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CONTEXT

Outline and objectives of SPP 23

6. 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 provide this information for SPP23.

7. SPP 23 is an amalgamation of the existing policy that is set out in NPPG 5 Archaeology and Planning and NPPG 18 Planning and the Historic Environment. The policy forms part of a series of SPPs, which together set the national policy framework for land use planning. The SPP:

• Outlines national policy on the historic environment which local authorities should consider in formulating and assessing development proposals.
• Explains how the protection of the historic environment and the promotion of opportunities for change can contribute to sustainable development.
• Identifies a range of planning action designed to achieve conservation objectives, including implications for development plans and development management.

8. The SPP outlines the planning approach to statutory designations of the historic environment, including listed buildings, scheduled ancient monuments and conservation areas and also notes other (non-statutory) designations, including world heritage sites and gardens and designed landscapes. However, it does not provide a framework for making these designations, as this is already provided in relevant legislation. ¹ The SPP also relates to broader (non-designated) aspects of the historic environment.

9. The SPP focuses on the role of land use planning in relation to the historic environment, and sets out the role of local authorities in this respect, defining how they can complement the role of Historic Scotland. It advises on policy making for the historic environment, including general policy guidelines, and sets out recommendations for development plans at a strategic and local level. It also notes the role of Supplementary Planning guidance ( SPG) and encourages the use of Model Policies (as proposed in Annex A of the draft SPP). It should be noted that the SPP continues to be primarily limited to the historic environment on land. Planning control has been extended to include control of marine fish farming, but in all other instances planning legislation is restricted beyond the mean low water mark.

10. The key difference between the existing NPPGs and the new SPP is the reduced level of background information and elaboration provided within the proposed policy document ². At present, the only anticipated changes to the SPP's key policies are amendments to the guidance on the role and content of structure plans/strategic development plans and local plans/local development plans, which will seek to avoid duplication between these two levels of plan and to reflect changes to the planning system introduced by the Planning etc. (Scotland) Act 2006. In addition, although the proposals on model policies represent a new part of the SPP, they are provided on an advisory basis only.

11. A longstanding commitment to amalgamating NPPGs 5 and 18 has led to this review taking place. A more radical or comprehensive revision of the policies is not currently proposed, and this is reflected in the proposed approach to the SEA. Furthermore, the SPP focuses on the role of land use planning in delivering broader commitments to the historic environment, as established in legislation and the broader series of Scottish Historic Environment Policies ( SHEPs) produced by Historic Scotland. Consequently, it is important that the SEA is realistic about the scope and content of the policy it is seeking to assess. The approach has therefore been defined with these important limitations in mind.

Relationship with other PPS and environmental protection objectives

12. Schedule 3 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes an outline of SPP 23's relationships with other relevant PPS, and how environmental protection objectives have been taken into account in its preparation. This section covers these issues and describes the policy context within which SPP 23 operates, and the constraints and targets that this context imposes on the policies and proposals it contains.

13. Table A in Appendix A lists the plans, programmes, strategies and environmental objectives that have been reviewed in terms of their relationship with the SPP on Planning and the Historic Environment. Drawing on this, key objectives that should be taken into account include the following:

Table 3: Summary of environmental objectives of relevant plans, policies and strategies, and implications for the SPP on Planning and the Historic Environment

Relevant aspects of the current state of the environment

14. 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 SPP 23 operates and the constraints and targets that this context imposes on the SPP.

15. The table below summarises the data collected and the sources:

Table 4: Baseline data sources

16. The following paragraphs describe the area of Scotland and identify any related environmental problems. These are brought together and summarised in Table 5 below.

Cultural Heritage, including architectural and archaeological heritage

17. Scotland has four World Heritage Sites, over 47,000 listed buildings and 628 conservation areas (in January 2007). There is currently no comprehensive record of the condition of listed buildings for Scotland as a whole, but in January 2006, 3,055 buildings were recorded on the Scottish Civic Trust's Buildings at Risk ( BAR) Register, of which 1,036 were at risk. The 2007 Inventory of Gardens and Designed Landscapes identified 386 sites. Historic Scotland has responsibility for 345 Properties in Care.

