationally important document require to be incorporated in the NPF.
Professional Organisations
Association of Regional and Island Archaeologists:ARIA notes that it is intended that the National Planning Framework will be subject to SEA and wishes to point out that the most up to date archaeological knowledge and advice for any given area resides within the local SMR Service and it is therefore expected that SEA for the National Planning Framework will use the appropriate local knowledge base in arriving at conclusions re the impacts of the locations of national development on archaeological resources.
Chartered Institute of Logistics and Transport: The proposal for Strategic Environmental Assessments is welcomed recognising the process will be participative. Urgent attention should be given to ensuring that the techniques and consultation processes are developed in a way which obtains the confidence of all relevant parties, does not impose unnecessary delays and ensures that undue attention is not given to relatively minor or frivolous aspects.
Chartered Institute of Housing: Without doubt a successful planning framework will enable Scotland to develop a sustainable future, linking the policy priorities of the Executive. The National Planning Framework for Scotland identified that: an adequate supply of affordable housing is an important factor in promoting economic activity and social justice and in closing the opportunity gap. It is unfortunate therefore that this link has not been highlighted in the White Paper produced at this stage. CIH would also like to see a continued commitment by the Scottish Executive to help local authorities revise and improve Local Housing Strategies and for this support to enhance the knowledge and understanding of the new national planning framework
RIAS: The National Planning Framework has gone a long way to establishing a national framework for the future. Recognition of policies and controls established by the European Union guides the system in the UK towards joined up planning not just for Scotland but also for Europe. The RIAS is generally supportive of these initiatives. There are key policy areas where a national Plan can give context and guidance and the RIAS welcomes informed discussion and decision at this scale.
RTPI Scotland: With regard to the National Planning Framework, we support the use of the National Planning Framework as a vehicle for large infrastructure schemes of national importance, simply for the reason that the current system for providing a spatial planning rationale for highways, electricity and pipeline schemes which do not fall within the statutory planning system, is entirely unacceptable. However, the decisions in principle on such schemes cannot possibly be taken through the National Planning Framework without a degree of independent scrutiny which the parliament and the Executive's own consultation processes cannot possibly provide. Further consideration should therefore be given to how the public may have access to this process and the opportunity to take part in an appropriate level of scrutiny which is perceived to be fair. We would therefore recommend that the bill should provide for the appointment of three Commissioners by the parliament to preside during the full cycle of preparation of each National Planning Framework and to provide a report to the parliament to inform committee scrutiny and then parliamentary debate, on the National Planning Framework.
SSDP: The Society supports the development of the National Planning Framework but wishes to ensure that there is effective consultation with planning authorities in concluding the proposals. In developing the National Planning Framework it is felt that the Scottish Executive must develop closer and more meaningful partnerships within the Executive e.g. with trunk roads and with national agencies such as Scottish Water, Scottish Enterprise and the Health Trusts.
The Law Society of Scotland: There is concern about the effect on the current system of development plans of delay in publishing the second National Planning Framework until 2008 and the effect this will have on the preparation of the new generation of development plans. There is a danger of a hiatus, which may inhibit change, by continuing outdated plans. It would be helpful if the process could be commenced earlier, or clear guidance could be given in the interim as to what is likely to be included in the second National Planning Framework. It is important if there is to be confidence in the Framework that the procedures for preparation and adoption of the Framework should be open, participative and transparent. Given the investment of time and effort in community planning, the linkage between the different levels of the hierarchy and community planning should be made clearer in order to facilitate local infrastructure being well co-ordinated.
Planning Consultants, Architects and Lawyers
Bell & Scott: We support the concept of the National Planning Framework in its proposed enhanced form. Nevertheless we have some concern over the apparent lack of opportunity for challenge to the National Planning Framework.
Collar, Neil: The current National Planning Framework is not supported by specific statutory provisions. It is unclear from the White Paper whether the NPF will be specifically mentioned in the Planning Bill. Given the role envisaged for the NPF, it is important that there is a specific statutory provision indicating its legal status (a material consideration, or part of the development plan?), and specifying the procedures to be followed for its preparation and publication. It is also unclear from the White Paper the extent to which local development plans and strategic development plans will require as a matter of law to comply with the NPF. The White Paper also fails to make it clear whether mention of a national development in the NPF will be determinative of the need for that development, such that the need cannot be debated during the planning application process.
