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1. INTRODUCTION
Purpose of this Environmental Report
1.1 As part of the preparation of the final part of the consolidated Scottish Planning Policy ( SPP), the Scottish Government is carrying out a Strategic Environmental Assessment ( SEA). The SEA is required by the Environmental Assessment (Scotland) Act 2005. SEA is a systematic method for considering the likely effects of plans, programme and strategies on the environment. SEA integrates environmental factors into policy preparation and decision-making. It also has an important role to play in increasing public participation and facilitating openness and transparency in decision-making, by ensuring the public is made aware of the potential environmental effects of proposed policies, and the alternatives to them.
1.2 The purpose of the SEA is to ensure that environmental issues raised by the SPP are systematically identified and addressed as far as possible. The purpose of this Environmental Report is to provide information on the content of the draft SPP and to describe and evaluate its likely significant effects. It also sets out the environmental impacts of the policy alternatives that were considered during the preparation of the consultative draft.
1.3 The key facts relating to SPP are set out in Table 1 below.
Table 1: Key facts relating to SPP
What prompted the PPS? | The production of a single SPP is a core element of the commitment to proportionate and practical policies at the national level, and forms part of the programme for delivering planning reform. |
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Subject | Town and country planning |
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Period / period for updating | Not specified |
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Purpose and/or objectives | The SPP is a statement of Scottish Government policy on land use planning which identifies priorities for the system and the contribution of planning to the overarching purpose. The Scottish Government is consolidating and rationalising the current SPP and NPPG series into a single policy document (Scottish Planning Policy). The first part of the SPP (published in October 2008) set out the overall context of the planning system and explains key components and procedures of the process, as defined by the Planning Etc. (Scotland) Act 2006. This replaced SPP1 The Planning System. The final part of the SPP includes sections on community engagement, the subject policies and outcomes Pre-screening determined that of the first part of the SPP did not require a full SEA. This report focuses only on the community engagement, subject policy and outcomes sections in the remainder of the document. The subject policy section explains the Scottish Government's planning policy across a range of key subjects, combining existing planning policy from the current series of SPPs and NPPGs. |
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1.4 It is important to note that the SEA reflects the broad remit and strategic nature of the consolidated SPP. It has aimed to identify and assess potentially significant effects of the policies and proposals whilst maintaining a national perspective. In many cases effects remain uncertain, and may only become clearer when they have been translated into development plan policies. The aim of producing the single SPP was to consolidate existing policies, not to create a new policy framework. Therefore, it is not the Scottish Government's intention to reopen the debate on existing policies, but to focus the consultation and assessment itself only on key changes to the policy. Consultees should make their responses to the consultation on the draft SPP in light of the findings of this Environmental Report.
SEA activities to date
1.5 Table 2 summarises the SEA activities in relation to SPP.
Table 2: SEA activities
Date | Activity | Comments |
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December 2008 - January 2009 | Screening | Concluded that an SEA was required, as the final sections of the SPP could have significant environmental effects. Determination submitted via the SEA Gateway. |
Scoping | Defined the scope of the assessment, the level of detail to be included in the Environmental Report, and proposed consultation period. |
January - February 2009 | Environmental Assessment. Consultative draft SPP and Environmental Report produced for discussion | The assessment was undertaken alongside the drafting of the SPP itself. This included further baseline and contextual policy analysis and analysis of key policy changes. |
Spring 2009 | Consultation | Stakeholders are now being provided with the draft SPP and the Environmental Report. |
Summer 2009 | Review of consultation findings and further environmental assessment | A review of the draft SPP will be undertaken to take into account views from consultees. During this process, the SEA findings will be referred to and updated as appropriate. |
Autumn 2009 | Publication of finalised SPP and post adoption SEA statement | To be undertaken. |
1.6 The main part of the assessment was undertaken alongside the drafting of the SPP. The assessment considered the effects of proposed key changes to the SPP, and findings and recommendations from the SEA were used to inform the preparation of the consultative draft. As detailed options emerged during the drafting process, their effects were reviewed as an integral part of the assessment.
Outline and objectives of the SPP
1.7 The final part of the consolidated SPP explains the Scottish Government's planning policies on community engagement, outcomes and various subject policies, identifying the key principles that should be applied and actions required by all involved in the planning system, particularly in terms of development planning and development management decisions. The subjects are economic development, town centres and retailing, housing, rural development, coastal planning, fish farming, historic environment, natural heritage, open space and physical activity, green belts, transport, renewable energy, flooding waste management, minerals, opencast coal and telecommunications.
1.8 The aims of the consolidated SPP are to:
- provide a single statement of the Scottish Government's priorities for the planning system, explaining the contribution of planning to the overarching purpose,
- make the cumulative requirements of national planning policy clear, and to eliminate duplication and resulting minor inconsistencies,
- enable policy to be expressed which is proportionate, practical and concise, as is required in development plans,
- provide national planning policy which is easier to understand with less scope for interpretation, therefore providing more certainty.
1.9 The final part of the SPP consolidates and, when finalised, will supersede:
- SPP2 Economic Development;
- SPP3 Planning for Homes;
- SPP4 Planning for Minerals;
- SPP6 Renewable Energy;
- SPP7 Planning and Flooding;
- SPP8 Town Centres and Retailing;
- SPP10 Planning for Waste Management;
- SPP11 Open Space and Physical Activity;
- NPPG13 Coastal Planning;
- NPPG14 Natural Heritage;
- SPP15 Planning for Rural Development;
- SPP16 Opencast Coal;
- SPP17 Planning for Transport;
- NPPG19 Radio Telecommunications;
- SPP21 Green Belts;
- SPP22 Planning for Fish Farming; and
- SPP23 Planning and the Historic Environment.
