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THE PROCESS OF PREPARING A SPATIAL FRAMEWORK
17. This section applies SPP6 Annex A: Spatial Frameworks for Wind Farms Over 20 Megawatts, which was drafted in terms of development plans, to the preparation of SPG.
Figure 1. The Overall Approach to Preparing Spatial Frameworks
(Within each stage the issues are not necessarily arranged in order of importance)
STAGE 1. IDENTIFYING AREAS WHICH WILL BE AFFORDED SIGNIFICANT PROTECTION.
18. The circumstances in which spatial policies must be used to identify areas that will be afforded significant protection from wind farm developments over 20 MW are set out in SPP6 Annex A paragraph 3.
Areas designated for their national or international natural heritage value
19. Nationally and internationally designated areas cover a significant proportion of Scotland. SPP6 states that the integrity of these designations should not be compromised (paragraph 54) and that "policies should seek to facilitate the meeting of national targets away from these locations in recognition of the strength of protection afforded to them by law." Maps of National, International and other areas designated for their natural heritage value can be found at: http://gateway.snh.gov.uk/portal/page?_pageid=93,866334,93_884286&_dad=portal&_schema=PORTAL
20. The international designations are:
- Special Protection Areas ( SPAs) - areas designated under the EC Birds Directive for the species listed in Annex 1 of the Directive or regularly occurring migratory bird species. SPAs safeguard the habitats of the species for which they are designated and protect the birds from significant disturbance.
- Special Areas of Conservation ( SACs) - areas designated under the EC Habitats Directive to conserve the habitat types and species identified in Annexes I and II respectively of the Directive.
- Ramsar Sites - wetlands of international importance designated under the Ramsar Convention.
(For World Heritage Sites - see Historic Environment below)
21. Ramsar sites, SPAs and SACs are approved by Scottish Ministers and are normally also Sites of Special Scientific Interest ( SSSI). It is Scottish Government policy to accord sites which qualify for designation only under the Ramsar Convention (and not as SPAs or SACs) the same level of protection as if they were SPAs.
22. Potential SPAs and possible SACs are sites on which Scottish Natural Heritage is either consulting or has completed consultation and submitted a case to the Scottish Ministers. It is Scottish Government policy to protect these sites as if they were designated. See NPPG 14, paragraph 39 ( NPPG 14 is under review and reference should be made to SPP14 when it is published.)
23. For wind farm proposals which are likely to have a significant effect on a Natura 2000 site ( SACs and SPAs) an assessment must be undertaken of the implications for the conservation interests for which the area is designated. This is known as an "Appropriate Assessment" and is separate to the requirements for an Environmental Impact Assessment and SEA. The requirements also apply to development plans and because the intention is to incorporate the SPG into a development plan at a later date it is advisable to undertake an AA of the SPG in relevant cases. Where applicable, the SPG should also include advice for determining when AA of an application may be required. Policies should take into account the possibility that a proposed development can impact upon a natura site even though it lies outwith the boundary. It is important that the authority gives full weight to the implications of the Natura 2000 network, and relevant considerations such as combination effects , given the strict obligations on the planning authority and Scottish Ministers under the Habitats and Wild Birds Directives. SNH can provide guidance on the respective sites and species interests. It is a matter for the competent authority to advise on the legislative implications.
Further advice and the SE Model Policies for Natura 2000 Sites can be seen at www.scotland.gov.uk/Resource/Doc/90377/0021755.pdf
The SG Interim Guidance on Appropriate Assessment of Development Plans is at: http://www.scotland.gov.uk/Publications/2006/06/02093425/0
The Conservation (Natural Habitats, &c.) Regulations 2004 (as amended) - See http://www.opsi.gov.uk/legislation/scotland/ssi2004/20040475.htm
24. Further guidance can be found in the SE publication 'European Protected Species, Development Sites and the Planning System - Interim guidance for local authorities on licensing arrangements, October 2001. http://www.scotland.gov.uk/Publications/2001/10/10122/File-1
25. The national designations are:
- National Scenic Areas - Areas which are nationally important for their scenic quality;
- Sites of Special Scientific Interest - Areas notified by Scottish Natural Heritage under the nature Conservation (Scotland) Act 2004 which are of special interest because of their flora, fauna, geological or physiographical features;
- National Nature Reserves - Areas of national importance for their nature conservation interests, where the natural heritage is positively managed;
- National Parks - Areas designated with the aim of conserving and enhancing their natural and cultural heritage; and promoting the sustainable use of the natural resources, the understanding and enjoyment (including recreation) of the special qualities of the area by the public, and the sustainable economic and social development of the area's communities.
