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APPENDIX 1
PREDICTED EFFECTS ARISING FROM THE GOAL OF 35,000 HOMES PER ANNUM

A.1 Introduction - rationale for the further assessment

A.2 In their responses to the Environmental Report, the Consultation Authorities recommended that a more detailed assessment of the aspirational goal of delivering 35,000 houses per annum in Scotland should be undertaken. Whilst this had been addressed at a strategic level within the Environmental Report, the Consultation Authorities felt that a fuller exploration of the issues would provide a clearer picture of the likely effects of the goal, and therefore more specific and effective mitigation measures.

A.3 This Appendix sets out the findings of a supplementary assessment that was undertaken. The mitigation and changes to the SPP that emerged as recommendations from this part of the assessment have been incorporated into the overall findings from the SEA and form part of Tables 2 and 3 within the main part of the SEA Statement.

Background to the goal

A.4 SPP3 states that the planning system has a key role to play in facilitating the attainment of the Scottish Government's goal of building 35,000 houses annually.

A.5 The 35,000 goal is based on the Scottish Housing Market Review ² published by the Scottish Government in 2007, which concluded that not enough houses were being built and that housing supply was not sufficiently responsive to market conditions. House prices were 72% higher in 2006 than they were in 2002, while levels of new build increased by only 2%. The proposed goal of building 35,000 new houses a year reflects a range of analysis and evidence that were drawn together in the Review. The Review concluded that a substantial increase in housing supply could be sustained by the market and would have a significant impact on affordability. The 35,000 figure, an increase of 40% over current levels, is consistent with that. It is important to note that it is a broad goal, which aims to achieve a significant change in the level of house-building activity in the country. As a result overly quantified analysis of the environmental effects of the figure itself are not appropriate. Instead, this assessment focuses on the broad implications of the goal and identifies its potential environmental effects from a strategic perspective.

A.6 It is also important to bear in mind that although the goal emerged as a key policy proposal from Firm Foundations it was accompanied by many other aims and objectives, not least that housing should be appropriately designed and located: in other words, the Scottish Government emphasises the need to ensure that the right homes are built in the right places. There is strong support for a planning-led approach to housing provision, and this is underlined within SPP3. The majority of consultation responses to the Firm Foundations discussion paper supported the proposed increase in new housing provision (89%). However, some respondents felt that further discussion of the regional apportionment of the goal would be useful, whilst others suggested that more guidance on its distribution across housing tenures would be beneficial. Environmental stakeholders also expressed concerns about its potential environmental effects, and this was reinforced in their responses to the SPP3 consultation, including specific comments on the Environmental Report as detailed in the main text of this report.

Further assessment of the environmental effects of the goal

Effects on biodiversity

A.7 The SPP3 Environmental Report notes that the 35,000 goal could have adverse effects on biodiversity, including increased pressure on greenfield land and some semi natural areas, and fragmentation of habitat networks. Further examination of data on the characteristics of land which is potentially suitable for housing development allows for a clearer view on this.

A.8 Research undertaken for Communities Scotland ³ mapped the extent to which land had the biophysical capacity to accommodate housing development, based on consideration of factors such as soil conditions, slope and rockiness. Overall, this showed that there was 23,000 square kilometres of land with no biophysical constraints, accounting for 31% of the total area of land nationally. However, application of a number of additional 'socio economic development constraints' to this total further reduced the amount of available land. Key constraints included: prime agricultural land, nature conservation designations, greenbelts, woodlands and proximity to infrastructure. More detailed modelling focusing on one local authority area (Fife) showed that half of the land with no biophysical constraints was prime agricultural land, although the researchers acknowledged that this pattern may not be the same in other areas. Overall the mapping showed that woodland was the most significant constraint, whilst nature conservation designations had the least impact on the effectiveness of housing land supply. With regard to the latter, 85% of land which is designated overlaps with land which is constrained on the basis of its biophysical characteristics.

A.9 Of the land identified as being most suited to development for housing on the basis of its biophysical condition, only 2.7% was within a nature conservation designation, and this was confined to a few local authorities: Aberdeenshire, Highland, the Scottish Borders and Perth and Kinross. Proportionately, nature conservation designations were the biggest constraint for only a small number of predominantly rural local authority areas. This therefore suggests that, from a national perspective, the level of risk to designated sites is relatively low.

A.10 For the majority of local authorities, woodland was found to be the biggest potential constraint, but the research also showed that for a small number of local authorities the most significant socio-economic constraint to housing development for some local authorities, taking into account biophysical limitations, was likely to be the green belt designation. Approximately 5% of the land most physically suitable for housing development was within a green belt, suggesting that "unless land supply for development can be provided by 'brownfield' sites, then it can be expected that there will be pressure on local authorities to relax greenbelt restrictions, or development will be displaced to neighbouring authorities." Infrastructure availability (as tested by using proximity to a metal road as a surrogate measure) was expected by the study to be only a very minor factor influencing land capacity.