18. The full extent of archaeological remains in Scotland is unknown, with 7,882 Scheduled Ancient Monuments representing only a small proportion of the 129,000 sites and monuments for which there are records, and the many more unrecorded sites and unknown resources throughout the country. According to the SHEA, RCAHMS also has 130,000 architectural records and 15,000 records for maritime sites. ³ The SHEA also notes that many older buildings are not designated but are nevertheless important to the character and identity of our villages, towns and cities. It is estimated that 18% of dwellings in Scotland were constructed before 1919.

19. The historic environment can be threatened by inappropriate development (guided by short-term aims), economic decline, loss of viable use, population change and neglect. Land use change, including forestry activity, renewable energy, biomass projects and agriculture ( e.g. plough erosion) can also have significant repercussions for the historic environment ⁴. In addition, natural features and processes can influence the robustness of Scotland's historic environment - for example coastal erosion, or burrowing animals - and some of these processes may be further exacerbated by climate change as it progresses. These issues are of relevance to both designated and non-designated sites. ⁵

20. RCAHMS records on Scheduled Monuments ⁶ show that around 14% are either in unsatisfactory condition or have extensive significant problems. Many of these sites fall within the categories of 'crosses and carved stones', 'ecclesiastical', 'secular' and 'industrial and transport' sites, although the condition of many other sites may be more difficult to gauge, and may also be of concern. In terms of future risks, it is estimated that 8.5% of Scheduled Monuments are subject to high or immediate risk of further deterioration, with a further 25.4% being at risk of deterioration within the next 5 years.

21. According to the SHEA, of the total of 50,049 planning applications in 2005-06, 7% also involved listed building or conservation area consent. Of these applications, 92% were granted in this time period.

22. Scotland has eight designated historic wreck sites around its coast. These sites are protected under the 1973 Protection of Wrecks Act. Under the 1979 Ancient Monuments and Archaeological Areas Act, a further seven wrecks of the German High Seas Fleet that were scuttled in 1919 are protected in Scapa Flow. Many more marine features are included in the RCAHMS database.

23. Maps 1 and 2 show the location of Listed Buildings, Conservation Areas, World Heritage Sites, Scheduled Ancient Monuments and Gardens and Designed Landscapes throughout Scotland. They illustrate that the spatial distribution largely follows the pattern of settlement across the country and is concentrated around valleys and the coast.

Landscape

24. The European Landscape Convention states that landscapes across Europe are being transformed as a result of a number of factors, including settlement expansion, transport and infrastructure and the economy. ⁷ Collectively, the series of landscape character assessments prepared by SNH provides a useful 'snapshot' of the characteristics of Scotland's landscapes and this is translated to a strategic level in SNH's Natural Heritage Futures Statements. As part of this, SNH prepared a national assessment of Scotland's landscapes that sets out nationally significant resources, pressures and opportunities ⁸. This emphasises that today's landscapes are a legacy of past generations, with evidence of settlement, rituals, hunting and farming over many years. A few places are of particular historic significance, with clear visual evidence of past land use that helps to maintain links with our ancestors. Past associations vary between Scotland's regions, from Pictish remains in the northeast to early Christian associations in the south and west, and evidence of ancient lives and rituals in the Northern and Western Isles. Even where remains are less tangible, more subtle influences such as field patterns, estate woodland and settlement expansion have influenced landscape character. In addition, historically, Scottish literature and culture has attached a high value to Scotland's natural landscapes.

25. The report notes that Scotland's landscapes are constantly evolving, but that forces for change vary between gradual natural processes and human activity. The latter is thought to result in more pronounced and often negative change, and further key challenges include incremental changes to land use and shifting perceptions of values attributed to different landscape features.

Biodiversity, Flora and Fauna

26. In short, Scotland's ecological health is variable and has been subject to change over time. Of the UKBAP priority habitats and priority species found in Scotland, by 2005 around 33% of habitats and 32% of species were stable or are improving, whilst 30% of habitats and 14% of species were in decline. ⁹ The condition of the remainder is unknown, unclear or fluctuating. SNH undertakes monitoring of the condition of Scotland's designated sites. Recently released figures ¹⁰ show that 71% of the sites monitored were found to be in favourable or 'unfavourable recovering' condition. Further restoration and enhancement will therefore be required to meet the stated targets of achieving favourable condition in 80% of sites by 2008 and 95% by 2010. This could provide both a challenge and an opportunity for the historic environment.