26. These areas are designated for a variety of different purposes. The policy criteria for assessing proposals therefore have to be concerned with the potential effects on the interests which the designation is intended to protect. This is expressed in NPPG 14 (paragraph 25) as follows:
"Development which would affect a designated area of national importance should only be permitted where:
- the objectives of designation and the overall integrity of the area will not be compromised; or
- any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by social or economic benefits of national importance."
( NPPG 14 is under review and reference should be made to SPP 14 when it is published)
For further policy and advice see:
Green Belts
27. Green belts are designated for the purpose of managing the growth of a town or city in the long term. They are not a designation to protect natural heritage or landscapes; there are other policies to carry out these functions, though their areas may overlap.
28. The key objectives of green belt policy are given in SPP 21 as:
- To direct planned growth [of settlements] to the most appropriate locations and support regeneration;
- To protect and enhance the character, landscape setting and identity of towns and cities; and
- To protect and give access to open space within and around towns and cities, as part of the wider structure of green space.
SPP 21: Green Belts, quoted in SPP6, confirms there is a strong presumption against inappropriate development in green belts. SPP6 says: "If a proposed use would not normally be consistent with green belt designation, it may still be considered appropriate in exceptional circumstances, either as a national priority or to meet an established need but only if no other suitable site is available."SPP21 can be seen at: http://www.scotland.gov.uk/Publications/2005/08/04154944/49451
29. During the preparation of their SPG planning authorities with green belts will wish to consider the appropriateness of wind farm developments in identifying areas that will be afforded significant protection.
Cumulative impacts
30. SPP6 says: "Development plans should identify those areas where there are existing wind farm developments and set out, in relation to the scale and proximity of further development, the critical factors which are likely to present an eventual limit to development. Consideration may need to be given to whether, in some instances, such limits have already been reached and, if this is the case, planning authorities should use spatial policies to identify the extent of those areas which will be afforded significant protection from further development.".
31. Two or more wind farms or the extension of a wind farm can have cumulative impacts. These will most frequently involve changes to the landscape (landscape impacts) and changes affecting views and visual amenity (visual impacts), but it may also affect natural heritage designations, protected species and aviation interests. Cumulative impacts on bird populations should be considered at the Natural Heritage Zone ( NHZ) level.
32. Assessing cumulative landscape/visual impacts is not straightforward and is a specialist field (see reference to SNH guidance below). Cumulative effects may be perceived when more than one wind farm is visible from one viewpoint, when several are seen during a journey and when there is a gradual increase in the number or size of wind farms over time. It cannot however always be assumed that a cumulative impact will necessarily be negative. Strategic Environmental Assessments have to consider the negative and positive effects as well as cumulative effects. Assessment may show for example that a cluster of wind farms is preferable to a more widely distributed pattern. The map prepared by SNH of wind farms installed or approved, subject of an application and at scoping stage can be seen at http://www.snh.org.uk/strategy/renewable/sr-rt01.asp
33. It may be appropriate to provide significant protection to the areas between wind farms or clusters of wind farms when analysis shows that their visual separation should be maintained. The scale and pattern of the turbines plus the tracks, power lines and ancillary development will be relevant to the 'critical factors' such as:
- landscape and visual impacts;
- the significance of the landscape and the views;
- proximity and inter-visibility;
- The sensitivity of visual receptors;
- Other combined adverse effects on specific constraints.
34. Further sources of information and advice include the following:
Additional advice is contained in the section below on Landscape Assessment and further guidance on designing wind farms in the landscape is expected from SNH during 2008 which will include consideration of cumulative effects.
35. The detailed visual representation of a proposed wind farm, often as part of an EIA environmental statement is an important aid to decision-making for specific applications, though this level of work is unlikely to be relevant at the SPG stage. A Good Practice Guide has been issued by SNH and can be seen at: http://www.snh.org.uk/pubs/detail.asp?id=846
36. Cumulative impacts may arise in relation to Natura 2000 sites. Article 6(3) of the Habitats Directive requires authorities to consider the impact of a development on a Natura 2000 interest "either individually or in combination with other plans or projects" (see paragraph 4.3.3 of European Commission guidance "Managing Natura 2000 sites" European Commission 2000. Further advice is available from SNH.