A.11 Whilst these data give a very broad measure of national physical capacity for housing development, it is important to recognise that this accounts for only a limited number of conditions and constraints. A range of other factors could reduce scope for housing development, including flood risk, proximity to designated areas (e.g. areas that form the setting of historic sites), semi natural habitats, minerals deposits etc. However, it is reasonable to conclude that whilst designated sites are unlikely to experience a particularly significant level of pressure for housing development, accessible rural areas close to existing large settlements (i.e. green belts and similar areas) could experience a disproportionate growth in demand, as more remote areas may be less physically suited to development and subject to a greater number of other constraints including nature conservation designations, prime quality agricultural land, woodland cover and infrastructure availability.

A.12 Therefore, whilst it is not possible to conclusively rule out adverse effects on biodiversity, it is nevertheless reasonable to expect that the scale of development proposed should be deliverable in a way which avoids significant adverse effects on designated nature conservation sites. Effective planning at the strategic and local development plan level, as recommended within the SPP, should ensure that less formally protected areas and species are taken into account when identifying appropriate sites for housing development. The emphasis on a more proactively planned approach which underpins the SEA as a whole should support delivery of this mitigation.

A.14 Further consideration of the effects of the goal on soils and the use of brownfield land (see below) also shows that there may be greater pressure on greenfield land for housing development in the longer term as a result of the growth arising from the 35,000 goal. However, given that brownfield land can have as much if not more ecological value as some greenfield sites, this is not expected to directly lead to significant effects on biodiversity, flora and fauna. As both brownfield and greenfield land can sustain semi natural habitats, mitigation should focus on the biological value of sites and proactively provide a long term approach to development that prioritises sites with least natural heritage value (amongst other criteria). This would help to reduce incremental loss of these habitats to urban development. Combined with mitigation that enhances biological networks, there is scope for positive effects to be delivered through habitat restoration delivered as part of planning.

A.15 Furthermore, positive planning for housing that incorporates and strengthens green networks could ensure that future settlement growth provides benefits for biodiversity. There are opportunities to achieve this through open space strategies, development plans and Section 75 agreements for greenspace provision that are targeted to deliver wider green network objectives.

The findings of the broader assessment are confirmed by this further review. However, more detailed mitigation measures should note the importance of effects on non designated biodiversity resources, as well as protecting those which are already formally recognised (Measures 1, 3, 4 and 6 in Table 3 - Mitigation Schedule). Mitigation should also deliver habitat restoration and improved ecological networks as an integral part of sustainable settlement planning (Measure 3) and strengthen references to open space and green network provision (Measure 5). It will also be important for local authorities to keep an open mind on the ecological value of sites when comparing brown and greenfield sites for development (Measure 7).

Effects on population and human health

A.16 The Environmental Report showed that the SPP as a whole should contribute positively to the well-being of the population. No negative effects were anticipated from the SPP including the 35,000 goal. The SEA concluded that the SPP as a whole would provide minor benefits for health, but also showed that the increased levels of housing development result in minor negative secondary effects, arising from some of the more immediate impacts of a growth in construction activity.

A.17 Whilst are considered to be valid and justifiable conclusions, it is useful to explore this relationship in more detail and to confirm that in-built mitigation should suffice to avoid secondary negative effects on the population.

A.18 Housing conditions can contribute to deprivation, whilst low income and poor health can limit housing choices. Around 880,000 people live in poverty in Scotland (defined before housing costs), around 18% of the total population. Of this total, around 9% are in 'persistent poverty', as they have been classed as poor within at least three of the past four years. Although levels of poverty have fallen by around 10% in the last 10 years, tackling poverty remains a priority. 47% of people in poverty own their own home, but recent figures also show that the risk of poverty is significantly higher for those who do not. In 2006/07 around 40,000 households in Scotland were homeless. ⁴

A.19 The baseline analysis included in the Environmental Report provided an overview of the Scottish Index of Multiple Deprivation ( SIMD), and noted that there are concentrations of deprivation within the central belt and urban areas of Scotland. More detailed consideration of the changes in deprivation between the 2004 and 2006 SIMD data shows that Glasgow, North and South Lanarkshire experienced a relatively large decrease in their share of deprived areas (defined by data zone), whilst the share has increased in Fife, Aberdeen, Highland and Inverclyde during the same period. In terms of local authority proportions, Glasgow City accounts for 48% of the most deprived areas, followed by Dundee (30%), West Dunbartonshire (28%), Clackmannanshire (23%) and North Lanarkshire (20%). Eilean Siar, Moray, Orkney Islands and Shetland Islands do not have any of the 15% most deprived data zones, although this may be due to more diffuse patterns of deprivation within these areas, as opposed to the complete absence of the issue.

A.20 The compendium of statistics used to define the SIMD allows for more detailed consideration of the pattern of deprivation as defined by the housing domain. ⁵ This shows that more than half of the 15% most deprived households defined on the basis of housing were in Glasgow, followed by Edinburgh (18.1%), Dundee (8.8%) Aberdeen and Renfrewshire (both 4.2%), North Lanarkshire (3.1%),South Lanarkshire (3.0%), Inverclyde (2%) and West Dunbartonshire (1.5%). All other areas accounted for less than 1% of the total number of households within the most deprived 15% nationally. Ten areas had no share of the most deprived households in terms of housing, ranging from accessible rural areas (e.g. West Lothian) to remote areas such as Shetland. However, it is important to note that this part of the SIMD is based on 2001 census data and requires updating.