27. SEPA provides further information on the current state of Scottish biodiversity. It notes that climate change is already having an impact on biodiversity, and that other processes including urbanisation, land use change and the spread of non-native species will make it difficult to reach stated biodiversity targets ¹¹ Although agriculture is noted by SEPA to be a key cause of habitat loss and degradation, SEERAD figures show that there has been a steady increase in the overall area of land which is managed under agri-environment schemes in Scotland ¹². SEPA also refers to SNH's natural heritage trends reports, which identified loss of neutral grassland, particularly in the uplands and islands, dwarf shrub heath, acid grassland and bog as key problems. This is confirmed by the broader Countryside Survey 2003, which monitored change in broad groups of habitats between 1990 and 1998, and showed that there was a substantial decrease in semi natural habitats in Scotland in this period (-88,000 hectares).

28. Climate change is likely to exacerbate established pressures on biodiversity resources, and therefore has the potential to increasingly compromise site-based conservation measures. As a result, there has been a growing emphasis on the development of broader-scale measures for protection and conservation including the commitment in the Scottish Biodiversity Strategy to removing barriers to species movement and dispersal and positively improving connections between habitats.

29. Map 3 shows the relationship between designated historic environment sites and key natural heritage designations. Although there is little obvious overlap at a national scale, there may be locations where tensions arise between protection or enhancement of the historic environment and management of natural heritage interests.

Population

30. Many Scottish settlements have cultural heritage value in their own right, and in turn the historic environment is a key part of national cultural heritage and identity. The SHEA reports that 94% of respondents to a recent opinion poll said that historic features form an important part of the identity of our villages, towns and cities, with 92% supporting their protection.

31. Historic Scotland is committed to increasing appreciation and enjoyment of the historic environment, is actively seeking to promote knowledge and skills, and to build the capacity of the voluntary sector. Recent research ¹³ suggests that a loss of traditional skills in Scotland has the potential to impact on our ability to maintain the historic environment, now and in the future.

32. The Scottish historic environment supports employment throughout the country and tourism data shows the importance of heritage resources in attracting visitors to Scotland. ¹⁴ Historic Scotland's properties alone are visited by some 3 million people annually ¹⁵ and around 70,000 school visits to Historic Scotland's properties were undertaken in 2006-2007. In 2006, of 692 properties where visitor numbers were collected by visitscotland, 344 were of a historic character, attracting 16.4 million visitors, accounting for 36% of the total number and a disproportionately high number of overseas visitors in particular. ¹⁶ Many other jobs depend on the historic environment, with an estimated 12,360 being employed in the Scottish Built Heritage Sector. ¹⁷

33. Heritage organisations appeal to many people in Scotland, with high numbers of members of Historic Scotland (75,749 in October 2006) and the National Trust for Scotland (296,714) in particular. The historic environment also provides varied opportunities for volunteering: in 2006 the National Trust for Scotland made use of the time of 2,973 volunteers, who collectively contributed 162,042 hours of time - equivalent to an estimated value of £1million in person hours.

Water

34. SEPA's recent reports on Significant Water Management Issues ( SWMI) for the Scotland and Solway Tweed River Basin Districts provide an up-to-date analysis of water quality issues under the requirements of the Water Framework Directive ^{18, 19}. For the Scotland RBD, it is predicted that almost one-third of water bodies will not reach the required 'good ecological status' by 2015. It maps the sources of pressure in relation to water bodies at risk and shows the effects of urban development in generating diffuse source pollution that impacts on water bodies in and around most of Scotland's most urban areas, primarily in the Central Belt but also extending southwards into Ayrshire. Climate change adds a further dimension to the challenge of improving water quality, with potentially substantial reductions in ground water flows in the east of the country and increased water temperatures putting further pressure on their ecological status and increasing their susceptibility to pollution.