STAGE 2. IDENTIFYING OTHER CONSTRAINTS AND POLICY CRITERIA
37. Having identified the areas of significant protection, the second step is to identify and describe other potential constraints, mapping them where appropriate. In doing this authorities will need to take an approach based on the nature of the constraint so far as it would be significantly affected by wind farm development and fully justify the nature and extent of the constraint. The approach should recognise that "The existence of constraints should not in themselves lead to blanket restrictions on development." ( SPP6 Annex A paragraph 4). The SPG policies should therefore provide a clear understanding of the constraint and the factors that must be satisfactorily addressed to enable development to take place. One format for such policies which authorities may wish to consider might be:
The key characteristics of this constraint are [insert key characteristics] and therefore its spatial extent is [describe extent and/or provide link to the map]. To enable wind farm development to take place the following factors must be satisfactorily addressed…[insert factors].
38. For ease of reference, each of the following sections begins by quoting the relevant paragraph from SPP6 and goes on to suggest some issues, concerns and sources of information as appropriate, but it cannot be regarded as fully comprehensive. The SPP does not give an exhaustive list of these Stage 2 constraints but indicates that the circumstances in which this approach should be used include those set out below. If there are additional circumstances in which the stage 2 approach is appropriate the SPG should fully explain and justify them in the context of the principle quoted in paragraph 15 above.
Historic Environment
39. "Development plan policies should set out how development can be accommodated without damaging the character of the historic environment. Further guidance is given on the relative weight which attaches to the protection of different types and categories of site in NPPG 5: Archaeology and Planning and NPPG 18: Planning and the Historic Environment. PAN 42 Archaeology and the Scheduled Monument Procedures provides more detailed advice".SPP6 Annex A.
40. Scottish Historic Environment Policy 1, Scotland's Historic Environment defines (page 9) what comprises the historic environment (see link below). Other documents in this Scottish Government policy series set out Scottish Ministers' policies for specific national designations. These policies will also be relevant when considering the place of World Heritage Sites within SPG. World Heritage Sites are sites which have been inscribed by the United Nations Educational, Scientific and Cultural Organisation on the World Heritage List. Member states have a duty to protect, manage, conserve and present for present and future generations the particular outstanding universal values for which each site has been designated These will encompass either one or a number of national designations and those will be significant in understanding and extending appropriate protection to the particular outstanding universal values of each site.
Key Issues and Considerations
- World Heritage Sites, the protection of the site and its setting to secure the preservation of the particular outstanding universal values for which they are designated (see also final bullet below).
- Listed buildings, especially where their landscape setting would be affected.
- Scheduled ancient monuments, where there are potentially direct impacts on the sites themselves and indirect effects on setting.
- Conservation areas, especially where the reason for their designation would be affected.
- Designed gardens and designed landscapes, especially where the proposal would affect important vistas.
- Give consideration to regional and local archaeological issues in accordance with NPPG 5.
- The key issues and concerns for Buffer Zones (see heading below) also extend as appropriate to historic environment designations if the protection of the setting is particularly important: and
- In the case of World Heritage Sites, UNESCO's Operational Guidelines for the Implementation of the World Heritage Convention requires (at paragraphs 103-107) the formal definition of buffer zones in some cases. Their purpose is to give an added layer of protection to the site's immediate setting, important views and other areas or attributes that are functionally important to support the site and its protection. For the purpose of SPG they should not be interpreted as "no go" areas for wind farm development. Rather, they indicate those areas where particular care should be taken to ensure development does not adversely affect the site. Large and prominently sited turbines may also affect the setting of a WHS beyond the boundaries of formally defined buffer zones.
Sources of Information
( NPPG5 and NPPG18 are under review)
Areas designated for their regional and local natural heritage value
41. Regional and local natural heritage designations cover a significant area of Scotland. "Planning authorities should identify areas designated for their regional and local natural heritage value in their development plans. NPPG 14 confirms that such areas are important although the level of protection afforded to them should not be as high as that given to internationally or nationally designated sites. Planning authorities should use appropriate criteria to ensure that proposals satisfactorily address any impacts on the particular interest that a regional or local designation is intended to protect. In some instances, such designated areas may represent those places most valued for their scenic character within a local authority area. This leads to a higher value being placed on them and, in such circumstances, a more cautious approach to development may be confirmed through criteria based policies. In doing so, planning authorities should ensure that policies do not unreasonably restrict the ability of the plan area to contribute to national targets."SPP6 Annex A.