A.21 The Scottish House Condition Survey continually monitors key indicators of housing quality. Estimates of levels of overcrowding suggests that this is an issue for around 4% of Scotland's total housing stock, with North and South Lanarkshire, Glasgow, Aberdeen, Inverclyde, Midlothian, Morayshire and Perth and Kinross all exceeding this level. ⁶ Based on five criteria of (1) above the tolerable standard, (2) free from serious disrepair, (3) energy efficient, (4) modern facilities, and (5) healthy safe and secure, 69% of Scotland's households failed to meet quality standards in the 2003-2006 period. ⁷ Particularly low levels were recorded in some of the most remote parts of Scotland: Eilean Siar (83%), Shetland (87%) and Orkney (80%), whilst the lowest levels of 'failed' dwellings were found in West Lothian (54%) and Aberdeen (59%). Further details on the energy efficiency component of the SHCS are set out in below.

A.22 These data confirm that poor quality housing is a nationally significant issue that has direct implications for social wellbeing. A significant increase in the new, higher quality housing which is available is likely to contribute positively to the criteria that aim to reduce social exclusion and increase housing supply and choice, including opportunities for affordable housing.

A.23 Although the SEA baseline notes overall health issues, there appear to be no comprehensive or up to date data linking poor health and housing conditions. A review of research evidence in 1999 ⁸ showed that although there is a correlation between poor housing and ill health, the evidence that demonstrates that one contributes to the other is limited. Research does, however, show that highest risks to health in housing arise from cold, damp and mouldy conditions, although the strength of evidence supporting this is inconsistent. Some links have been established particularly between reported illness, including respiratory problems, aches and pains, nerves, diarrhoea, headaches and fever in children, and dampness and mould in their homes. Furthermore, higher rates of winter death are link with cold conditions and other physical and mental health problems can arise from poor air quality in housing, lead water piping and overcrowding.

A.24 These data broadly support the suggestion that an increase in housing options and provision of new housing which is more likely to be insulated, heated and in better condition overall, could have positive effects on health. There appears to be no specific evidence that environmental impacts of new housing development can significantly affect health. The SPP is likely, however, to do more to positively contribute to the SEA criterion that focuses on designing housing areas that encourage higher levels of physical activity, and the scale of new development would mean that there may be significant opportunities to achieve this in many locations. As a result, and in response to comments from a number of stakeholders on this issue, the mitigation schedule has been developed further to emphasise the scope to achieve this within development plans.

The findings of the broader assessment are therefore confirmed. However, further mitigation / enhancement that aims to increase the contribution of housing to the health agenda have been proposed (Measures 9 and 10 in Table 3 - Mitigation Schedule).

Effects in relation to climatic factors

A.25 Overall, positive effects were expected from the SPP as a whole in relation to climatic factors, ranging from improved energy efficiency to its broader support for local authorities in defining sustainable settlement patterns which take climate change into account. However, the assessment also showed that the 35,000 goal could lead to negative effects as the overall number of households, and therefore energy consumed, will grow. The SPP makes reference to the need for energy efficiency in domestic properties and emphasise the need for flexible living environments which should reduce resource consumption over the long term. However, the SEA also suggested that greater support could be given to domestic microrenewables. This has now been incorporated into the finalised draft.

A.26 A more detailed baseline provides a further insight into the potential effects of the 35,000 goal specifically. The Scottish House Condition Survey ⁹ examined the energy efficiency of housing in Scotland for 2005-2006. It showed that more than two thirds of Scotland's homes were estimated to have failed the national quality standard, a decrease from 2002 (77%). Most of those that failed did so on the grounds of poor energy efficiency, as this requires full efficient central heating and thermal insulation. Based on the National Home Energy Rating Scale, the survey showed that 47% of dwellings achieved good energy efficiency ratings of 'good' or better. Only 4% were given a rating of 'poor' and 48% were classed as 'moderate'. This represents an improvement from 2002, where only 31% achieved a good rating. However, there has been a more significant improvement in energy efficiency rating of public as compared to private sector housing stock. 14% of private rented dwellings are rated poor, compared to an average of 4% across all sectors. In addition, flats had higher energy ratings than houses, with the majority of the former being rates as good, compared with less than a third of detached and semi detached houses (due to the latter's higher surface area of external walls). The survey also showed that newer homes were more energy efficient than older homes, with less than one percent of those built after 1982 having a poor rating, compared to around 10% of those constructed before 1919. Urban homes were twice as likely to be rated as 'good' than rural homes, and much less likely to be rated as 'poor'.

A.27 It would therefore be reasonable to assume that an increase in new build housing could contribute positively to the proportion of the housing stock which is considered to be energy efficient, and these positive effects could be enhanced by the further measures within the finalised SPP to improve energy efficiency overall.

A.28 Fuel poverty is a national issue: the number of fuel poor households declined from around 36% in 1996 to 13% in 2002, but rose again by 2005/6 to 23.5% of households, partly due to changing fuel prices. 7.5% of households were considered to be in 'extreme fuel poverty' in 2005-2006, needing to spend more than 20% of their income on fuel. These figures are likely to increase in light of recent fuel price rises. Fuel poverty is linked with energy efficiency ratings, as well as being determined by income level and occupant status. As a result, an increase in housing stock which is more energy efficient could make a partial contribution to the fuel poverty agenda, as suggested within the initial assessment of the SPP.