35. Statistics compiled by Scottish Water ²⁰ show that there has been a growth in demand for water that could put significant additional pressure on Scottish water supplies in the future. Water quality is also an important measure of environmental health and it is generally accepted that for Scotland this has been improving over the last two decades and is good overall. Whilst this is encouraging, SEPA continues to work towards specific targets such as levels of compliance for licences issued under the Control of Pollution Act, and diffuse pollution remains a problem.

36. This in turn has repercussions for the robustness of the historic environment. Whilst water quality enhancement has tended to focus on the amenity and ecological value of the water environment, cultural resources can also be positively or negatively affected by water improvement programmes, such as measures to reduce point source pollution and flood protection measures. The Council for Scottish Archaeology ²¹ has noted that key features at risk from such activities include embankments, weirs, lades, mills and burial mounds, and notes that the expansion of settlements and associated requirements for water supplies has inevitable impacts on the historic environment.

37. Whilst this forms important baseline data, the assessment does not consider the extent to which SPP 23 may have effects on the water environment, as such effects are not expected to be significant.

Air

38. As with water, although it is unlikely that the SPP will have significant air quality impacts, it is important to bear in mind the environmental context within which the policy is being developed. Air pollution can have repercussions for many aspects of quality of life, including human health and biodiversity. Targets set by the UK Air Quality Strategy have generally been met, including in relation to PM₁₀, NO₂ and SO₂. However, there continue to be problems with reducing CO₂ emissions (as noted in relation to climatic factors, energy and transport sectors). Record levels of ozone depletion were recorded over Scotland in 2005, with a 5% decline in stratospheric ozone recorded over the last 20 years.

39. Further measures and a continuing commitment to air quality improvements will be required to continue generally positive trends and avoid any future secondary impacts of air pollution on the historic environment. ²² As with the water environment, however, no significant effects on air quality are anticipated and so this topic area was scoped out of the assessment.

Climatic Factors

40. The long-term increases in temperatures in the UK and Scotland have accelerated over the past three years, showing that "there is now evidence that human activities are having a discernable impact on the global climate"²³. The UKCIP02 ²⁴ climate change scenarios predict that by the 2080s temperatures will rise by up to 3.5 ^o in the summer and 2.5 ^o in the winter, and that there will also be changes in precipitation, snowfall (up to a 90% reduction), seasonality, cloud cover, humidity, wind speeds, soil moisture, extreme weather (especially rainfall events) and seasons, and sea levels as a result of climate change. Spatial patterns of climate change within Scotland are predicted to vary. For example, summer rainfall is expected to reduce by 10% in most of the country except the north west, and much more substantial increases in spring and autumn rainfall in the south west and north east of the country are envisaged. The spatial impacts of these scenarios are provided by UKCIP ( http://www.ukcip.org.uk/scenarios/ukcip02/maps/). Updated UKCIP08 climate change scenarios are currently under development and will be released in 2008. These will be based on more detailed 25km cells and address some of the uncertainties of the previous model. Further evidence of Scottish climate change has been provided in research by SNIFFER. ²⁵ This includes data showing a 25% reduction in frost days since 1961, a shorter snow season and a lengthened growing season. Many of these trends appear to be most significant in north and west regions of Scotland.

41. Some evidence is beginning to emerge on the implications of climate change for historic buildings. For example, there is concern that increased intensity of precipitation combined with high winds will result in increased rainwater penetration of building stone. In addition to causing damp problems, this can combine with salt accumulated in building fabric, accelerating erosion and weathering, particularly of vulnerable materials such as sandstone. ²⁶ More indirect effects from climate change might also be expected, with the mitigation-based drive to renewable energy generation, for example, possibly putting pressure on the historic built environment. This pressure ranges from the effects of wind farm siting and construction on unknown archaeological remains to the installation of micro renewables in conservation areas.

