The Scottish Government

Decline in overall area of semi-natural habitats in Scotland. Some aspects of the draft SPP were predicted to exacerbate this.

Yes

The assessment showed that this could be exacerbated by the aspiration for an increase in housing development, by new settlements and rural housing development. The SPP included some mitigation to reduce these potentially adverse effects. These provisions have been strengthened within the finalised version of the SPP, by noting the need to take biodiversity into account in considering proposals for sustainable settlements, by noting the importance of biodiversity under the broader heading of 'landscape and open space', and by referring to landscape scale ecology as part of the place making agenda. Further mitigation is provided in other parts of the SPP series.

Climate change, urbanisation and other processes leading to habitat loss and fragmentation.

Yes

This was also raised as a problem that could be exacerbated by a substantial increase in the rate of house building. The finalised SPP refers to the need to take climate change into account as part of sustainable settlement strategies, under the place making heading. Energy efficiency and resource use are also explained, with the SPP supporting measures which contribute to climate change mitigation and adaptation.

Growing numbers of households / changing household structures and challenge of meeting housing market needs which result.

Yes

This problem formed a focus for the policy aims that are set out in the SPP as a whole. The SPP will play a key role in meeting housing market needs through the planning system in the future.

Key headline health problems including high rates of Coronary Heart Disease 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. The SPP was predicted to have mixed effects on this issue.

Yes

The SPP will play a role in reducing environmental health problems by promoting more sustainable patterns of development. The further assessment and mitigation measures proposed as a result of this and the stakeholder consultation responses should ensure that the SPP plays a key role in reducing the contribution of planning for housing to these existing problems. The finalised SPP specifically refers to healthy and active living as part of the place making agenda. The role of open spaces as part of housing developments is noted as contributing to community health. Mixed communities are also supported in the SPP, which makes reference to the opportunities they can provide for supporting healthier lifestyles.

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.

Yes - as far as possible

The assessment showed that on the whole the policy should ensure that possible negative effects on soil resources will be mitigated through appropriate planning responses that prioritise previously used land for development. However, negative effects such as soil sealing and loss of brownfield land may not be entirely avoidable given the role of the SPP in substantially increasing levels of land that are made available for housing development, as this may incur some loss of greenfield land (albeit in a planned and sustainable way). The finalised SPP now refers to the need to consider the vulnerability and value of soil, particularly prime quality land, when considering land for housing development and emphasises the importance of achieving the efficient use of land and buildings. Consideration of the intrinsic value and contribution of land to natural, cultural and heritage resources in terms of effect of development and relative costs is also included.

Ongoing need to reclaim / redevelop contaminated or derelict land, as supported by national policy.

Yes

This was a key aim expressed in both the draft and finalised SPP. The assessment showed that this emphasis should reduce negative effects on soil and ensure the efficient use of available land. The finalised version of the SPP has been strengthened to provide additional information on how this can be achieved including a reference to rural vacant land availability and an explanation of what constitutes brownfield land in rural areas.

Potential future pressure on lochs, rivers and groundwater due to continuing growth in demand for water.

Yes - as far as possible

The increase in house building rates and creation of substantial numbers of new households are likely to lead to increased demand for water overall, as noted in the assessment and the supplementary work on the 35k goal. The finalised version of the SPP emphasises the need for a planned approach to take into account and mitigate adverse effects on the water environment, and work collaboratively to ensure planning is linked with wider considerations, including water and drainage connections. This will be important for settlement expansion and possible new settlements. Reference is now also made to SUDS and this is linked to the broader place making agenda.

Flooding is a longstanding problem in parts of Scotland, which has had different effects on different housing tenures and households with varying incomes.

Yes

Additional mitigation has been included in the finalised SPP to address flood risk, including specific reference to this as one of the criteria to be taken into account when allocating sites for development. Advice for development planning notes that flood risk is one of the considerations for defining where development should be guided to. Flood risk is now also referred to under Sustainable Settlement Strategies. Further more specific guidance on housing and flooding is provided in SPP7. It was not considered appropriate to repeat this within SPP3.

Energy consumption from the residential sector has continued to rise despite efficiency driven initiatives.

Yes

This was noted as a problem that could be addressed through a stronger emphasis on the deployment of energy efficiency, sustainable construction and renewable energy measures via the planning system. The finalised SPP has addressed this by making specific reference to wider aspirations for improved energy efficiency and use of renewable energy, including the Sullivan Report, under the place making heading.

