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CONTEXT
Outline and objectives of SPP3
Schedule 3 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes " an outline of the contents and main objectives of the plan or programme". The purpose of this section is to explain the nature, content, objectives and timescale of the PPS.
The review of SPP3 will replace the current SPP3 (2003) and was not expected to result in fundamental changes to the principles of the existing policy on planning for housing, which seeks to encourage provision and maintenance of an adequate supply of land for housebuilding to meet identified requirements. The reasons for the review were linked primarily to three circumstances:
- the modernisation and reform of the land use planning system in Scotland
- related necessary changes in the relationship between land use planning and housing policy; and
- a recent review of the housing market in Scotland and particular issues of supply arising in pressured areas.
The Consultative Draft SPP3 has a different format to the existing document. It has evolved into a statement of policy on planning for housing, accompanied by a suite of related annexes covering guidance on strategic assessments of housing need and demand, housing land audits (to replace PAN 38: Housing Land), guidance on the interface between the planning system and Houses in Multiple Occupation (to replace Circular 4/2004), and in addition a policy framework is included to demonstrate the important interlinkages between planning for housing and a wide variety of other relevant policy and guidance which must be considered in developing policies and proposals for housing.
The revised SPP3 continues to provide policy direction on the sustainable provision of well-located, high-quality new housing through the planning system. The SPP directs the achievement of the timely provision and maintenance of a sufficient supply of developable land across Scotland to meet identified housing requirements and to ensure that housing is built. It refers to the need for co-ordination of provision of infrastructure and services to support new housing development and acknowledge the need for a variety of responses to meet differing housing demands. The revised SPP3 also continues to emphasise the creation of quality, sustainable residential environments which contribute to a better quality of living, providing healthy and attractive places to live to meet a variety of needs and aspirations, across all tenures and in a variety of locations. The policy specifically encourages closer working between the housing and planning functions of local authorities, other local authority departments and housing providers in the achievement of these aims.
SPP3 is a planning policy document and as such it focuses on the land-use planning requirements for, and implications of, increased levels of new house building. The policy provides direction to local authorities in relation to the exercise of their statutory responsibility to produce development plans, which should identify land to meet housebuilding requirements and include a framework to guide housing developments. The challenge faced in reaching decisions which reflect an appropriate balance between environmental, social and economic considerations is primarily for the local authority to address taking account of local circumstances. The environmental, social and/or economic implications of alternative strategies for housing development, including the scale and location of land allocations, would be fully considered at the local level in the context of the Strategic Environmental Assessment carried out in relation to development plans.
At a national level, the full range of Government and international policies set the wider context for all policy streams including planning for housing. For example, policies for the protection of the environment, including species and habitats, assessment of flood risk and promotion of economic growth all require to be considered alongside each other in light of The Scottish Government's overarching policies.
Relationship with other PPS and environmental protection objectives
Schedule 3 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes an outline of the PPS relationships with other relevant PPS, and how environmental protection objectives have been taken into account in the PPS preparation. This section covers these issues and describes the policy context within which the PPS operates, and the constraints and targets that this context imposes on the PPS.
Table 3 summarises how SPP3 affects, and is affected by, other relevant PPS and environmental objectives. Appendix A shows a more detailed analysis.