Drivers Jonas: Given the proposed enhanced role and status of the National Planning Framework ( NPF), it is considered that further details are required about the procedures that are to be used to ensure that all parties are given the opportunity to become involved in the revision of the document. We consider that clarification is required as to how the Scottish Ministers will determine the need for developments that are to be included within the NPF. We suggest that a consultation draft of the NPF should be prepared. A formal consultation period for the draft NPF should be introduced and there should also be statutory timeframes set for its review and update. It is noted that, despite its proposed increased importance, the NPF is not proposed to be subject to public inquiry or hearing. GVA Grimley LLP: Recommends extensive consultation on the key infrastructure questions and the ultimate format / scope of the NPF takes place as soon as possible, to enable the second NPF in 2008 to actually contain the bold, strategic decisions and power to implement decisions which Scotland needs answers for.
Hargest & Wallace Planning: The enhanced status of the NPF is supported as is the proposal to make it more precise. However it is not clear what status is proposed to be given. On the basis of the priority given to national developments identified in the NPF it is appropriate that the NPF should be given the same or higher status as the development plan - otherwise, at appeal, it will not be possible to ensure that developments in accord with the NPF are not over-ruled by out of date development plans. The NPF needs to be a lot more precise than is found currently. There should be a statutory requirement that development plans are in accord with the NPF.However the NPF will require to be clearer and more explicit with its proposals to ensure that there is no ambiguity re the conformity or otherwise of SPs and Local Plans. Development planning in Scotland is now moving into a period of uncertainty and limbo, which needs to be resolved as quickly as possible. There is a real danger that uncertainty will further delay the Development Plan process. Deadlines must be set for the adoption of the new plans.
Ledingham Chalmers: Establishing the national planning framework as a means of securing the delivery of national policies combined with the introduction of new procedures for determining applications for large scale developments is admirable. We sincerely hope this will lead to greater consistency in decision making, and ensure that there is greater use of joined-up thinking. The national planning framework will require to be more detailed than it is at present, if the document is to serve as a more useful tool in the determination of planning applications.
Scottish Planning Consultants Forum: We believe that the relationship between the National Planning Framework ( NPF) and the Local Development Plan ( LDP) needs to be carefully considered in order to establish the need, or otherwise, for an intermediary level of statutory plan -the Strategic Development Plan ( SDP) as proposed for the four city regions in the White Paper. We see potential for plans covering the City Regions which are informed both by strategic thinking and the LDP. However we are aware that statutory approval or adoption procedures and the need for conformity can make the achievement of synchronicity very difficult to achieve. We do not find in the White Paper any recognition of this difficulty -and, consequently, it is not addressed. A combination of strategic planning guidance through non-statutory frameworks and the NPF might offer some advantages in terms of interactivity but this could be at the expense of local democratic accountability. This is an issue of major importance and could have implications for the drafting of the Bill and its provisions for the preparation and examination of development plans.
Warren Consultants: We approve of the White Paper's proposals but seek more clarity on, e.g. how the NPF will be approved. Will this be a decision for Parliament or the Cabinet?
Academic Bodies and Individuals
Lloyd, Greg Professor: The White paper must trigger an informed and realistic debate about infrastructure. It is very clear that the objectives for the Scottish economy (as set out in the Partnership Agreement, and reflected in the Framework for Economic Development) demand logical thinking about public sector investment. Yet this remains disengaged from the land use planning system. Hopefully, the proposed role for the National Planning Framework and its political importance will allow for these matters to be brought together. The separation of land use planning and infrastructure decisions has led to an effective privatization of infrastructure provision through the negotiation of planning gain with a consequent lack of strategic thinking about long-term development patterns.