Climate change trends are already established and predicted to continue and accelerate. The residential sector could be affected by this - adaptation is therefore required. The contribution of the sector to climate change mitigation could be increased further.

Yes

The finalised SPP makes reference to the need for the housing sector to take into account the effects of climate change, particularly at a strategic level when planning the sustainable expansion of settlements. It has now been included as a recommended criterion for local authorities to take into account when identifying land for housing and in other parts of the SPP as noted above. It will also be addressed in the assessment of environmental effects through SEA and Appropriate Assessment of lower level plans.

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.

Yes

As noted above, the finalised SPP makes reference to the value of renewable energy generation for the domestic sector and links with broader policy commitments to increasing this. Beyond the SPP, other initiatives, including draft proposals for permitted development rights for domestic microgeneration, will also provide mitigation in combination with the SPP.

Fuel poverty is a national problem that is estimated to have grown substantially in recent years.

Yes - indirectly

This is not explicitly addressed within the SPP, although the supplementary assessment of the 35000 houses per annum goal (appendix 1) showed that this could provide benefits in terms of energy efficiency, as new build tends to be significantly more efficient than older housing stock. This in turn has the potential to contribute positively to reducing fuel poverty. The SPP makes reference to measures which could contribute to this goal, including improved energy efficiency and micro generation, as explained above.

Air quality management areas and concentrations of poor air quality.

Yes

The finalised SPP continues to emphasise the need for sustainable patterns of development. As shown in the supplementary assessment of the 35k goal, additional housing allocations may introduce higher levels of air pollution, particularly within urban areas, and where accessibility is based on the road network or motorised transport links. Air quality is not specifically referenced, but it is expected that the improved emphasis on accessibility by sustainable transport (including land allocations taking into account public transport, pedestrian and cycle networks) and the broader emphasis on place making and environmental quality more generally should ensure that there are no additional significant adverse effects on existing environmental problems.

Inappropriate development and wider urban and rural decline pose ongoing threats to designated, undesignated and unknown historic environment resources.

Yes

The SEA and the supplementary assessment noted that some aspects of the environment are likely to be safeguarded by development planning, but that the overall increase in levels of housing development could lead to particular pressure on undesignated townscapes and archaeology. The Finalised SPP notes that the historic environment should be taken into account within the process of directing the housing to the right locations. Cultural heritage is also noted as a consideration within sustainable settlement strategies, as a contributor to the intrinsic value of a potential housing site. Improved policy on site selection within the Finalised SPP should reduce the likelihood of inappropriate development.

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.)

Cumulative impacts from development on designated and non-designated landscapes.

Declining quality of settlements and their surrounding landscapes as a result of demand for housing and residential development standards and trends.

Yes

The draft SPP made reference to the importance of landscaping and quality design. However, the assessment showed that some other parts of the SPP may nevertheless have adverse effects on landscape, particularly the aspiration for a substantial increase in the amount of housing which is constructed. In light of the assessment and stakeholder comments, the SPP has been revised to give greater weight to landscape as a part of environmental protection and enhancement. The sustainable settlement strategy approach to site selection requires consideration to be given to protection and enhancement of landscapes and to recognise the need for a different approach according to the character of the location. Sustainable settlement strategies are also required to take account of other policy objectives which would include protection of designated landscapes. The section within the SPP on Landscape and Open Space is also relevant, recommending that landscape frameworks should be prepared to ensure that housing developments take into account their setting and impacts.

CONSULTATION AUTHORITIES.

Historic Scotland

Largely content with the results of the assessment, but some elements require clearer explanation in the report.

Noted - see more specific comments below.

No explanation of the elements that have been assessed and how they relate to the SPP. Difficult to compare with policy content. Without this, difficult to identify whether this is a full assessment. Would have been useful to provide key with assessment tables and cross reference further.

The Scottish Government is confident that a comprehensive high level SEA has been undertaken of the proposed SPP, although it is acknowledged that the headings of the assessment tables do not now precisely reflect those of the SPP. This arose due to the complex nature of the SPP drafting process. We would suggest that this is a presentational issue, as opposed to an problem about the comprehensiveness of the content of the assessment, but it is also acknowledged that more could have been done to ensure that the reader can navigate their way through the findings more easily. This criticism will be taken on board in future SEAs of SPPs.