Table 3 Relevant plans, programmes and strategies ( PPS) and environmental protective objectives, and their relationship with SPP3
Summary of environmental objectives | Summary of implications for SPP3 |
Biodiversity, flora and fauna related conservation and enhancement objectives are set out at the international level in key EU Directives, and primarily in the Nature Conservation (Scotland) Act 2004 and the Scottish Biodiversity Strategy at the national level. All public authorities in Scotland consequently have a duty to protect biodiversity. Less formal strategies also strongly emphasise opportunities for broad scale and site-specific biodiversity enhancement. | The revised SPP3 could go some way towards contributing to the wider agenda for biodiversity, particularly by guiding development plan policies away from the most ecologically sensitive areas. There may also be opportunities for biodiversity enhancement arising from sustainable approaches to site selection, planning and the detailed design of developments. These opportunities could be explored further by the SEA. |
The social and health policy agendas emphasise The Scottish Government's commitments to health and social inclusion and reducing inequalities. Key policies relate to area regeneration, provision of affordable housing, reducing fuel poverty and improving health. The existing SPP3 responds to this agenda in part, including by seeking to deliver sufficient land for new housing development, in the right places. | Experience since the policies of SPP3 were initially implemented suggests that there is a need to review the Scottish planning policy on housing to encourage planning authorities to implement national policy which aims to secure sufficient land for housing. Ongoing commitments to other policy priorities, particularly those relating to social equity remain relevant to planning for housing. |
Soil policies include a European Strategy for Soil protection that aims to address natural and man-made pressures on soil quality including wind and water erosion and loss of organic content. In Scotland, planning related soil policy currently focuses on scope for derelict/contaminated land reclamation, remediation and redevelopment. A Scottish Soil Strategy is currently in development. | The revised SPP3 will seek to ensure that housing land allocations avoid adverse effects on soil resources as far as possible. Emphasis on strategies that aim to release brownfield land by promoting the reuse and redevelopment of previously used land would provide for the protection of greenfield land where possible. |
Water-related policies are primarily driven by the aims of the EC Water Framework Directive as translated into Scots law by the WEWS Act 2003. Key objectives include safeguarding water quality and ensuring reliable water supplies. River Basin Management Plans, currently in preparation, will provide more specific objectives. Current national planning policies relating to the water resource focus on water supply and drainage and flooding. SPP7 notes the potential vulnerability of housing to flooding, and emphasising the need to take this into account when making housing land allocations. | SPP3 could usefully highlight the links between residential development, water quality and supplies. The issue of flood risk is also particularly relevant, with planning authorities having a responsibility to ensure sufficient land is promoted for development which is not at risk from flooding, and that building does not exacerbate flood risk in other areas. |
Air quality targets have been set at a European and national level, with the aim of improving overall quality, particularly the reduction of the most harmful emissions. | SPP3 has a limited role to play in contributing to this broader environmental policy agenda. Locational decisions and in particular the level of commitment to sustainable transport accessibility will influence the effects of the SPP on air quality. |
Climate change policies aim to secure two key aims - mitigation ( i.e. reducing harmful emissions and slowing down the process of change) and adaptation (responding to change in a positive way). Key priorities relating to housing include development of low impact homes (in terms of energy efficiency, use of sustainable materials, reducing journey lengths etc), and adaptation measures such as appropriate siting that reflects future flood risk, robust construction etc. Commitments range from the international to national level - most recently set out in 'Changing our Ways' (2006). | This policy agenda has recently grown substantially in significance, and it is important that SPP3 reflects climate change opportunities and challenges that are relevant to planning for housing. |
Key policies falling under the heading of material assets include those relating to economic development, transport, energy and waste. Priorities across these sectors seek to promote growth in the Scottish economy, reduce carbon emissions by increasing travel by sustainable modes of transport, promoting energy efficiency and increasing the share of energy that is generated from renewable sources as well as managing waste in an appropriate manner. The housing sector of the economy has a key role to play in achieving these aims, as demonstrated by the recent Draft Energy Efficiency and Microrenewables Strategy. | As the housing industry represents a significant element of the Scottish economy, support for new house building will assist in encouraging positive responses to these policy priorities by actively promoting policies such as the target for on-site renewables set out in SPP15, and the inclusion of energy efficiency technologies in construction standards. The extent to which this can be achieved depends on the influence of SPP3 on housing layouts and design. Further opportunities for microgeneration and renewables in the housing sector are likely to arise in the future, due to ongoing policy reviews. |