Macaulay Land Use Research Institute: The paper suggests that the new National Planning Framework, developed with public involvement, will be published in 2008. Allowing two years is not much time when the Executive themselves recognize: (a) the need for a cultural change (p. 30), and (b) the many conflicting interests involved in the national planning arena (p.30). Whilst acknowledging the need to coordinate with other policies, through statutory consultees and input to the NPF, it is not clear what mechanisms this new planning regime will use when, and if, there is a conflict between two policies. Do EU policies take precedence, and if so, where does this leave the process of public involvement in developing a NPF that is consequently overruled by supra-national policies?
Community Councils
Grange-Howard Community Council: It is noted that the NPF has been recognised as achieving good practice in spatial planning and that its role has to be enhanced by becoming a tool for securing delivery of national policies and programmes. It is charged with setting out the Executive's development priorities more clearly. It will support the role of our cities in the city/region model of economic affairs and development to which the geography of Scotland lends itself and the Executive seems committed. The Strategic Environmental Assessment to be carried out by NPF will involve it in extensive consultation throughout Scotland. It is hoped that the Framework will consult the Community Councils when their respective areas are being reviewed in terms of the SEA.
Greengairs Community Council and Greengairs Environmental Forum: Our main concern is that the NPF does not appear to afford accessible and effective public consultation and, we believe, is too removed from the public for them to be aware of how it could impact on their area until it is too late. Generally, it is our experience, that the public are not too concerned about planning issues until it directly affects them. It will therefore be crucial that various methods of communication are used to inform on the relevance of participation along with education/advice on how to effectively contribute. We are concerned that the NPF could be used to decide the location for bad neighbour developments such as waste management facilities, in a manner that would devalue the impact on communities and encourage a "sacrificial zone" ideology that would be completely contrary to social and environmental justice principles. The bigger the picture the less attention there may be to the local detail. There is concern that even if a development is included in the NPF there must be flexibility to ensure that when the development becomes relevant and the detail is subjected to scrutiny that Ministers are prepared to accept that the development may not be appropriate for that location. Just because it is included in the NPF does not mean that ten or fifteen years on, as may be the case for certain developments, that it is set in stone - if it doesn't stand the test - then we need to be assured that it will be abandoned and an alternative consulted on. Of course, there are also the grave fears that the NPF could be used to minimise public participation in relation to the need and location of Nuclear Power Stations and Incinerators. There needs to be more clarity on precisely what developments will be covered by the NPF. We are not convinced that the system will be inclusive enough to ensure a level of public participation in the National Planning Framework that is effective and promotes confidence in the system.
Knightswood North Templar Community Council: The current proposals to strengthen the role and status of the NPF can therefore only be welcomed by those with an interest in sustainable development and the development of Scotland, particularly since there appears to be no provision for the structural and strategic planning of the Highlands and Islands. The proposed bill rightly recognises that the next NPF needs to place a greater emphasis on implementation than its predecessor. In this context the linking of the NPF to the Infrastructure Investment Plan and the investment programmes of public agencies and infrastructure providers is a welcome step, as is the requirement for the NPF to undergo a strategic environmental assessment. Given the Governments commitment to Sustainable development there is no reason why the state should not be used to identify and fund opportunities for wind-farm development, tidal energy development and for a new round of Hydro projects.
Mid Atholl, Strathtay & Grandtully Community Council: The idea of the NDF does not appear to have been welcomed by representatives of local communities, or at least they are not mentioned. If the second NPF emphasizes implementation, and developments identified by LAs are called in to be decided by those remote from, and untouched by, its local impact, how is local involvement assured? Even if local communities are consulted about the NDF itself where is the consultation about specific developments in the 'national' category?
The Royal Burgh of Cupar & District Community Council: National infrastructure projects should speed up under the new system and democratic input to the principle of a project would be in Parliament when the National Planning Framework (Version 2) is settled.