A.29 The Scottish Government also recently consulted upon proposals for permitted development rights for domestic microrenewables, and this was subjected to an SEA. This explored the potential gains of installing renewable energy equipment on homes in terms of reducing emissions, and identified potential secondary effects on the wider environment. The assessment concluded that the proposed permitted development rights could make a positive contribution to the overall environmental goals without significantly impacting on the wider environment, subject to appropriate mitigation and monitoring.

The findings of the broader assessment are therefore confirmed, particularly in light of the enhanced references to energy efficiency which have been built into the finalised SPP. As now referred to in the SPP, further mitigation could be achieved within development plans, particularly if they take forward the recommendations within the Sullivan Report and these would be supported by wider initiatives including permitted development rights for domestic microrenewables. This is reflected in Measures 11- 14 of the Mitigation Schedule (Table 3).

Effects on air quality

A.30 The Environmental Report showed that the 35,000 goal could have positive or negative effects on air quality, depending on the location of development proposals. As a result, mitigation measures were proposed, including an overall approach which reduces levels of unsustainable travel by promoting development in areas which are accessible by public transport.

A.31 The SPP3 ER notes that air pollutant concentrations vary in different parts of Scotland as a result of difference in climate and geography. Further consideration has been given to whether attaining the proposed 35,000 goal might exacerbate existing problems or lead to new air quality issues in areas where no AQMA has been declared. This has shown that, overall, problems tend to be concentrated in the Forth and Clyde lowlands, and Air Quality Management Areas ( AQMAs) have been designated in Aberdeen, East Dunbartonshire, Edinburgh, Falkirk, Glasgow, North Lanarkshire, Renfrewshire, Dundee, and Perth and Kinross. With only one exception where pollutants originated from industrial activity (Grangemouth), transport is the source of air pollution that has led to these designations. The table below shows AQMAs that have been designated in Scotland to date:

Source: www.airquality.co.uk/archive/laqm/laqm.php as set out in SEPA (2006) State of Scotland's Environment.

A.32 The proposed emphasis on infill and brownfield land development and the associated assumption that a large share of future construction activity will arise within urban areas could have implications for many of these existing AQMAs. Furthermore, the support for higher density development could exacerbate existing air quality issues, including in many of these areas where AQMAs already exist. Given that existing problems are primarily transport related, planning authorities need to prioritise developments in areas which are accessible by public transport, walking and cycling routes, to ensure that housing additions form an integral part of more sustainable settlement patterns. No development should be permitted which would substantially increase car use in areas which are close to existing AQMAs.

The findings of the broader assessment are therefore confirmed, but it is accepted that in some areas, significant air quality issues may arise depending on the sensitivity and effectiveness of settlement strategies and spatial planning for housing growth. Consequently, additional mitigation should be taken forward. Air quality should be recognised as a key factor within the process of selecting land for housing development, and local authorities with AQMAs should pay particular attention to the potential effects of housing proposals in their vicinity. (Mitigation Measure 15 in Table 3).

Effects on soil

A.33 The SEA suggested that SPP3 will have negative effects on soil, primarily due to soil sealing arising from the higher levels of development of housing on previously undeveloped land. The Environmental Report noted that this could have secondary impacts on other environmental resources, such as the water environment.

A.34 The actual effects of the increase in housebuilding will very much depend on location decisions which are made at a more local level. Whilst this cannot be identified at this stage as it will be largely dependent on local level proposals in development plans, it is possible to broadly consider the extent to which new development could be accommodated on brown or greenfield land from a national perspective.

A.35 The 2007 vacant and derelict land survey ¹⁰ showed that there were 10,401 hectares of vacant and derelict land across Scotland. Of this total, 5,778 hectares were within a settlement of more than 2,000 residents, 509 were in a settlement of less than 2,000 residents, and 4,114 were in the countryside. This is clearly a very uneven distribution, as around half of all brownfield land is located within larger towns and cities, but only 3% of the total land mass is classified as urban. ¹¹ If all of the additional housing was built on brownfield land, and no further additional brownfield land was to become available in the same period, based on an average housing density of 25 houses per hectare, there is potential for derelict and vacant land to be depleted within the next ten years. ¹² However, the overall supply of brownfield land is not static, and is likely to continue to grow as a result of dereliction, demolition and land use change more generally, as well as being reduced as a result of redevelopment. It is therefore expected that there would remain scope to develop a large proportion of housing on brownfield land into the long term future, but there is also a need to recognise there may be a growing need for managed release of greenfield land particularly in parts of Scotland where brownfield land is in short supply.

A.36 A more rapidly diminishing supply of brownfield land will have different implications for different parts of the country, depending on existing levels of land which are available. The spatial distribution of existing brownfield land suggests that a larger proportion of planned housing development could be accommodated on urban brownfield land as compared with rural areas. In rough proportions, there would be the smallest amount of this type of land available in rural settlements, around eight times this amount in the countryside, and the most within urban areas (approximately 50% more than the amount available in rural areas). This is based on current vacant and derelict land figures and ratios.