Policies relating to cultural heritage cover all aspects of the historic environment, and seek to safeguard important resources whilst also recognising the potential value of unknown and undesignated sources. | SPP3 should take this policy context into account, and seek to ensure that the framework for the identification of land for housing is complementary to the wider aim of historic conservation and enhancement (where appropriate). |
Landscape related policies seek to conserve protected landscapes, and also emphasise the potential value of wider (non designated) areas. Growing evidence on landscape vulnerability suggests that a careful approach to development that recognises spatial differences is required. | SPP3 should recognise the vulnerability of particular landscapes to change, and should seek to promote landscape protection and enhancement as part of the identification of appropriate sites for housing development. |
Other policies and strategies of relevance include those relating to sustainable development and design quality. There is an emphasis on raising standards within all types of development, and a recognition that the housing sector in particular could benefit from change. | The revised SPP3, like others in the series, should support the overall policy emphasis on sustainable development and continue to be underpinned by this underlying commitment to sustainable development and high quality design. |
Key points arising from this analysis include the need for SPP3 to reinforce targeted levels of housing provision whilst also supporting broader policies that seek to protect biodiversity, landscape, cultural heritage and the built environment, air, water and soil. In addition, a suite of policies relating to population and human health emphasise the importance of delivering on regeneration commitments, reducing health and social inequalities, providing more affordable housing, and generally supporting quality of life. Broader environmental targets are also relevant, including recent proposals to set higher targets for reducing greenhouse gas emissions and ongoing work to build climate change adaptation into sustainable land use planning.
Relevant aspects of the current state of the environment
Schedule 3 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes a description of "the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme", and "the environmental characteristics of areas likely to be significantly affected". This section aims to describe the environmental context within which the PPS operates and the constraints and targets that this context imposes on the PPS.
A full baseline review is provided in Appendix B. The following key points emerged from the assessment:
- Scotland has a wide range of habitats and species that are protected under international and national legislation. Biodiversity value is not confined to rural areas and there are potentially positive and negative interactions between new housing development and environmental protection and enhancement policies and aspirations.
- Population statistics support a need to provide more land for housing to meet growth and reduced average household sizes.
- Scotland's health is poor, and is exacerbated by low levels of physical activity (as well as other lifestyle factors). Environmental sources of health problems in Scotland also include those arising from poor air quality.
- Social and health exclusion tends to be geographically concentrated in urban areas and in the Central Belt of Scotland.
- The Scottish Housing Market Review provides a detailed assessment of the housing market in Scotland, including analysis of the recent rapid growth in house prices and a review of this in relation to supply. This emphasises the need to address issues of affordability, the reasons for which vary in different parts in the country and to deliver not only more housing, but the right types of housing which is appropriate to its location.
- Soil sealing, pollution and erosion are continuing problems throughout Scotland.
- Scotland is experiencing problems in water quality, which River Basin Management Plans, prepared under the Water Framework Directive, will be seeking to address. Water supply issues vary in different parts of the country. Flood risk is also documented in SEPA's flood risk maps for Scotland.
- Climate change has already become evident, and is predicted to potentially accelerate, unless carbon emissions can be significantly reduced. The Scottish residential sector is the largest energy consumer and has continued to experience a growth in energy consumption in recent years.
- The Scottish housing sector has become more energy efficient in recent years, but could go further towards reducing its carbon footprint by also increasing the share of energy that it uses from renewable resources.
- Air quality varies in different parts of Scotland. There are several designated Air Quality Management Areas where levels of pollution are unacceptable.
- Although there have been significant reductions in derelict and vacant land in Scotland over recent years, there remains a substantial amount of brownfield land, particularly within North Lanarkshire, Glasgow, Renfrewshire and Highland Council areas.
- Scotland has many protected and valued cultural heritage resources, including listed buildings, conservation areas, scheduled ancient monuments, historic gardens and designed landscapes. Heritage value also extends to those resources which have not necessarily been designated for protection, including broader cultural landscapes.