The Royal Burgh of St Andrews Community Council: Suffering currently from the malign effects of NPF 2004 into which we had no input (unlike other, selected, community councils we understand). In its setting of the agenda for a Structure and Local plan we find unsympathetic. We are concerned at the lack of public consultation or public review for the NPF being mentioned in the white paper. Leaving this to ministerial or departmental diktat, as the white paper appears to do, does not meet the objective of delivering "a system where everyone's views are listened to and taken proper account of". It is centralisation; where is the participation ("everyone's views are listened to") when the NPF is set entirely centrally? How will "these proposals restore confidence in the planning system" when the rules are set in a realm far more easily influenced by professional lobbies, than it can be by ordinary people in local communities who have neither the money, the organisation, the access, nor the time to lobby ministers? The Community Council propose that regular reviews of the NPF should be subject of wide and open consultation; and that even then the NPF be guidelines subject to review and questioning of assumptions ( e.g. in planning enquiries), rather than as overriding strategic policy, as it is currently presented.
Voluntary Organisations
Brethren Gospel Trusts: We support the clear definition of the enhanced status for national planning policy documents in order to remove any doubt by both local planning authorities and/or members of the public.
Colinton Amenity Association: The next National Planning Framework [ NPF] already appears to have an overwhelming commitment to growth. The statement that 'It will also address the Executive's commitments on environmental policy and sustainability…' is weak and does not bode well for the achievement of balance in the NPF. We believe it is important to set out how balance is to be achieved in the NPF. There is much stress on expediting decisions in the national interest. There is a lack of emphasis upon obtaining the right decisions and being seen to achieve the right decisions. On the latter point, if the Scottish Executive is to be the decision maker for national developments as well as the formulator [particularly for NPF], this is tantamount to being judge and jury! Debate in Parliament will not overcome this either, as the Executive is drawn from the political party[s] in power. This is not acceptable in a democracy and there must be a mechanism for independent scrutiny of proposals for their feasibility and acceptability, before decisions are made. Appeal via the Courts, which focus on administrative aspects and not planning issues, will not achieve this.
Edinburgh World Heritage: We welcome a National Planning Framework as a strategic tool, with the opportunities for greater inter departmental co-operation across Government. At present World Heritage Sites are not a designation under the Scottish (or English) planning system -although it is a material consideration in determining planning applications. The National Planning Framework should recognise the very special status that this international accolade gives to the 4 World Heritage Sites in Scotland -The Heart of Neolithic Orkney, New Lanark, St Kilda and the Old and New Towns of Edinburgh, and thus ensure that there is a broad commitment to their care, protection, presentation and that the sites are transferred to future generations through a sustainable approach to development and change.
Energy Saving Trust: We welcome the proposals for a strong National Framework. It is essential that this framework effectively engages with key national priorities, in particular the need to tackle climate change. Local planning policies and decisions are unlikely to take full account of the wider or global environmental impact of development activity without this central lead. In our experience, many local authorities are reluctant to pursue more pro-active policies to support development integrating sustainable energy where they fear this may result in losing development to other authorities. To supplement such a strong framework, we would therefore like to see clear, relevant guidance on sustainable energy issues to create a level playing field for local planning authorities. As such, we welcome the revision to Planning Advice Note 45 on Renewable Energy Technologies, and the proposed review of NPPG 6 on Renewable Energy Developments. We would like to see a pro-active approach adopted in guidance which encourages local planning policies to require low-carbon developments.
Friends of the Earth Scotland: Fo ES supports the idea of an up-to-date and influential National Planning Framework ( NPF). However, these proposals for the development and implementation of an NPF are unparticipatory. There appears to be no provision for formal public consultation or examination by planning inquiry and the White Paper does not make clear what role the Parliament will have in scrutinising or vetoing the detailed contents of the NPF. Projects deemed by Ministers to be of 'national significance', such as major transport infrastructure, will be treated in a streamlined way. The NPF will be renewed and made more directive, but without any formal public consultation or examination by planning inquiry, although it will be subject to strategic environmental assessment ( SEA). Priorities will be dictated by Ministers and possibly not subject to Parliamentary approval. It has been suggested that NPF priorities will be mandated into local plans with limits on the scope for any challenge on grounds of need (inquiries will only be able to consider issues such as location and mitigation of environmental impacts). No other form of strategic planning will be retained outside the city-regions. This centralisation of power in the planning system will reduce both participation and accountability. It provides greater access and opportunities to wealthy and powerful lobbyists than to concerned citizens, and risks putting political horse trading before rational planning. Fo ES believes that regular updates of the NPF should be made statutory and should be subjected to both SEA and formal wide public consultation. There should be no constraints placed upon public inquiries into NPF priorities even if Parliament takes a formal role in scrutinising and approving the NPF.