The Environmental Report should include an explanation of the relationship between Firm Foundations and the SPP, as w are unclear what alternatives to the target have been considered and assessed elsewhere. Agree that the 35k target has the potential for adverse effects on the historic environment, but it is difficult to determine significance at this stage as will be dependent on local level implementation.

Agreed. This has now been addressed within a supplementary assessment ( Appendix 1). This has explored potential effects in more detail, leading to revised mitigation measures from a strategic perspective. It is agreed that further assessment of the implications of the scale of development proposed will be required within strategic and local development plans.

Agree that mitigation is required for the setting of listed buildings and wider historic townscapes. Mitigation is also needed for archaeological sites and HGDL.

The revised mitigation schedule (Section 3) (produced following the supplementary assessment in Appendix 1) now makes specific reference to mitigation measures for these resources.

Agree that development plans are critical for mitigation. Useful to clarify in SEA Statement and in particular to explain 'capacity assessments'. At the moment these focus on landscape but cover little about the wider environment.

Noted. More is now explained about capacity assessment within the revised mitigation schedule, reflecting the findings of the supplementary assessment as well as the SEA as a whole and the content of the finalised SPP. Text is included in the finalised SPP on sustainable settlement strategies which provide the context for new development including more than landscape. The role of masterplanning is referred to.

Content with cross referencing approach within the SPP.

Noted.

Content with baseline and contextual analysis.

Noted.

Agree that increased land for housing will have cumulative effects on the historic environment, but note that impacts will be dependent on delivery through development plans, site selection and capacity analysis.

Noted. Scope to positively influence this process has been explored in more detail within the supplementary assessment, and is more comprehensively set out in the finalised SPP.

The proposed monitoring approach is unclear. This should be clarified in the SEA statement, noting when review of the SPP might take place and identifying monitoring indicators.

The proposed approach to monitoring is explained in Section 5.

Scottish Environment Protection Agency

Generally content with a high level assessment, in terms of scale and scope.

Noted.

Difficulty with assessment groupings. These were difficult to fathom, although we now understand how these were developed. It would have been helpful for this to be clarified. It is difficult to follow whether there are any omissions, and therefore whether assessment is reasonable.

Agreed - see comments in response to Historic Scotland view above.

Relationship with Firm Foundations. SEPA is unclear how the assessment of SPP3 relates to this. Firm Foundations itself states that an SEA will be undertaken but it is unclear how or when this will be achieved. If the SPP3 assessment was expected to cover this, HS would have expected a more detailed assessment

Noted. As a consequence of this view (as well as concerns expressed by other consultees), a Supplementary Assessment of the 35000 goal has now been undertaken and is provided in Appendix 1. The findings from this assessment have been used to inform the development of a more detailed revised mitigation schedule.

Comments on the high level assessment of the 35k target: This would be a significant increase, and therefore it is surprising that more significant effects have not been identified - i.e. minor in relation to biodiversity, energy, water quality and soil quality. SEPA would expect more significant effects from soil sealing, urban diffuse pollution, increased construction and demolition waste, increased land take and potential effects on air quality. However, it is also recognised that there is scope for this to result in environmental enhancement.

This is now addressed in Appendix 1.

SEPA is disappointed that there is little mitigation relating to the 35000 goal. We would have preferred specifically targeted mitigation.

This is addressed in Appendix 1 and in the updated mitigation measures set out in Section 3 of this statement.

SEPA is unconvinced that air quality effects of the target should be recorded as positive, as a result of increase in traffic generated, particularly in areas of high development pressure where air quality may already be problematic.

This has been considered further in Appendix 1.

Water and drainage infrastructure capacity and waste need further consideration.

This has been considered further in Appendix 1.

SEPA recognises that it is very difficult to assess significant effects of the target in detail, as this will need to be done at a more detailed level. Clear direction to planning authorities would be helpful as this represents a significant policy development. The concern is not necessarily about the size of the target, but the need for management of the scale of change in a way that safeguards the environment.

The finalised SPP contains strong policy direction to local authorities to consider a sustainable settlement strategy approach to preparing their development plans. The SEA of development plans provides additional scope for management of environmental effects. The effects arising from the goal, and associated environmental mitigation measures, are explained in Appendix 1.

SEPA generally welcomes suite of mitigation measures, but makes the following comments:

• Focus more on mitigation measures for effects of the 35000 aspiration.
• An implementation plan for mitigation measures should be developed.
• Flood risk mitigation needs to be clarified and reference to SUDS.
• Requirement for more land is not an SEA issue - focus on environmental issues arising from this policy proposal.