A.37 Analysis of data ¹³ on the level of greenfield land that has been developed demonstrates further spatial patterns. The proportion of greenfield land used for new housing has generally declined in urban areas including Aberdeen, Dundee, and Glasgow, but has increased in the City of Edinburgh since 2001. There has been a similar pattern of reducing levels of greenfield development in some rural local authority areas including Dumfries and Galloway, and Highland but overall the use of greenfield land in rural areas accounts for a much greater proportion of all housing completions. There has been an increasing level of greenfield land take for new housing development in some rural areas, such as Orkney and consistently high levels in others, including Eilean Siar. Comparative figures for brownfield site development for housing show that there has been a rise in rates of this type development since the late 1990s in all of Scotland's cities, with the exception of the City of Edinburgh, where rates have broadly declined, with a small increase between 2005 and 2006. In the other cities, there has been a greater increase than has been experienced in Scotland as a whole, probably reflecting the greater availability of this type of land within large cities. In contrast a more variable pattern of brownfield land development for housing appears to exist in rural areas, with an increase followed by decline in Orkney since 2003, and more consistent growth in Dumfries and Galloway. With the exception of Orkney in 2003 and East Lothian in 1998 and 1999, rural areas have taken up lower levels of brownfield land than the overall national average level of activity during this time period.

A.38 This variation in capacity to accommodate new housing development on brownfield sites means that a creative approach to sustainable settlement planning is required particularly in rural areas, which could continue to prioritise brownfield land but which also allows for the managed and sustainable release of greenfield sites to accommodate development. Supporting this, several consultees emphasised the need to ensure that the definition of brownfield land was extended to also take into account opportunities to make use of disused land in rural areas. The finalised SPP has been amended to reflect this.

The findings of the broader assessment are therefore confirmed, but additional mitigation has been built into the SPP and taken forward within development plans. This includes recognition that brownfield sites may not always be available to accommodate rising levels of housebuilding, particularly within rural areas, and consequently mitigation should ensure the value of these areas is fully understood in relation to overall patterns of sustainable settlement expansion (Measures 8, 19, 20 and 21). Mitigation which has been built into the SPP also aims to address the predicted effects of new housing development on soil (Measures 22, 24 and 25). Furthermore, local authorities should bear in mind the need to continue to protect prime agricultural land from development, given its role as a service provider for the food industry (as reflects in Measures 8 and 23).

Effects on water

A.39 The SEA concluded that the water environment could be adversely affected by the overall increase in housing land supply and development that is promoted by the Consultative Draft SPP. It suggested that the SPP could go further to limit further adverse effects such as diffuse pollution, and that some aspects of it, including the 35,000 goal, could potentially be at odds with the measures proposed in the forthcoming River Basin Management Plans in the longer term.

A.41 SEPA provides analysis of the current state of water bodies in the Scotland and Solway-Tweed River Basin Districts, as part of the preparation of River Basin Management Plans. ¹⁴ This shows that overall one third of water bodies will not reach the required 'good ecological status' by 2015. As noted in the ER for SPP3, mapping of the sources of pressure on water bodies shows that diffuse source pollution from urban development is an issue for Scotland's urban areas, leading to environmental problems such as pollutants in watercourses, and the release of herbicides killing aquatic plant life.

A.42 As stated in the ER, increased levels of development are likely to add to existing problems of diffuse pollution as a result of urban development. As a result, SUDS were proposed as a mitigation measure to reduce this pressure in new areas of development.

A.43 There is also potential for increased flood risk for existing and new properties arising from an increase in overall rates of development. SEPA's indicative flood risk maps, and the Scottish Government's analysis of the implications of this for properties in Scotland, provide local authorities with a useful reference point for determining this. An estimated 100,000 properties are currently located on fluvial or coastal flood zones, with particular risks arising in Glasgow where 11,749 properties are within the river flood zone, and in Falkirk where 6,000 properties are at risk of coastal flooding. ¹⁵ Whilst a substantial increase in new housing development has the potential to add to this problem, existing mitigation measures should ensure that appropriate locational decisions are taken by local authorities. The full policy on planning and flooding is already provided in SPP7, ¹⁶ which notes that new development should not take place if it would be at risk of flooding, materially increase flood risk elsewhere, require additional flood protection, undermine the functional flood plain or interfere with the flow of water within it or compromise future options for shoreline or river management. It also notes that the redevelopment of brownfield land may be acceptable where built up areas already benefit from flood defences, but greenfield proposals are likely to extend urban cover and therefore flood risk. As noted in SPP7 it will be important for local authorities to bear in mind that flood risk may increase in some areas over the long term as a result of climate change, and to take longer term projections of flood risk into account in determining the suitability of proposed land allocations for housing developments. This policy framework is expected to be sufficiently robust to ensure that realisation of the 35,000 goal does not exacerbate flood risk. Consideration of the implications of long term settlement expansion at a catchment wide scale will be important in light of the potential cumulative effects arising from the increased scale of the development proposed.

A.44 New housing development generates demand for water supplies, drainage and sewage capacity. Detailed assessment of capacity, based on projected growth as well as available capacity and anticipated investment, is provided within Scottish Water's Strategic Asset Capacity and Development Plan. There has been a general erosion of treatment capacity across Scotland, due to a combination of tighter regulation, population shift and increasing demand. As a result, some places have experienced restrictions on new development until additional capacity comes on-stream. SEPA works with Scottish Water to continually manage the environmental effects of increased use of available infrastructure and treatment works (partly arising from new housing development), to avoid exacerbating associated pollution and highlight where investment is required. ¹⁷ Scottish Water sets out anticipated demand for infrastructure capacity arising from planned development within its Quality and Services Programme, and there is now a requirement for developers to contribute to any additional need for capacity upgrades. As a result of this rolling programme, it is now thought that there should now be no constraint on development or growth arising from a lack of water infrastructure capacity.