42. The regional and local designations highlighted in NPPG 14 Natural Heritage include Areas of Great Landscape Value, Local Nature Reserves, Local Wildlife Sites and Regionally Important Geological/Geomorphological Sites. For Regional Parks see under Tourism and Recreational Interests below. ( NPPG 14 is under review)
Key Issues and Considerations
- Identifying the particular interest or interests for the designation.
- Setting appropriate criteria (see Criteria Based Policies below).
- For areas designated for their landscape value, consider whether the number of turbines, their height, their pattern in the landscape, their overall composition and relationship to key landscape features are important in setting policy.
Sources of Information
Tourism and recreational interests
43. "Tourism is an important element in the economic, social, environmental and cultural well-being of Scotland. The beauty of Scotland's landscape attracts many visitors and sustainable tourism supports many small businesses and remote rural and island communities. Those areas which have been designated for their scenic importance are covered by other policies in this SPP. When considering development plan policies, views on whether there are other locations where there is likely to be particular sensitivities requiring carefully consideration should be sought from tourism and recreational bodies in the area and, if appropriate, broad criteria should be set out to ensure that wind farm developments are not incompatible with tourism and recreational interests."SPP6 Annex A.
44. A recent research report The Economic Impacts of Wind Farms on Scottish Tourism, found overall that if the tourism and renewable industries work together to ensure that suitably sized wind farms are sensitively sited, whilst at the same time affording parts of Scotland protection from development, then the impacts on anticipated growth paths are expected to be so small that there is no reason to believe that Scottish Government targets for both sectors should be seen as incompatible. It also found that from a tourism standpoint, larger developments may be preferable to a number of smaller developments, particularly when they occur in the same general area. A link to the full research report is given below.
45. The research found that the negative impact of wind farms on tourism at national level is small. However it said that planning authorities may wish to consider a range of issues (see following paragraph) to ensure that any adverse local impacts on tourism are minimised.
46. Regional Parks designated under the Countryside (Scotland) Act 1981 provide important destinations for various types of recreation close to larger centres of population and may include landscapes considered to be of regional importance. They may also have regional or local natural heritage value. If they include areas designated for other purposes, for example an SSSI, then the policies relevant to that designation will also apply.
Key Issues and Considerations
- The location in relation to tourist routes, including designated cycling and walking routes.
- The relative scale of recreation and tourism in the area i.e. local and national
- Views from accommodation in the area.
- The potential positive tourism issues associated with the development.
- The views of tourist organisations i.e. local tourist businesses or VisitScotland.
- The visitor population whose recreational interests may be affected.
- Be aware of 'double counting' tourist and recreational interests which have already been taken into consideration because an area is otherwise designated.
- Consider likely significant effects within an environmental impact assessment.
Sources of Information
Communities
47. "Broad criteria should be used to set out the considerations that developers should address in relation to local communities. These should ensure that proposals are not permitted if they would have a significant long term detrimental impact on the amenity of people living nearby. When considering spatial policies, planning authorities may consider it helpful to introduce zones around communities as a means of guiding developments to broad areas of search where visual impacts are likely to be less of a constraint. PAN 45 confirms that development up to 2 km is likely to be a prominent feature in an open landscape. The Scottish Ministers would support this as a separation distance between turbines and the edge of cities, towns and villages so long as policies recognise that this approach is being adopted solely as a mechanism for steering proposals to broad areas of search and, within this distance, proposals will continue to be judged on a case-by-case basis."SPP6 Annex A.
Key Issues and Considerations
- Identify, as set out in SPP6, how the 2 kilometre separation distance between turbines and the edge of cities, towns and villages applies, recognising that applications will continue to be judged on a case by case basis within this distance; and
- their role in guiding applications to broad areas of search;
- Set policies to judge applications on their merits within the zones;
- Have regard to the likely visual impact on views looking from the community;
- Take into account noise issues according to PAN 45 and the recommended good practice in The Assessment and Rating of Noise from Wind Farms, ETSU for DTI 1996. This is kept under review and led to research on Aerodynamic Modulation of Wind Turbine Noise, see http://www.berr.gov.uk/files/file40571.pdf
- Have regard to Issues raised by members of the community, including positive and negative opinions; and bear in mind the relevance of the research findings (see below) regarding public attitudes to wind farms.