Glasgow Council for the Voluntary Sector: The proposals for an enhanced role for the National Planning Framework ( NPF) are welcome but the proposals for scrutiny and challenge are not. The NPF should be subject to an 'Examination in Public' chaired by an independent professional who can hear and consider evidence and make recommendations. This has been done for other spatial strategies in the UK, for example, the Spatial Development Strategy for London and the Regional Development Strategy for Northern Ireland and need be neither costly nor lengthy.
Greenhill and Church Hill Amenity Association: The National Planning Frarnework2 should, as its first objective, review, compile and advertise all present incentives to business to establish/expand activities in areas where they will be wholly beneficial, in the wider sense of contributing optimally to the local community. New incentives to existing businesses to re-locate to areas of less congestion and lower cost (wages, rentals, construction, infrastructure etc.) should be considered.
Helensburgh Study Group: It is not yet clear to us how precise or relevant the new NPF will be or the extent to which it will provide a substitute Structure Plan for rural authorities. It is difficult to make comment on an unknown quantity. Yet there are indications that major issues such as health, education, affordable housing, transport, water and drainage, energy, urban regeneration, urban expansion, and business investments could be affected by the new NPF. Dearth of public involvement about the new NPF is worrying. There are references to the NPF being debated in parliament while "those with an interest" (including the public?) may "express views", but it looks like simple centralisation with minimal involvement. We would only be able to judge at consultation stage.
However, if the next NPF can reduce the adversarial nature of the planning system and give greater balance and fairness than the White Paper provides, then it could be valuable.
Highland Perthshire Communities Partnership: The proposed removal of so called nationally important developments from the public inquiry process represents a serious centralization of decision making with potential objectors being excluded where large scale developments may have irreversible impact on rural residents and landscapes. The proposed replacement provisions through the national planning framework are inadequate to replace the inquiry process, which identifies the need for each such development.
Planning Aid Scotland: The NPF will make important decisions in the national interest and will predetermine the opportunities for community influence on issues in strategic and local development plans. We welcome the proposed draft NPF stage but question the adequacy of scrutiny and examination arrangements. It will be essential that the preparation process makes adequate provision for community consultation and the local implications are clearly understood and debated. We would support an examination of the NPF by an independent reporter who could report the findings to Parliament.
Portobello Campaign Against the Superstore: It is indicative of the failure of the Executive to engage communities in the planning process that the National Planning Framework, published in 2004, is an unknown document. Far more work needs to be done to interest communities at the esoteric stage of planning framework consultation. This includes full explanation of the ramifications of accepting a proposal in the framework.
Ramblers' Association: Supports the establishment of a National Planning Framework as a sensible means of deciding on projects of national significance, but we have strong reservations in the way that this policy mechanism is presented in the consultation document. In particular we are concerned that there are no measures proposed on how developments of national importance, decided by Ministers, will be subject to detailed scrutiny and be able to be challenged publicly, bar the bland statement that there will be the full involvement of parliament. To be inclusive as intended, national projects must be allowed to be scrutinised and tested through public inquiry. The forthcoming Planning Bill needs to be explicit on the criteria by which this process will be publicly accountable.