- Scotland's landscapes play an important role in reflecting local character and distinctiveness. Although Scotland's towns and cities often benefit from high quality townscapes, nationally homogenous housing developments have contributed to a decline in quality and distinctiveness of our settlements in recent years.
No significant gaps in data were identified during the course of the baseline analysis.
Environmental problems
Schedule 3 paragraph 4 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes a description of existing environmental problems, in particular those relating to any areas of particular environmental importance. The purpose of this section is to explain how existing environmental problems will affect or be affected by SPP3 and whether it is likely to aggravate, reduce or otherwise affect existing environmental problems.
Relevant environmental problems are summarised at Table 4.
Table 4. Environmental problems relevant to SPP3
Problem | Supporting data |
Decline in overall area of semi-natural habitats in Scotland. | Countryside Survey 2003 / State of Scotland's Environment Report ( SEPA, 2006) |
Climate change, urbanisation and other processes leading to habitat loss and fragmentation. | SNH Natural Heritage Trends and Site Condition Monitoring |
Growing numbers of households / changing household structures and challenge of meeting housing market needs which result. | Scottish Housing Market Review 2007 |
Key headline health problems including high rates of CHD and spatial concentrations of health problems in areas with high risk of deprivation. High rates of asthma and wheezing amongst children in households of with low incomes. | Scottish Health Survey 2003 Results |
Soil erosion, primarily caused by wind and water, and potentially exacerbated as climate change progresses. Soil sealing, which interferes with the ability of the land to process water, resulting in increased flooding and depletion of groundwater flows. | SEPA State of Scotland's Environment 2006 |
Potential future pressure on lochs, rivers and groundwater due to continuing growth in demand for water. | SEPA State of Scotland's Environment 2006 |
Flooding is a longstanding problem in parts of Scotland, which has had different effects on different housing tenures and households with varying incomes. | SEPA River and Coastal Flood Map |
Energy consumption from the residential sector has continued to rise despite efficiency driven initiatives. | Scottish Government Energy Efficiency and Microgeneration Strategy Consultation Draft 2007 |
Climate change trends are 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. At the same time, the contribution of the sector to climate change mitigation could be increased further. | SNIFFER research UKCIP02 scenarios Scottish Climate Change Programme |
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. | Scottish Executive Key Environment Statistics |
Fuel poverty is a national problem that is estimated to have grown substantially in recent years. | Energy Action Scotland |
Air quality management areas and concentrations of poor air quality | SEPA State of Scotland's Environment 2006 |
Inappropriate development and wider urban and rural decline pose ongoing threats to designated, undesignated and unknown historic environment resources. | NPPG5 and NPPG18 ( NB under review) |
Landscape change, standardisation and loss of distinctiveness. Pressure on greenspace in and around settlements, as well as broader / rural landscape change. Hot spots / areas of high pressure for land use change ( e.g. trunk road corridors, firths etc.) | SNH Natural Heritage Framework / SNH's Landscape Policy Framework |
Cumulative impacts from development on designated and non-designated landscapes | SNH's Landscape Policy Framework |
Declining quality of settlements and their surrounding landscapes as a result of demand for housing and residential development standards and trends. | SNH Natural Heritage Futures - Settlements Prospectus |
Ongoing need to reclaim / redevelop contaminated or derelict land, as supported by national policy | Scottish Vacant and Derelict Land Survey (2006) |
Likely evolution of the environment without SPP3
Without the revision of SPP3 existing environmental trends related to housebuilding activity in Scotland are likely to continue. Councils would also continue with current approaches to housing land allocations, maintaining concerns about qualitative and quantitative shortfalls in delivery of housing into the future. Whilst it is possible to envisage continuing improvements to some aspects of the wider environment, including water quality, biodiversity and landscape as a result of sector-specific policies, the potential for significant levels of positive change at a national level could be reduced without national level co-ordination and enhancement.