Further mitigation measures are identified in Section 3, as a result of the additional assessment provided in Appendix 1. The final SPP now makes specific reference to use of SUDs.

Notes listing of wider policies in Annex D of SPP. Consider drawing out environmental requirements of Annex D policies within the SPP to trigger awareness amongst planning authorities. Label Annex D as indicative.

This was also suggested by the RTPI. See comments in response to their views below.

Suggest providing further detail on SUDS and use in new residential development. The SPP should urge planning authorities to use SUDS to reduce flood risk and urban diffuse pollution.

Agreed. SUDS is now incorporated into the revised mitigation schedule and reference to it has been made within the SPP itself.

Assessment already identifies most likely sources of cumulative and synergistic effects, but mitigation does not go far enough towards addressing them. Although the SPP does include mitigation measures, a focus on this, together with specific instructions to planning authorities would be useful.

Agreed. Section 3 now provides a clearer set of mitigation proposals.

Assessment of alternatives is reasonable, and demonstrates policy improvements. But misses key points, including alternatives to the 40% target. If this is the only opportunity for assessment, there is a need to consider options further.

Agreed. This is now reflected within the Supplementary Assessment ( Appendix 1) although, as explained therein, there are not considered to be any reasonable alternatives to the goal.

Issues raised by SEPA at scoping. Most of these have been dealt with in the ER, but the following points are outstanding (in addition to those already raised above):

• Extrapolation of further information from RBMPSWMI Report.
• Recommend planning authorities consider AQMAs as part of housing policy.
• Waste issues are omitted.
• Drainage constraints and cumulative effects should be considered further.

Noted. The RBMP Report, AQMAs, waste issues and drainage are all now referred to within the Supplementary Assessment ( Appendix 1).

Scottish Natural Heritage

Overall approach is clear and comprehensive.

Noted.

Would expect ER to assess the impact of delivering 35,000 houses per year over a period of perhaps 10 years or more / up to 2018. Assessment could give broad estimates as to proportion that can be accommodated on brown or greenfield land free from environmental constraints. More could be done to explain cumulative effect over several years. Could also investigate resultant increase in demand for infrastructure, including water and drainage, and its relationship to projected supply. Also effects on energy demand, and the extent to which this might be offset by improved energy efficiency in house design.

Noted. See comments above in response to similar comments from SEPA. The Supplementary Assessment in Appendix 1 provides further detail on the long term cumulative effects of the 35000 goal.

Accept that effects will be largely dependent on interpretation at a more local level. Welcome proposed mitigation measures including plan-led approach. Important that these measures are taken forward - need to articulate in strong and clear language in the finalised SPP.

Agreed. Further detail on mitigation is proposed within the revised mitigation schedule.

There is a particular need for further work on flood risk. Expand SEA criterion on flood risk to 'seek to keep flood risks for new housing to an acceptable minimum in light of predicted climate change and to contribute to decreasing flood risk to the housing stock as a whole as older, more flood prone stock is phased out.' This may require a reassessment of brownfield land for housing development to take flood risk into account.

Agreed. The SPP now makes reference to flood risk and this has been explored to within the supplementary assessment ( Appendix 1) and mitigation schedule (Section 3).

Cross referencing is useful but not as effective as a clear explanation of the issues to be addressed by planning authorities when identifying land allocations for sustainable communities or the criteria for ensuring high quality design.

Noted. The revised and finalised SPP attaches greater weight to quality design. The revised mitigation schedule also provides a clearer explanation of these issues and more detailed mitigation as a result. Much of the policy and advice on this is already expressed in other guidance.

Further information would be helpful to consider soil quality and soil sealing

Agreed. This has been explored in more detail within the Supplementary Assessment (Appendix 1).

Suggested mitigation measures

• Maintaining habitat networks within development plans, master plans, preparatory capacity assessments.
• Provision of opportunities for physical activity within housing proposals.
• Energy efficiency and renewable energy.
• Significant opportunity to take account of landscape in strategic and site specific decision making.
• Tensions in housing demand in or around NPs and NSAs.

Agreed. These have been largely incorporated into the revised mitigation schedule.

OTHER CONSULTEES

Central Scotland Forest Trust

Encourage SG to work with SLF, trade organisations and house builders to ensure planning delivers quality developments that avoid adverse effects on the environment.

