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Non Technical Summary

Introduction

As part of the preparation of the revised SPP3: Planning for Housing, the Scottish Government is carrying out a Strategic Environmental Assessment ( SEA). SEA is a systematic method for considering the likely environmental effects of certain plans, programmes or strategies produced by public sector organisations. It aims to:

• Integrate environmental factors into policy and decision making;
• Improve policies, and enhance environmental protection;
• Increase public participation in decision making; and
• Facilitate openness and transparency of decision making.

SEA is required by the Environmental Assessment (Scotland) Act 2005. The key stages of the revised SPP3 SEA to date have been as follows:

• Screening. A Screening Report was prepared and submitted to the Consultation Authorities (Scottish Natural Heritage, Scottish Environment Protection Agency, and Historic Scotland) in September 2007.
• Scoping. A Scoping Report was prepared and submitted to the Consultation Authorities in September 2007. This set out the intended scope and level of detail to be included in the Environmental Report, and the proposed consultation periods.
• Environmental Report. This NTS reflects the content of the Environmental Report, which sets out the findings of the assessment of the consultation draft revised SPP3. It aims to inspire as wide a consultation response as possible, by providing a clear statement of the predicted environmental effects of the SPP. The assessment is necessarily broad brushed - reflecting the high level of the policy itself. Recommendations for more detailed SEAs of strategic and local development plans are provided.

Consultation on the Draft Environmental Report and Consultation Draft Revised SPP3

The Environmental Report is currently available for the public to view and comment on. The 12 week consultation period will run until 31 March 2008. Responses by email should be directed to spp3@scotland.gsi.gov.ukor can be sent in writing to : SPP3 Consultation, Planning Directorate, The Scottish Government, 2H, Victoria Quay, Edinburgh, EH6 6QQ

When the consultation period has closed, all comments and responses will be reviewed and taken into account in the preparation of the final revised SPP3. This is expected to be published around May 2008. At that time a Post Adoption SEA Statement will be published which sets out the way in which consultation comments have been taken into account, and provides commitments to future monitoring of predicted environmental effects.

Purpose of the Environmental Report

The Draft Environmental Report provides information on the consultation draft revised SPP3. It identifies, describes and evaluates its likely significant environmental effects, and compares this with the options that were considered during the policy preparation process. The aim of the Draft Environmental Report is to provide an early and effective opportunity for the Consultation Authorities and the public to offer views on any aspect of its content.

Outline of the contents and main objectives of the consultative draft revised SPP3

SPP3 sets out The Scottish Government's policy on the identification of housing requirements, the provision of land for housing and the delivery of housing through the planning system. The overarching aim is to refocus the role of planning in the delivery of housing, from debates around the calculations of housing requirements and land availability, to building a better, more diverse range of houses to serve the economic, social and environmental aspirations of Scotland.

The key objectives of the revised SPP are to provide policy guidance on:

• identification of housing need and demand on a more aspirational, but consistent and robust basis;
• allocation of sufficient and appropriate land to meet identified need and demand for housing, including affordable housing, across all tenures, and mechanisms to ensure those houses are built;
• creation of high quality residential environments; and
• interface between planning control and licensing of Houses in Multiple Occupation.

SPP3 is part of a framework of planning policy and guidance - setting the policy context for development plans. Each development plan is subject to its own strategic environmental assessment. As a result, a key purpose of the SEA of SPP3 is to provide a framework of environmental issues, within which SEAs of development plans should be set.

Current state of the environment likely to be affected by SPP3, and existing environmental problems.

SPP3 applies across Scotland, in both urban and rural contexts. Scotland has a unique and high quality environment, with a plethora of protected areas and features, ranging from those which are protected at the international level (Special Protection Areas, Special Areas of Conservation and Ramsar Sites), to those which are nationally recognised ( SSSIs) and those locally protected. Biodiversity value is not confined to rural areas - well designed housing developments can contribute positively to urban and peri-urban green networks.

Scotland's demographic and household composition supports the need for higher levels of housing to meet demand. Poor health and social exclusion tends to be geographically concentrated in urban areas. Housing market data supports delivery of more affordable housing, and to ensure housing supply meets the varying needs in different parts of the country.

Scotland has generally good quality water resources, which nevertheless require ongoing protection from the adverse effects of incompatible land use and development. Up to one third of Scotland's waterbodies may not reach water quality targets by 2015, unless action is taken to address pressures on them. Flooding is a continuing challenge that requires a long term perspective to avoid exacerbating existing problems and anticipate the additional effects of climate change.

Scotland has good quality soil resources, but they can be adversely affected by both natural and human activities. Soil sealing and erosion are of particular concern. Air quality is also generally good, but protective measures seek to avoid exacerbating problems in areas where pollution is already high. Energy is increasingly being generated from renewable sources, but there is a need for further work to reduce the carbon footprint of our housing stock and domestic energy consumption. Vacant and derelict land remains a challenge, although this has declined significantly in recent years as a result of ongoing remediation and redevelopment.