42. Conservation of historic buildings can be viewed as inherently sustainable, given the resources that can be saved by reducing the need for new development. Considerable energy 'capital' has been invested in the original source of materials for the construction of buildings, and so their conservation helps to save energy. Some types of historic buildings also perform well in energy terms throughout their lifecycle, as a result of their higher insulation properties, and some aspects of their design ( e.g. small windows). Others require more innovative thinking if they are to be made more energy-efficient. Research is ongoing about the energy generated in producing materials for building conservation, with some concerns being raised ( e.g. restrictions on the use of double glazing), but being balanced by more positive views ( e.g. improved sustainability of timber products, particularly when compared to the use of plastics). In the meantime, it is clear that climate change could be at least partly positively affected by planning policy on the historic environment.

Gaps in Baseline Data Sources

43. The following summarises the likely gaps and/or unreliability of the SEA baseline data, and how they were minimised:

• The Historic Land Use Assessment Dataset would potentially have been a useful source of further information for the assessment as it provides fine grained maps that allow for consideration of heritage resources potentially at a landscape scale. At the time of the assessment, however, this was not available for use as coverage of Scotland remains partial (60% in 2007). The dataset also requires further analysis to define issues such as value and significance, in order for it to be effectively applied to a national level SEA.
• At scoping, a need to combine information on natural and cultural heritage using GIS was suggested, to establish a clearer view of their interactions. It was concluded that this only provides a very broad insight into issues at a national level, as the scale of mapping and the complexities of the conservation value of different sites makes interpretation difficult. Notwithstanding this, Map 3 was created to illustrate the overall distribution of both datasets.
• There remains a need for more data which defines the changes to the historic environment that are occurring as a result of development. In particular, Historic Scotland's recent audit prioritises data collection to identify planning consents where archaeological conditions have been set, in order to provide a clearer view of the interaction between planning and the historic environment.

Environmental problems

44. 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. Some of these have already been raised in the description set out above. The purpose of this section is to explain how existing environmental problems will affect or be affected by the SPP and whether SPP 23 is likely to aggravate, reduce or otherwise affect existing environmental problems. These environmental problems were identified at an early stage in the SEA scoping process and confirmed in consultation with the Consultation Authorities and an analysis of the baseline data. Relevant environmental problems are summarised at Table 5.

45. The SPP has the potential to help to address some existing environmental problems, particularly those relating to the historic environment. Whilst numerous environmental problems currently exist in Scotland, it is important for the SEA to focus on those which are most relevant to this SPP, and therefore the historic environment.

Table 5. Summary of environmental problems relevant to SPP 23

Likely evolution of the environment without SPP 23

46. It is difficult to fully and realistically consider the evolution of the environment without the SPP, given that it is largely an amalgamation of adopted policies ( NPPG 5 and NPPG 18). However, it can be broadly concluded that without the SPP, existing environmental trends would continue.

47. However, in the absence of any review of the policy to reflect the environmental trends set out above, many of the problems described are likely to be exacerbated, with a consequent acceleration of negative effects on the historic environment such as damage or adverse effects on the setting of sites and buildings as a result of inappropriate development.

48. The draft SPP removes much of the descriptive text which featured in the NPPGs, much of which refers to NPPG documents which have now been superseded by SPPs. It is now practice within SPPs to include a general statement at the beginning of each document which states that they should be read as an integral policy suite with other SPPs, rather than repeating the content of individual policy documents.

49. The SPP also contains information on the SHEP series, which is not reflected in the previous documents. It updates the links to other policy guidance and includes reference to the Planning etc. (Scotland) Act 2006. In the absence of SPP 23, it would not be possible to provide local authorities with appropriate policy guidance to reflect the ongoing changes to the planning system and would not provide sufficient clarity to allow those starting work on Strategic Development Plans ( SDPs) and Local Development Plans ( LDPs) to appropriately reflect the historic environment. Existing policy would not reflect the new system, where SDPs will focus on city regions rather than covering the entire country.

50. The revision shifts the emphasis towards the informed management of change and the need for the historic environment to adapt in order to retain its value, better reflecting the stance of Historic Scotland towards the evolution of the historic environment. This supports a more proactive planning role for the historic environment.

51. The revision and amalgamation reduces the amount of text and description provided, but contains no overall change in policy direction; it provides clearer information and policy for local authorities, applicants and others, while reflecting the changes to the planning system under modernising the planning system.

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