Sources of Information
Buffer zones for Areas designated for their Landscape or Ecological Value
48. "Planning authorities should not impose additional zones of protection around areas designated for their landscape or ecological value including sites of national and international importance. However, the potential impact of proposals on such areas may be a material consideration to be taken into account when determining planning applications. Where there are potential significant effects on a Natura 2000 site the competent authority will require to undertake an appropriate assessment under the Habitats Regulations."SPP6 Annex A.
Key Issues and Concerns
- Proposals outwith a designated area may nevertheless have an impact on that area which needs to be controlled.
- Address this issue through policy rather than by showing buffer zones on a map.
- Include policy in the SPG on when proposals outwith designated areas but potentially affecting them may be a material consideration, and
- The policy should address the interests that the designation is intended to protect.
Aviation and defence interests
49. "Development plan policies should, following consultation with the relevant bodies, take account of the need to address impacts on airport operation, flight activity, aviation and defence radar and seismological recording and confirm that it is a matter for developers to address these impacts through discussion with the relevant bodies. Planning authorities should undertake consultation with the relevant bodies when considering applications to ensure that impacts have been satisfactorily addressed."SPP6 Annex A.
50. PAN 45 provides background advice on this topic but this is an evolving field. It is clear that large-scale wind farm proposals may have the potential to impact significantly on primary, secondary or weather radar stations and thus affect public safety. It is therefore vital that the SPG recognises the relevant aviation and radar issues and takes them into account. It should also direct developers to the relevant consultees such as National Air Traffic Service, Civil Aviation Authority, Ministry of Defence, British Airports Authority and other airport operators so that they can engage with them at an early stage in the design process, to establish the potential impacts and agree acceptable technical solutions. This is important for specific applications where actual or potential conflicts exist so that an acceptable solution can be identified wherever possible and that the relevant consultee agrees to that solution being implemented in the anticipated timescale.
51. Policies should ensure that applications are considered in the light of the most up-to-date information. Work to describe and map the nature of this constraint for the spatial framework should take account of the latest information from the aviation authorities and operators, but it will not usually be possible to resolve the matter in the absence of a specific proposal. Experience shows that site-specific technological or other mitigation solutions may be possible in the context of an application when radars are potentially affected and these are to be encouraged where practically possible. Collaborative work by planning authorities may help to achieve a joint solution. It will nevertheless be important to put in place clear mechanisms to promote the resolution of issues at the earliest possible stage since this is unlikely to be achieved quickly.
52. The Scottish Government is participating in the UK government's Aviation Board with the aim of identifying and testing technological solutions to the potential difficulties wind farms pose to air traffic and defence radars. Further guidance on consultation with aviation and radar stakeholders is being prepared.
Key Issues and Considerations
- Aviation and radar constraints and possible mitigation measures.
- Policies should confirm that it is for applicants to undertake pre-application consultation with MoD, CAA/ NATS and airport operators.
- As SPP6 says (see above) it is the role of the SPG/spatial framework to "take account of the need to address the issues" because it may not be possible to fully resolve matters in advance of a specific proposal coming forward.
- PA to consult NATS, CAA, MoD, and airport operators.
- The circumstances in which suspensive conditions may be appropriate (see advice at Appendix 1).
Sources of Information
Broadcasting installations
53. "Development plans should take into account the location of radio and television broadcasting installations within the area and include criteria to ensure that the protection or reprovision of transmission links is maintained. Where applicable, applicants should consult with network owners and Ofcom to ensure that no material impact will occur, or alternatively that a technical solution is available and will be provided as part of the scheme."SPP6 Annex A.
54. In most cases, it will be important to include in SPG a policy to the effect that where there may be an issue with broadcast interference it is for the applicant to show that they have consulted the network owners and that the latter are satisfied with the proposal. As with aviation and radar issues, it may not be possible to resolve matters in advance of a specific proposal coming forward.