The effects of climate change are already becoming apparent. Longer term predictions include substantial increases in levels of rainfall, reduced snowfall, and temperatures, and increased risk of storms and high winds. These effects will vary between different parts of the country and seasons. International commitments to reducing emissions, which contribute to climate change and the need to adapt to its effects, provide a challenging policy framework for all national level planning policies.

Scotland's identity and history is reflected in its many listed buildings, conservation areas and scheduled monuments. There are many more remains, buildings and townscapes which have not been formally designated for protection, but which together make our landscapes and settlements attractive and distinctive. Scotland's mountains, moorlands and coasts are particularly renowned and distinctive at a national scale. Many of our most accessible landscapes are subject to ongoing pressure for change.

The following environmental problems formed a focus for the assessment:

• Decline in overall area of semi-natural habitats in Scotland. This is compounded by climate change, urbanisation and other developments leading to habitat loss and fragmentation
• Growing numbers of households and changing household structures provide a challenge for meeting housing market needs.
• Key headline health problems including high rates of coronary heart disease and spatial concentrations of health problems in areas with high risk of deprivation.
• Soil erosion is an ongoing concern. In addition, soil sealing interferes with the ability of the land to process water, resulting in increased flooding and depletion of groundwater flows.
• Potential future pressure on lochs, rivers and groundwater due to continuing growth in demand for water. Flooding is a longstanding problem in parts of Scotland, which has had varying effects on different housing tenures and households according to their incomes.
• Energy consumption from the residential sector has continued to rise despite efficiency driven initiatives. In order for Scotland to realise its targets in relation to renewable energy generation, a further shift in methods of generation will be required to generate a larger share from renewable sources.
• Climate change is already established and predicted to continue and potentially accelerate. The residential sector could be affected by this in a number of ways, suggesting a need for adaptation. The contribution of the sector to climate change mitigation could be increased. Linking with this fuel poverty is a national problem that is estimated to have grown substantially in recent years.
• Scotland has numerous air quality management areas reflecting concentrations of poor air quality. Many of these have been designated in recent years.
• There remains a need to reclaim and positively reuse or redevelop contaminated or derelict land.
• Inappropriate development and wider urban and rural decline pose ongoing threats to designated, undesignated and unknown historic environment resources.
• Landscape change, standardisation and loss of distinctiveness. There is pressure on greenspace in and around settlements, as well as rural landscape change. The baseline analysis noted the declining quality of settlements and their surrounding landscapes as a result of demand for housing and residential development standards and trends. Cumulative impacts from housing development on designated and non-designated landscapes are therefore a continuing concern.

If SPP3 was not revised, many of these existing environmental trends may continue. This includes continuing growth in greenhouse gas emissions, and threats to biodiversity. Whilst there might continue to be positive progress towards achieving some environmental targets, such as air and water quality, the contribution of planning to these environmental objectives may prove to be limited without positive planning to steer housing developments towards appropriate locations and achieve higher quality standards. At the same time, however, the Environmental Report identifies a number of potential effects which will arise as a result of the proposed revised policy. This includes an overall increase in housing delivered through the planning system, which will have implications for some of the above environmental problems. These issues are explored in more detail below.

Wider environmental protection objectives

The assessment reviewed a broad range of environmental policies and objectives, to identify the context within which SPP3 is set. This showed that there are clear policy commitments to the protection and enhancement of biodiversity, cultural heritage, landscapes, air, soil and water quality. Social and health policy agendas aim to promote social inclusion and reduce inequalities. Climate change is also a key policy sector - with objectives seeking to achieve mitigation by reducing harmful emissions, and also promoting adaptation in response to its impacts. Further policies on sustainable waste management, renewable energy, energy efficiency and transport are also relevant to the development and delivery of SPP3. The objectives were used to inform the development of SEA objectives and criteria, against which the draft SPP3 was reviewed. In addition, the development of the SPP itself has aimed to bring together wider sectoral policies to provide an integrated framework for housing planning and development.

Likely significant effects of the consultative draft of SPP3 on the environment

Overall, the draft revised SPP aims to increase the amount of housing that is delivered through the planning system. Whilst this might appear to increase the risk of adverse environment effects, the actual level of development and in particular additional land-take for housing may not necessarily be significant, as a result of an emphasis on more efficient planning processes and sustainable development patterns. Taking this into account, the following effects are anticipated as a result of the consultative draft SPP3:

• There may be adverse effects on biodiversity, flora and fauna as a result of higher levels of housing development overall. These effects may be significant in some locations, although the actual impacts will only become clear when the policy is taken forward within strategic and local development plans. Some aspects of the draft revised SPP should also deliver benefits for biodiversity - including an emphasis on quality developments that build in measures such as sensitive landscaping, SUDS and networks of open space. The SPP promotes this explicitly and implicitly, by comprehensive cross referencing to wider policy, particularly the suite of SPPs which is already in place. Overall, it is expected that a long term and plan-led approach to housing provision should provide benefits for biodiversity.
• The SPP provides general support for population and human health, as a result of its emphasis on providing an improved supply of land to accommodate higher quality housing, more energy efficient housing stock, and better access to affordable housing, local facilities and networks of open space. However, effective mitigation is required from development plans to avoid possible temporary adverse effects on quality of life and health from new housing construction.
• The SPP generally complements SEA criteria that aim to deliver more sustainable patterns of development, in response to the climate change mitigation and adaptation policy agendas. The influence of climate change on long term capacity to accommodate housing development should be considered further within development plans. This will be particularly important for large scale settlement expansion, and if proposals to establish a new settlement are taken forward.
• The water environment may be adversely affected by the overall increase in housing that should be delivered as a result of the SPP. Development plans will have an important role to play in ensuring that new development avoids contributing further to existing water quality issues, through appropriate locational and design policy. The SPP refers to broader policies, including SPP7, that seek to achieve this. Strategic new housing development areas may need to be complemented by enhanced infrastructure capacity, and the SPP acknowledges that this should partly be achieved through environmentally sensitive solutions such as SUDS.
• Soil may also be adversely affected by an overall increase housing development. The draft SPP aims to minimise these effects by continuing to prioritise brownfield land for development, and supporting more flexible, mixed developments in and around existing settlements. The proposals for HMOs could help to deliver higher density housing within urban areas which reduces wider pressure for the expansion of settlements.
• Air quality issues are not expected to be significant at the national level, as the SPP reflects a need to link development areas with accessibility by public transport and to increase energy efficiency and the use of microrenewables. Within development plans there will be a need to ensure that locational decisions to not exacerbate existing air quality problems - for example as a result of increased congestion arising from strategic housing land allocations close to existing concentrations of pollution.
• Cultural heritage resources may be better protected by some parts of the draft SPP, and in particular its plan-led approach. The emphasis on quality design should better complement the historic environment. However, the overall aspiration for a substantial increase in housing land could nevertheless result in a higher risk to historic buildings and sites, and impact on their settings. Mixed effects are therefore predicted.
• The draft SPP is expected to provide similar benefits for landscape, as a result of its commitment to high quality design, and further cross-references to wider advice on landscaping should also be beneficial. However, as with the other environmental resources, further pressure on some landscapes is also expected as a result of the proposed overall increase in housing development. There may be scope to build in additional guidance on landscaping of new developments, to strengthen this aspect of the policy.

No further alternatives have been assessed in detail within the SEA. The consultative draft has been arrived at in light of extensive comment and input from a group of key stakeholders, and was informed as far as possible by the SEA itself as it progressed.

Mitigation Measures

The Environmental Report sets out mitigation measures, which should be taken forward to maximise the positive environmental contribution of the SPP, and minimise its potentially adverse effects. Most of these relate to strategic and local development plans, as they will provide the spatial interpretation of the higher level policies provided in the draft revised SPP3. These range from undertaking integrated environmental capacity assessments to delivering more site specific measures. The procedural approaches set out in the SPP should help to achieve this. The SPP also supports delivery of mitigation by clearly and comprehensively cross referencing broader planning policy on a wide range of environmental topic areas.

Some recommendations for the ongoing revision of SPP3 itself have also been identified at this point in the process, and will be considered further alongside the findings from the consultation process. These include making more explicit references to landscaping and water quality and ensuring that the SPP reflects broader policy on climate change as it continues to evolve.

Monitoring proposals

SPPs are reviewed on a periodic basis to ensure that they remain relevant and reflect their broader policy context. It is proposed that the potential environmental effects of SPP3 will be built into this future review work, to ensure any unexpected or significant effects are addressed within subsequent policy revisions.

Next Steps

The table below lists future milestones in the development of SPP3 and its SEA, and the dates when these are expected to be completed.

Anticipated plan-making and SEA milestones

Questions for Consultees

In order to help structure their responses to the consultation on this Environmental Report, consultees are invited to consider the following questions:

• Do you disagree with any of the assessment findings, including the following key issues:
• do you agree with the assessment of environmental effects of SPP3, particularly given that it reflects the broader proposed aspirational goal of moving towards building 35,000 houses per annum by the middle of the next decade? Do you have any alternative suggestions?

• do proposals for a plan-led approach and suggested mitigation measures go far enough towards managing identified effects?
• do you agree that the approach within SPP3 to cross referencing broader environmental planning policies, as opposed to explicitly restating them, provides sufficient environmental protection? Are there any particular problems or opportunities that should be more explicitly addressed?

• Should any further baseline evidence, wider environmental policies or sources of information be taken into account?
• Do you have concerns about significant or cumulative environmental effects on particular areas or environmental resources?
• Are there opportunities to limit the adverse effects of the SPP that have not so far been noted in the proposals for mitigation?
• Can the SPP deliver any further positive aims and aspirations for the environment in the long term?

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