A.45 In addition, point source pollution arising from sewage waste is an issue that is exacerbated by the age and limited capacity of many urban sewerage systems. Additional housing development of this scale has the potential to contribute to this issue, although the River Basin Management Plan Significant Water Management Issues Report also notes that Scottish Water has had funding since 2006 to provide strategic capacity to accommodate growth at water and sewage treatment works. Whether or not the improved capacity identified above would encompass the additional growth proposed in Firm Foundations remains unclear, and so there will be a need for development plans to consider links with water supplies, drainage and sewage treatment capacity and infrastructure as an integral part of sustainable settlement planning. This is noted within the SPP which supports a collaborative approach to site selection which takes into account issues extending beyond the immediate remit of the planning system.

A.46 Abstraction and flow regulation for water supplies also affects water bodies throughout the country. In addition, morphological change arising from historical engineering and urban development affects many water bodies in the Central Belt and North East, with SEPA continually aiming to reduce problems arising by restoring water bodies to their natural state where possible. A substantial increase in rates of housing development has the potential to further increase demand for water supplies, with associated environmental impacts on ground and surface water bodies.

The findings of the broader assessment are confirmed, but it is suggested that further mitigation is built into the SPP and taken forward within development plans. This could be achieved by:

• noting the need to take into account cumulative effects on water bodies and provide a fuller assessment of the capacity of water infrastructure (Measure 16 in Table 3).
• reviewing incremental, cumulative, direct and indirect effects of housing developments on long term flood risk, taking into account climate change (Measure 17).
• improving references to SUDS within new housing areas (Measure 18).

Effects on Material Assets: Waste

A.47 There has been a continuing rise in household waste generated in Scotland. In 2005/2006, 2.89 million tonnes of household waste arose in Scotland. ¹⁸ An average Scottish household produces 1,197kg of waste annually, an increase of 2% from the previous year. A large proportion (865kg) is landfilled at present. The National Planning Framework Discussion Draft (2008) notes that at present there is capacity to divert around 1 million tonnes of municipal waste from landfill, and that this will need to be increased to around 1.5 million tonnes by 2010, more than 2 million tonnes by 2013 and by 2.5 million tonnes by 2020.

A.48 Further capacity is required to treat commercial and industrial waste. In 2005/2006, 10.60 million tonnes of construction and demolition waste were generated, a significant proportion of the 22.22 million generated for Scotland as a whole. ¹⁹ In 2005, the highest proportion of construction waste was generated and handled in the Glasgow and Clyde Valley waste strategy area (4.36 million tonnes), followed by Lothians and Borders, (1.3 million tonnes), North East and Fife (both accounting for just over 1 million tonnes each). The house building sector is estimated to account for around 30% of the total construction industry in Scotland. ²⁰ Providing that similar proportions of waste are generated across construction sectors, this suggests that current rates of house building account for 3.18 million tonnes of waste annually.

A.49 SEPA sets out mitigation measures for minimising construction waste in its 'Small Environmental Guide for Construction Workers. ²¹ This includes building this into contractual arrangements as far as possible, efficient use of ordering materials, reuse of materials, use of recycled materials, using appropriate materials and dimensions, off-site prefabrication, good practice in materials and handling storage, efficient waste management with good on-site segregation, waste auditing and monitoring.

The mitigation schedule has therefore been reviewed and supplemented with further recommendations that the waste management implications of the creation of a large number of new homes are proactively planned for. Measures can range from the local level (provision of on site recycling facilities - Measure 27) to more strategic commitments including taking long term growth into account within local authority plans for additional waste management facilities (Measure 28). Management of construction waste should also be considered at the consenting stage (Measure 29).

Effects on Material Assets: Minerals

A.50 As mineral resources are finite, planning policy seeks to ensure that development they are not sterilised by development. Increased supplies of aggregates will be required to deliver the increase in housing provision, thereby adding to the need to safeguard resources. SPP3 specifically refers to the need to safeguard mineral resources within the site selection process and cross references to SPP4, which provides further guidance on the most important resources to be safeguarded.

A.51 The British Geological Society ( BGS) has produced online maps of mineral resources in Central Scotland. ²² This shows significant deposits of peat and silica sand within the Central Belt, at times close to existing communities and main transport routes, for example a seam of silica sand running north east from Glasgow to Falkirk, and from Alloa southwards as far as Motherwell. There are clusters of peat in North Lanarkshire, West Lothian, East and South Ayrshire, Dunbartonshire and Inverclyde, covering largely upland areas but also extending into lower lying areas between Glasgow and Edinburgh. As these resources should be safeguarded from sterilisation by development, there will be a need for careful planning and site selection to ensure this is achieved. This in turn could place further pressure on other areas for development in order to accommodate the aspirational goal.