RSPB: While we welcome many of the proposals relating to the National Planning Framework ( NPF), we are concerned that there will be no opportunity to challenge or test this document. This has not been the case for equivalent documents developed elsewhere in the UK. If the NPF is to establish the principle for a number of nationally important developments, it is critical that the principle be tested in an open and accessible forum. Essentially the NPF will establish outline planning permission for particular developments leaving local communities with opportunities to wrangle over the colour or the specific footprint. This would appear to be a significant reduction in the current rights enjoyed by individuals and communities across Scotland. We also understand that the document will be subject to some level of parliamentary scrutiny, as yet to be determined. We remain interested in what this process might be but sceptical that the parliament will have the time or opportunity to subject the NPF to the type of scrutiny it would benefit from should there be an examination in public chaired by a planning professional. We also appreciate that the document will be subject to SEA, this too is welcome, yet fundamentally neither of these proposals allow those most likely to be affected by a proposal to lodge an objection or challenge the principle. The Spatial Development Strategy for London and the Regional Development Strategy for Northern Ireland were both subject to an examination in public.
Rural Scotland: Rural Scotland is gravely concerned about the proposal to process and scrutinise developments of national, strategic importance within the context of the National Planning Framework, because it appears to take decision making further away rather than closer to the public. This would be particularly true of proposals stemming from UK policy relating to energy and other reserved matters. To address this we propose the establishment of an independent planning commission to review the establishment and provisions of a national planning framework.
Scottish Badgers: The National Planning Framework will identify developments of national strategic importance and it seems the white paper proposes limited opportunities to object or to challenge such proposals. This is not acceptable and is contrary to criteria 3 above of improving inclusion allowing planners and the public to have a real say in the National Planning Framework that must surely be held up for close scrutiny by those who are going to be most affected by it. In a new system, which proposes to be open and transparent, making national decisions without reference to the public will not fulfill the designed purpose and will therefore not be "fit for purpose".
Scottish Civic Trust (and Civic Trust Network): We are concerned that there is no statutory period for preparation and no statutory public consultation process. It is ironic that the White Paper proposes "front-loading" public consultation into the development plans, but then does not propose the same for the NPF. Some method of public scrutiny is required. We do not support, based on the evidence in the White Paper, the use of the NPF to bring forward specific development proposals. This would result in a reduction of public scrutiny and seems contrary to the thrust of "front loading" public involvement in the planning process.
Scottish Consumer Council: The SCC believes that the next NPF should be subject to an independent public inquiry. It is vital that consumers are adequately assured that the NPF is given appropriate impartial scrutiny before it is adopted.
Scottish Renewables Forum: The renewable industry is of the firm view that spatial planning for renewables will not assist in delivery of development to meet targets, or in delivery of better schemes. Experience to date demonstrates clearly that a case by case approach, informed by national planning policies, and through impartial expert advice and involvement of statutory consultees, is the best way to ensure workable sensible renewable schemes result.
Scottish Wildlife Trust:SWT supports the development of a coherent and integrated vision for Scotland's spatial development. This must however be radically different from the existing National Planning Framework which is little more than compendium amalgamating and illustrating current development proposals and policies. The next NPF should instead provide the focus for debating and deciding on the fundamental issues concerning Scotland's development adding a spatial dimension to policies which move future patterns of growth onto a sustainable footing. In line with the level of importance accorded to such a framework it is vitally important that communities throughout Scotland are able to challenge proposals and see them scrutinised through an examination in public. The National Planning Framework must therefore be subject to an examination in public so decisions on its finalisation by Ministers or Parliament are made on the basis of sound evidence which has been subject to expert and independent scrutiny
The Grange Association: There appears to be little or no public participation on the preparation of the National Planning Framework. Indeed many people will be unaware of it or particularly interested in contributing their views to the discussions before it is set up; but they will become concerned when developments are to take place within their area or where developments would affect their way of life. It is accepted that certain developments of national importance must occur but it is not always the case that they are clearly set out at an early date and so the eventual effect of these developments will not be apparent to those who will be affected by them. We believe there should be a way for people to express their concerns at a later stage after the NPFs are decided. More publicity about the NPF and a review by an independent body would help to overcome this. Will NPFs include an assessment of maximum sustainable population within specific areas so that quality of life is maintained?