Noted. The enhanced mitigation schedule (Section 3) provides scope to achieve this.

Agrees with ER comments on biodiversity: would welcome further research on pinch points for species migration in the Central Belt and work to progress the Central Scotland Green Network. Encourages the setting aside of land along main transport corridors to create green corridors and reduce the effects of development along key routes.

This is being explored in more detail within action programming work being progressed as part of the 2 ^nd National Planning Framework.

Notes that an emphasis on brownfield sites may reduce biodiversity.

Agreed. This point in made within the SEA and in the SPP and is accounted for within the revised mitigation schedule.

Concerns expressed in relation to landscape quality and change. Agree with findings of assessment in terms of landscape impacts and notes that landscaping should form an integral part of planning for housing.

Support provision of additional guidance on landscaping of new developments. More could be done to deliver the aspirations of the European Landscape Convention ( ELC), and work with local greening bodies, BEFS and SLF.

Support inclusion of mitigation measures in finalised SPP.

Noted.

Recommendations have been made for further guidance on landscaping within the mitigation schedule and built into the SPP as far as possible.

Suggest reviewing extent of disused land that is not classed as derelict and vacant to identify opportunities for development that would provide environmental benefit. Housing could remedy this problem or merely push it further out to peri-urban landscapes where they meet rural areas.

Would also welcome more work to develop a better understanding of why land lies disused and how it can be brought into more productive use.

The repercussions of the policy proposals for derelict and vacant land is explored in more detail in the supplementary assessment ( Appendix 1). Further examination of disused land and the opportunities it presents for housing development should be explored in more detail within development plans and their associated SEAs. The need for this has been incorporated into the revised mitigation schedule. The SPP contains text on the use of urban capacity studies to inform development plans, and the efficient use of land and buildings including consideration of the value of sites for housing as well as other uses.

Cross referencing of environmental issues is acceptable but more could be done to highlight best practice. SPP could do more for urban biodiversity e.g. green roofs and open space planning. Acknowledge that this may be more appropriately covered by other SPPs - landscape and biodiversity often sit at the end of a long list of 'harder' priorities.

This has been done as far as possible within the SPP. Whilst it is agreed that best practice examples would be helpful, the SPP is not the appropriate place to explore best practice.

Would welcome more on urban biodiversity and open space uses.

The importance of open space in housing development is covered in paragraphs 77 - 79. This is also considered in more detail within SPP11.

Would like to see more acknowledgement of adverse effects of inappropriate development on the well being of the population including mental health.

The SEA and the supplementary assessment consider the effects of the proposed policy on population and human health. It is accepted that inappropriate development can have more negative effects on communities, but the mitigation measures and overall content of the SPP should provide sufficient scope to avoid these potential effects. The final SPP makes specific reference to the contribution well-designed places can make to safer environments which create opportunities for positive social interaction and healthier lifestyles.

Suggest further analysis of net loss of woodland to development.

This is generally considered further within Appendix 1. Previous analysis of land capacity for housing development suggests that this need not necessarily incur large scale loss of woodland. This issue would be more appropriately explored within development plans and their associated SEAs.

Concerns about the scale of development planned for Central Scotland.

Noted. Further analysis of the scale of the proposed development and its repercussions for the environment are provided in Appendix 1, although the SPP gives no specific policy direction that would necessarily lead to this issue arising. The analysis in Appendix 1 has led to a more detailed mitigation schedule which should limit adverse effects from the increased activity across Scotland.

City of Edinburgh Council

States that the SEA gives insufficient attention to the implications of the proposed approach of providing a 'generous' supply of housing land.

This has now been addressed in the supplementary assessment provided in Appendix 1.

East Renfrewshire Council

Questions some of the conclusions of the assessment and suggests that there may be more negative effects on living environments, sustainable settlement strategies, air quality, and efficient use of land and resources than is suggested in the findings. Also suggests more negative effects arising from New Settlements.

The supplementary assessment has confirmed the broader findings of the SEA with regard to the 35000 aspirational goal. Whilst it is agreed that some parts of the SPP could result in more negative effects, it is important to bear in mind that the SPP as a whole includes measures to ensure that increased housing development is delivered through a planned approach. These policy messages, together with the proposed mitigation measures, should substantially limit the potential negative effects raised by the consultees.

Justification for 35000 target is insufficient. Suggests that the SEA conclusions on the negative effects of the 35000 target means that this should be reconsidered.