A.52 In addition, local authorities should be aware of the increased demand for minerals that will arise as a secondary effect of the increased level of house-building. Based on an estimate of 200 tonnes of aggregate that would be required per house built (60 tonnes per house, with the remainder being used to construct access roads, services etc.), around 2 million tonnes of additional aggregate may be required annually to meet the increased level of house-building. At present between 30 and 35 million tonnes of crushed rock and sand and gravel are produced annually in Scotland, with an increasing proportion being secondary or recycled aggregates (currently around 18%) and around 5 million tonnes being exported. ²³ As a result, the growth in demand from the house-building sector may be around 6% higher in future years. This should be taken into account by local authorities who have responsibility for minerals planning and there will be a need for further local level environmental mitigation where additional materials are being extracted. Demand for additional minerals in the Central Belt is likely to be high given that a large proportion of additional housing is likely to be constructed close to Scotland's key urban areas. This could therefore contribute to existing pressures in some areas where local sourcing of aggregates is more difficult (particularly East Central Scotland) and currently consented reserves are unlikely to be sufficient to meet growing demand over the long term.

The mitigation schedule has therefore been amended to emphasise the implications of the increased level of house-building for the safeguarding of mineral resources and sustainable production of minerals in close proximity to future sources of demand (Measure 26).

Effects on cultural heritage

A.53 The Environmental Report showed that the goal would have adverse effects on cultural heritage, noting that the increased requirement for housing land could result in loss of or damage to archaeological remains. Wider effects on historic townscapes and the setting of listed buildings were also expected to require appropriate mitigation through the planning system.

A.54 Further baseline evidence, gathered to inform the SEA of SPP23 Planning and the Historic Environment, ²⁴ shows that the condition of many historic sites vary, with around 14% of Scheduled Monuments either in unsatisfactory condition or having extensive significant problems and an estimated one third of recorded sites being at immediate or longer term risk. As a result, effects on these and other historic sites could be significant, if they were to cumulatively exacerbate problems with their condition. To provide an insight into the potential scale of development that would have implications for the historic environment, of 50,049 planning applications in 2005-06, 7% also involved listed building or conservation area consent (of which 92% were granted). Based on an estimated 17% of applications which relate to new dwelling houses (including those for both outline and full planning consent), ²⁵ it is expected that around 8500 applications annually could be for housing developments, with some 595 requiring conservation area or listed building consent. If the total number of applications for housing were to increase by around 40% to reach the 35000 goal, then a further 238 applications of this nature might be expected annually. A further number would have implications for other designated sites and non designated sites and areas.

A.55 Further consideration of the goal in relation to this baseline suggests that, although these effects may be cumulatively significant, they should be manageable through the protection and mitigation that the planning system already seeks to deliver. However, it will be important for local authorities to give careful consideration to the potential impacts of housing developments on the historic environment. Although SPP3 supports brownfield redevelopment in order to minimise greenfield land take, sites within settlements which have been previously developed could have particular value within their broader townscape setting, and as a result of the potential for unknown or unprotected archaeological remains to be disturbed or lost as a result of development. In addition, pressure on the edges of existing settlements could have implications for the overall historic character of many towns and cities, and has the potential for further effects on other cultural heritage resources, such as gardens and designed landscapes.

A.56 It is important that housing site selection gives as much consideration to the known and unknown cultural heritage value of a location, as it does to the often more obvious natural heritage assets. In addition, new housing development should not be allowed to have significant adverse effects on designated sites and buildings, in accordance with wider planning policy on the historic environment.

The findings of the assessment are confirmed, but it is also noted that the goal of 35,000 homes could lead to significant cumulative pressure on cultural heritage, given that brownfield land can have as much historic value as greenfield sites. The SPP's emphasis on accessibility implies that much development will be located in and around existing settlements, with implications for townscape character and the setting of historic sites and buildings in and around urban areas. Capacity analysis, undertaken to inform housing land allocations, should take these sensitivities into account. Further mitigation includes high quality design and avoidance of loss or damage to protected historic sites, buildings, townscapes and landscapes (Measures 30, 31, 32, 33 and 34).

Effects on landscape

A.57 The Environmental Report shows that there would be cumulative and negative effects on landscape arising from housing development. Issues include loss of distinctiveness and character as a result of the homogenous design of new housing developments.

A.58 It is not possible at this stage to fully define the landscape effects of a substantial increase in housing development. However, it is useful to give further consideration to the scale of environmental problems arising from this type of activity at the moment. The Scottish Landscape Forum ²⁶ highlighted several key issues for Scotland's landscapes, including the poor settings of urban and peri-urban communities, loss of diversity in the landscape and dilution or erosion of distinctive character, generally poor standards of design, decline and loss of natural and cultural heritage features; attrition of undeveloped, remote and wild countryside, and coasts, and the erosion of the rural character of Lowland Scotland. These pressures vary between different landscape settings. SNH undertook analysis of its national series of Landscape Character Assessments in 2001. This highlighted the type of change which is occurring in different landscapes.

A.59 The SPP3 Environmental Report noted the ways in which Scotland's landscapes are evolving, and reflects on the Settlements prospectus within the Natural Heritage Futures Series which emphasises the influence of "nationally homogenous stand-alone housing" on landscape quality. It also identifies several key trends arising from development, including high density housing developments, settlement consolidation and amalgamation, growth of smaller rural and suburban settlements (particularly within commuter areas) and more housing in the countryside.