The National Trust for Scotland: The recent introduction of the National Planning Framework ( NPF) has been a significant step forward, as it offers welcome new opportunities to address strategic national issues such as energy, waste, transport and water. The proposal that national developments of strategic importance should be proposed and debated in the context of the NPF is a logical extension of this approach. However, public support for this proposed increased status for the NPF will only be assured by the introduction of some mechanism by which it can be publicly challenged, as can the other levels of forward planning which sit beneath it. The White Paper states that the NPF will be subject to extensive consultation, including strategic environmental assessment, and that Parliament will have the opportunity to contribute to its development. However, there appears to be no formal mechanism to object to it or to challenge the decisions it contains. The parliamentary process for its approval has yet to be decided, but the options are limited; these are unlikely to include the close scrutiny and robust testing of specific proposals, given that MSPs have neither the time nor the technical knowledge to do so.
The strategic and local development plans for which the NPF will set the context are rightly subject to either public inquiry or examination in public. The purpose of such inquiries is to ensure that the policies and proposals being put forward are robust and necessary. If the NPF is not subject to similar public challenge, it may in future be possible for damaging large-scale developments to be pursued without adequate professional scrutiny or detailed examination. The NPF should therefore be subject to an examination in public, chaired by an independent reporter who can consider evidence and make recommendations. This is the case for other spatial strategies elsewhere in the UK, for example the Regional Development Strategy for Northern Ireland.
Private Individuals
Anonymous: The detachment of the National Planning Framework from the appeals procedure is quite undemocratic in that community involvement (trumpeted throughout the document) is completely excluded from the largest projects i.e. those that might impact most on communities.
Anonymous: We are particularly pleased that Public Health will at last receive the pre-eminent place it should have in all Planning decisions. We enclose copies of several recent scientific papers which emphasise the impact on Preventive Medicine which major Planning decisions can have. The first details increased risks of Low Birth Weight and congenital anomalies adjacent to landfill sites ( BMJ, 18 Aug 2001); the second the increased risks of a particular form of leukaemia in children whose home addresses at birth were within specified distances of high-voltage power lines ( BMJ, 4 June 2005). We hope they will be helpful in the preparation of the second National Planning Framework.
Baylis, Wendy: We are also concerned at the removal of nationally important developments from the Public Inquiry Process. Such large-scale developments may have irreversible impacts on rural residents and landscapes. The proposed replacement provisions are frankly inadequate. The vast quarry on Lewis would no doubt have gone ahead under these proposed revisions.
Greenlaw, Mrs Floris H.: a great deal more publicity and consultation is needed in drawing up/reviewing the National Planning Framework than was evident prior to the adoption of the first one, and utilities must be required to commit themselves to relevant infrastructure investment.
Hopkinson, Sue: I fully subscribe to the need outlined for overall planning for Scotland as in the reference to planning for"the essential infrastructure we need" and "to foster the right development in the right places"
Mackenzie, Mary E: A National Planning Framework is essential to prevent urban sprawl and to protect the amenity of towns and villages. It is also necessary to ensure that the necessary transport infrastructure is put in place.
Russell, TJ and TS: We are concerned that proposals for national developments would not be subject to the public enquiry system. We feel that this would be unfair to the general public and especially to those who have a particular interest in a proposed development. Many large scale renewable energy developments are proposed for the future and if there is not an improved protection of landscape much irreversible damage may occur.
Turner, Barry: This needs to be subject to statutory consultation/scrutiny if it is to be such a fundamental part of the package of plans and if it is to enjoy public ownership. Regional Spatial Strategies in England, which amount to much the same thing, are subject to rigorous examination. Public scrutiny is especially important in the absence of structure plans outside the city regions since the National Planning Framework will provide the context for Unitary Plans. It is also important because the framework will set out the so called 'national developments' which will now be decided by Ministers.
Urquhart, Graham: I share the views expressed by many organisations that are concerned about the lack of participation and accountability in the proposals for the National Planning Framework. ( e.g., RSPB, National Trust, Foe, Scottish Environmental Link).
Politicians and Political Groups
Scottish National Party: In designing the National Planning Framework there must be clarity on the level and import of public participation and that this should be clearly indicated to the Communities Committee prior to Stage 1. We would refer the SE to the processes developed in Spatial Development Strategy for London and Northern Ireland.
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