Assessment methods
The Consultative Draft SPP and the policy alternatives that emerged during the drafting process, have been assessed against the range of environmental issues set out in Schedule 3 of the Environmental Assessment (Scotland) Act 2005. Comments from the Consultation Authorities ( SNH, SEPA and Historic Scotland) have been taken into account regarding the methods, scope and level of detail in this Environmental Report.
At the scoping stage, a proposed assessment framework was set out for further discussion with the Consultation Authorities. They broadly agreed with the proposed approach, but did feel that further clarification of the methods used to assess the alternatives to the SPP would be useful. As noted at the scoping stage, the methods for the assessment have evolved as the work has progressed, and ultimately it was concluded that there were no identifiable reasonable alternatives to the Consultative Draft SPP. Consideration of the effects that maintaining the current SPP might have, has however, been undertaken and has been used to provide comparative findings.
The following SEA objectives were used to help structure the assessment and to identify the effects of SPP3 and its alternatives on the environment.
Table 5 SEA Objectives and Secondary Criteria to apply in the SEA of SPP3
SEA Objectives | Criteria for SPP3 assessment |
Protects or enhances biodiversity, flora or fauna | Reduces the overall decline in the area of semi natural habitats in Scotland |
Safeguards and enhances sites that have been designated for protection as a result of their biodiversity value. |
Promotes planning of biodiversity networks as an integral part of new housing developments. |
Promotes human health | Builds opportunities for increased everyday physical activity ( e.g. functional walking or cycling) into proposals for new or improved housing. |
Increases the contribution of good quality housing to reducing established health inequalities |
Safeguards or enhances the living environments of people or communities | Reduces social exclusion, particularly by targeting action in areas where this is currently concentrated |
Contributes to key priorities for community regeneration, including by helping to target housing improvements within these areas |
Delivers affordable housing |
Secures an effective and sufficient supply of land for new housing to meet the needs of projected household numbers and sizes |
Promotes the development of a sustainable settlement pattern and physical infrastructure | Where settlement expansion is promoted it protects the existing character of settlements and reflects their current and future capacity to accommodate change |
Ensures planning for housing is complemented by sufficient and sustainable infrastructure provision |
Ensures that new housing areas are robust in relation to predicted climate change |
Reduces energy consumption and / or CO2 emissions | Promotes housing development in areas that are accessible by sustainable modes of transport |
Contributes to achieving a reduction CO2 emissions from the energy sector by 60% by 2050 and substantially by 2020) |
Promotes the use of more diverse energy generation technologies (including renewables) |
Encourages improved energy efficiency |
Helps to reduce fuel poverty |
Reduces water pollution or enhances water quality | Achieves sustainable management of water demand / supplies for new strategic developments |
Avoids exacerbating current and predicted flood risk and / or delivers sustainable flood management solutions |
Protects of enhances the quality of soils | Avoids adverse direct and indirect impacts of developments on soil stability, structure and quality |
Maintains air quality | Avoids exacerbating air quality problems in existing AQMAs and does not contribute to designation of further AQMAs. |
Encourages efficient use of land and resources | Protects mineral resources from sterilisation by development |
Reclaims / redevelops derelict and contaminated land |
Achieves sustainable rural development |
Overcomes rural marginalisation arising from peripherality, poor infrastructure and / or limited access to services |
Contributes to sustainable waste management by promoting recycling of building materials and helping to provide appropriate facilities as an integral part of housing developments. |
Safeguards or where appropriate enhances the built environment | Protects / enhances (where appropriate) sites/townscapes that are recognised for their architectural and / or archaeological heritage value, and their settings |
Recognises and reflects the heritage value of wider (non designated) landscapes and townscapes |
Respects and protects the character, diversity and special qualities of Scotland's landscapes. | Protects/enhances the landscape setting of existing settlements |
Protects / enhances the quality, scenic value and distinctiveness of designated and non designated landscapes, including by avoiding inappropriate development |
Achieves sustainable management of change in vulnerable landscapes |
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