Sources of Information
STAGE 3 OUTWITH PROTECTED AND POTENTIALLY CONSTRAINED AREAS - REFINE REMAINING AREAS OF NO SIGNIFICANT CONSTRAINTS
55. "The above process should enable planning authorities to identify those areas where there are no significant constraints on wind farm development. This should be reflected in the criteria set out in development plans. There may be scope to consider whether these areas can be further refined to provide developers, communities and other interested parties with a stronger steer towards broad areas of search where development is favoured. The issues that should be considered include:SPP6 Annex A
Other natural heritage interests
56. "There may be locations within the plan area that, although not formally designated, include habitats or landscape characteristics that are considered to be more sensitive to development than others. These areas should not be afforded the same protection as designated sites. However, in line with Article 10 of the Habitats Directive and the European Landscape Convention, it may be appropriate, particularly where significant development opportunities exist elsewhere in the area, to use the development plan process to steer development to other sites that are considered within the area to be more suitable for development."SPP6
57. Given that designated areas have already been addressed, constraints arising from these other natural heritage interests relevant to preparing the spatial framework are likely to be limited in scope. The SPG should set out broad areas of search in accord with SPP6.
58. Wind farm development on soils which hold large stocks of carbon, for example peat, can potentially lead to carbon losses. This is considered in SNH's Technical Guidance Note - Windfarms and Carbon Savings. Authorities may also wish to refer to Calculating Carbon Savings from Wind Farms on Scottish Peat Lands - A New Approach (see below). This does not justify avoiding peat soils on the grounds of potential carbon emissions but does emphasise the importance of good on-site management practices in reducing carbon losses.
59. It should be borne in mind in developing a spatial framework that before granting planning permission the planning authority (or Scottish Ministers in Electricity Act cases) has to be satisfied that the proposed development either will not impact adversely on any European protected species on the site or that, in its opinion, all three tests necessary for the eventual grant of a Regulation 44 licence (issued under The Conservation (Natural Habitats, &c.) Regulations 1994, as amended) are likely to be satisfied. To do otherwise would be to risk breaching the requirements of the Habitats Directive and Regulation 3(4) of the 1994 Regulations.
Key Issues and Considerations
- Landscape character and sensitivity.
- Law and policy on protected species.
- Other species and habitats of conservation concern ( e.g. Biodiversity Action Plan species/habitats).
- Undesignated sites are likely to have more influence on the specific siting of turbines and related development than on the general location of the proposal.
- Measures to mitigate the carbon losses from peat soils including good management practices on site.
- Policy on peat and wind farms is at paragraph 50 of SPP6.
- Adverse impacts on protected species.
Sources of Information
Project viability
60. "Planning authorities should consider, in consultation with the wind farm industry, issues such as wind speed, site access, ground suitability and other key environmental factors which could impact on development. This should ensure that broad areas of search are capable of accommodating a viable wind farm project."SPP6 Annex A
Key Issues and Considerations
Consultation with the industry, including on:
- the wind resource;
- potential for access to the site and on-site accessibility;
- constraints imposed by the slope of the ground; and
- ground conditions and foundation requirements, including the implications of peat soils and the need for appropriate mitigation measures (see above).
Grid
61. "Planning authorities may consider steering developments to areas where existing and approved grid capacity can be maximised and wind farm developments are likely to be able to be accommodated. This is intended to facilitate early achievement of the Executive's 2020 target. However, policies should also recognise that upgrade of the grid is essential if Scotland is to realise fully its renewable energy ambitions. Grid constraints should not, therefore, be used to exclude the identification or safeguarding of appropriate broad areas of search where renewable energy potential exists and there is likely to be developer interest in bringing forward proposals.SPP6 Annex A
Key Issues and Considerations
- Policies should recognise that grid improvements do take place.
- Grid constraints do not signify that an area cannot be a broad area of search.
Sources of Information
STAGE 4 - IDENTIFYING BROAD AREAS OF SEARCH
Stages 1, 2 and 3 lead to the identification of broad areas of search. These should be mapped. SPP6 says that such areas should provide a steer to developers on acceptable locations.
Key Issues and Considerations
- The identification of 'broad areas of search' should not imply that other areas may not be considered in the context of specific applications.
- Consider the implications of defining areas of search which are not broad.
- It may be necessary to reconsider the approach taken in stages 2 and 3 if the areas of search are not sufficiently broad.
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