A.60 Closer examination of SNH's natural heritage trends information shows a number of changes to landscape arising from housing and related development:

• Major urban expansion confined to lowland farmland and the coast;
• Village expansion and incremental edge-of town development;
• New single houses in the countryside;
• Farm steadings falling into dereliction and converted to residential new uses in lowland farmland;
• Alteration of landscape character due to inappropriate siting, design or building materials in new developments;
• Loss or decline of historical / archaeological features in farmland, coastal and urban settings;
• Incremental road improvement in all settings, with new main road / bridge construction associated with fresh water and coastal settings; and
• In the fresh water setting, reservoir and water supply infrastructure, and hydro-electric power schemes.

A.61 In terms of spatial patterns, residential development was identified as a major pressure within the West Central Belt, Eastern Lowlands, Border Hills, North East Glens, and North Caithness and Orkney.

A.62 Whilst this assessment cannot predict the spatial distribution of the 35,000 goal overall, it is reasonable to conclude that a large proportion will add to existing pressure on landscape from residential development in the West Central Belt and Eastern Lowlands. There will therefore be a particular need to consider how the landscape of these areas can accommodate increased housing development, without experiencing further, potentially significant erosion of landscape character. The Natural Heritage Prospectus for the Eastern Lowlands ²⁷ notes that there has been a 39% increase in the area of built land and transport corridors since 1950 and that this has been supplemented with increased demand for aggregates locally, with the resulting extraction of materials generating further environmental effects. Similarly, the West Central Belt has experienced substantial levels of development, but much of this has taken place on vacant and derelict land which arose from industrial decline. ²⁸

A.63 The West of Scotland Prospectus also states that in the last 60 years there has been almost a 50% increase in the land required for settlements in Scotland as a whole. This is a long term trend, and it is unlikely that the current goal of increased housing building would be extended over such a period to lead to a significantly higher level of pressure. However, it is important to recognise that spatial patterns of development have led to major changes in the character and setting of settlements, and the wider countryside which has been eroded in some areas as a result of increased commuting and demand for rural dispersal of more urban populations. As a result, careful siting and design of new housing is required to reduce fragmentation of greenspace and loss of local distinctiveness from some built developments and this will be particularly important in and around the Central Belt.

The findings of the assessment are confirmed, but it is also noted that the proposed goal of 35,000 could lead to significant cumulative pressure on some landscapes, particularly those within the Eastern Lowlands and West Central Belt, where levels of development have been high over the past 50 years, and considerable settlement expansion has already taken place. As a result, mitigation measures are proposed including continuing to give consideration to landscape capacity as part of settlement expansion strategies (Measure 35), using masterplanning and design to deliver achieve quality places and better integration of new housing with the wider environment (Measures 36 and 37), landscaping and links with green networks (Measure 38). These measures will be particularly important within the areas referred to above, where pressure for housing development may have the most significant landscape and visual impacts.

Cumulative and synergistic effects arising from the goal

A.64 This analysis has highlighted a range of potential environmental effects, and has noted the influence which the goal of 35000 homes per annum may have on these effects. Whilst it is not possible to define significant cumulative effects spatially, as this will be dependent on local level interpretation of the goal and land allocations delivered through development plans, it is possible to highlight the following potential cumulative and synergistic environmental effects:

1. The goal could have cumulative effects arising from a continuing focus on brownfield land for development. This could include loss of or damage to biodiversity which is concentrated on vacant and derelict land, cultural heritage resources (designated and non designated) particularly associated with formerly industrial or developed areas, and landscape, including greenspace resources. It is important that local authorities give careful consideration to the implications of this, and ensure that development of brownfield land within settlements in undertaken in a sustainable and sensitive way. Mitigation measures provided within the Mitigation Schedule and now integrated into the SPP, including the creation of additional areas of open space as an integral part of development and sensitive siting and design, could help to address these cumulative effects.

2. It is unlikely that all of the housing land requirements will be met on brownfield land. Given the emphasis within the SPP, there may be particular issues arising for the environments around settlements (green belt and other urban fringe areas) and land around existing transport corridors. These areas will also require careful consideration, recognising their importance in forming the landscape setting of settlements and their sensitivity as a result of the incremental change which has taken place over a long period of time.

3. There is potential for synergistic effects arising from impacts on the water environment, together with increased levels of soil sealing. This may manifest itself as a significant increase in flood risk in some areas which requires mitigation, and there are also likely to be cumulative impacts on biodiversity arising from substantial alterations to existing ecosystems. This multifaceted environmental change requires careful environmental management to be delivered by the planning system in collaboration with environmental organisations. Collaborative working to deliver housing in a sustainable way is a key aim expressed within the finalised SPP3..

4. Secondary effects of increased levels of housing development could also raise further cumulative effects over the long term. For example, declining air quality in and around urban areas and a growth in waste and energy demand from higher numbers of households will require monitoring at a local level, and it will be important to take into account the implications which increased demand for aggregates arising from the construction industry may have for the environment, combined with the more direct effects that housebuilding itself may generate. This raises a challenge for development plans, their respective SEAs and associated monitoring programmes, which the revised content of the SPP should help to address.

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