This has been considered in further detail within the Supplementary Assessment of the 35000 goal ( Appendix 1).

Proposes making clearer reference to the SEA findings within the main body of the SPP.

This has been undertaken as far as possible within the finalised draft SPP. Some references are implicit, given the need for a focused SPP that does not repeat the findings provided in the SEA outputs, unless it adds value to the policy proposals.

Greenspace Scotland

Welcomes assessment and publication alongside the SPP.

Noted.

Notes that actual impacts will be heavily dependent on detail of local implementation of SPP3 through development planning and management. Argue for guidance and advice to support delivery of the SPP3 and promote positive environmental impacts - potentially a PAN or more detailed approach. Would be happy to work with SG and other stakeholders to develop guidance on open space.

This is provided as far as possible within the revised mitigation schedule. SPP11 Open Space and Physical Activity provides policy guidance on open space provision. The final SPP3 refers to the value of open space within housing areas. Further advice is available in existing Planning Advice Notes such as PAN 67 Housing Quality. The future dissemination programme for SPP3 may explore how this could be achieved.

Would like to see more specific assessment of open space and greenspace - e.g. in Table 5 of the ER but assume this was included as an implicit part of the assessment.

This formed an integral part of the assessment. Greenspace and open space issues have been addressed as far as possible, without unduly duplicating the policies provided in SPP11. The SPP refers to the importance of open space provision.

SPP3 should make stronger reference to the role of open space in climate change adaptation ( SUDS, shading, reducing wind damage etc.)

This has been built into the revised mitigation schedule as far as possible. The finalised SPP3 makes specific reference to environmental performance and design quality impacts on climate change.

Landscaping references should include clearer references to usable high quality spaces and creating new landscape settings (as opposed to current cosmetic approach to landscape).

This has been built into the revised mitigation schedule. Final SPP3 refers to the need to consider the wider context for new development including the protection and enhancement of landscapes and the wider environment.

Homes for Scotland

Agrees that the assessment has been comprehensive and that there are no major environmental barriers to the implementation of SPP3.

Noted. This is also confirmed as a result of the Supplementary Assessment ( Appendix 1).

Development plans should take into account environmental effects of delivering housing requirements set by SPP3 - there should be early inclusion and debate of environmental issues before it reaches the stage of individual applications.

Tools for achieving this are explained within the SPP, and are also provided within the revised mitigation schedule. Early engagement of key stakeholders in plan preparation (under the modernised planning system), a sustainable settlement strategy approach and consultation on SEA will address environmental effects.

Notes that only 3% of Scotland is urbanised and that the 35k target will only add to this by 1% over the medium term. This should be manageable in terms of environmental effects.

The SPP aims to emphasise the need for proactive planning to manage this in a sustainable way.

Effective master-planning will be key to managing environmental effects and delivering mitigation.

This is referred to within the revised mitigation schedule.

Planning reform will also be required to achieve mitigation measures.

The final SPP is drafted to remain relevant in the context of planning reform.

RTPI

Recommends also making reference to broader policy context explored in the SEA within the SPP as a tool for assisting the comparative assessment of sites.

Paragraph 54 of the SPP refers to the broad policy context and the importance of this in a sustainable settlement strategy approach to plan making (referring to Annex B which sets the policy context out in some detail). Further policies identified in the ER have not been incorporated in the interest of maintaining clarity and focus, but are implicit within the assessment of the SPP and remain available for reference within the ER.

Notes the importance of energy efficiency in housing design and the advice available from Architecture and Design Scotland on design

This was raised by a number of other consultees in their responses to the SPP (as opposed to responses specific to the SEA). The finalised SPP supports this as far as possible. Further measures to secure this are explored in the Supplementary Assessment ( Appendix 1) and incorporated in the revised mitigation schedule.

Scottish Property Federation

States that without further investment in infrastructure, there will be repercussions for the environmental assessment of SPP3.

Agreed. The Supplementary Assessment ( Appendix 1) includes further consideration of the infrastructure implications of the 35,000 goal.

Sustainable Communities Scotland

Fully support the findings of the assessment of HMO accommodation objectives. Note that guidance will require complementary action in order to be effective: propose integrating HMOs into the planning process.

Noted. Following consultation on the draft SPP, it has been decided to pursue the review of the HMO / planning interface separately. The final SPP3 contains policy on how local authorities should plan for HMO requirements.