1.10 NPPG12 Skiing Developments has not been incorporated into the review as the Scottish Government is of the view that specific planning policy on this matter is no longer required. SPP20 The Role of Architecture and Design Scotland has not been incorporated because it is not planning policy.
Summary of assessment methods
1.11 As explained above, the assessment has been undertaken alongside the drafting of the SPP. After scoping, the following activities were undertaken:
- Baseline evidence and contextual PPS were reviewed further, to ensure that the assessment focuses on relevant environmental issues.
- The emerging content of the draft SPP was reviewed, to identify the key policy components that should form a focus for the assessment. As explained below, each part of the existing SPPs and NPPGs and the draft consolidated SPP was reviewed in detail to identify where significant changes had arisen, thereby allowing for a more focused approach to the assessment.
- Each of the significant changes was reviewed in relation to the SEA objectives and sub criteria, to identify their environmental effects. The findings from this assessment were recorded in matrices, which included summary symbols and a commentary.
- The findings from the individual assessment of each key change were brought together to provide a broader picture of the effects arising for each policy topic.
- The findings were then combined, to allow the assessment to focus on the interactions between SEA topic areas. Cumulative, synergistic and significant effects were identified, by bringing together the findings for each key change to the SPP.
Limitations of available baseline data / methodological problems
1.12 No major gaps in the available baseline data were identified. The approach to the SEA was designed to be as clear and simple as possible, reflecting the generally environmentally positive and high level nature of the draft SPP itself. No significant methodological concerns arose during the course of the assessment.
SEA Objectives
1.13 Objectives have been used to structure the SEA process, and ensure that the assessment is systematic and relevant. SEA objectives, together with more detailed sub-criteria, were identified for the assessment. It was proposed that the objectives used to assess the content of the National Planning Framework would also be used to assess the content of the draft SPP, to provide a consistent approach to the two key statements of national level planning policy. However, in response to SNH's comments on the scoping report, some of the sub-criteria that were originally included in the table have been removed, as they relate to social or economic objectives and therefore inappropriately broaden the assessment and undermine its environmental focus. Several sub-criteria focusing on employment and sustainable economic development, affordable housing and housing land, employment and rural development were removed from the assessment framework.
1.14 The finalised SEA objectives and related sub-criteria are set out in Table 3 below. Each relevant component of the SPP was assessed against these objectives. Within the assessment, baseline information and wider references to evidence and research was used to ensure the assessment was as closely linked to available evidence as possible.
Table 3: SEA Objectives and Sub-Criteria
SEA Objectives | Sub criteria |
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Protects or enhances biodiversity flora or fauna | Supports the delivery of the Scottish Biodiversity Strategy |
Reduces the overall decline in the area, condition and diversity of semi-natural habitats |
Safeguards and enhances sites that have been designated for protection as a result of their biodiversity value |
Addresses the impacts of climate change on biodiversity, including by addressing habitat network fragmentation |
Supports population and human health | Improves community health and wellbeing by promoting higher levels of physical activity |
Reduces health problems arising from environmental pollution |
Addresses established health and social inequalities that are linked with environmental degradation |
Promotes the development of a sustainable settlement pattern and physical infrastructure | Promotes settlement expansion that protects the existing character of settlements |
Supports climate change adaptation within settlement planning |
Increases the benefits of green networks, green belts and access networks |
Reduces energy consumption and / or CO 2 emissions | Promotes development in areas accessible by sustainable transport |
Contributes to achieving a reduction CO 2 emissions from energy |
Helps to reduce CO 2 emissions from transport |
Promotes more diverse energy generation technologies |
Encourages improved energy efficiency |
Contributes to air quality / emissions reductions targets |
Reduces water pollution or enhances water quality | Achieves good ecological status of waterbodies by 2015 |
Complements the emerging role of RBMPs |
Achieves sustainable management of water demand |
Reduce water pollution and protect / enhance the status of aquatic ecosystems |
Delivers sustainable drainage systems |
Delivers sustainable flood management solutions |
Supports the sustainable management of the marine environment |
Protects or enhances the quality of soils | Avoids adverse direct and indirect impacts of developments on soil |
Encourages efficient use of land and resources | Increases carbon sequestration |
Protects mineral resources from sterilisation |
Reduces waste going to landfill |
Helps to achieve target of 55% of waste being recycled or composted by 2020 |
Reclaims / redevelops derelict and contaminated land |
Promotes a shift to more sustainable modes of transport |
Safeguards or enhances the built environment | Protects / enhances (where appropriate) sites that are recognised for their architectural and / or archaeological heritage value |
Recognises and reflects the heritage value of wider (non-designated) landscapes and townscapes |
Respects and protects the character, diversity and special qualities of Scotland's landscapes. | Improves the landscape setting of existing settlements |
Protects / enhances the quality, scenic value and distinctiveness of designated and non- designated landscapes |
Achieves sustainable management of change in vulnerable landscapes |
Focusing the SEA on key changes to existing policy
1.15 The Scottish Government did not intend to introduce any new policies through the consolidation and rationalisation of national planning policy, as the redrafting merely sought to better present existing policies on planning. Whilst considerable accompanying text and advice has been removed from the revised policy, the Scottish Government has based its assessment of whether or not a change is significant on consideration of whether the intended outcome from the policy would be different. This allows the review to focus only on substantive changes, avoiding a tendency to afford too much attention to what is essentially a presentational change. The key changes for each of the policy areas within the draft SPP are set out in Table 4 below.
Table 4: Summary of proposed changes to the SPP and comments on the corresponding approach to the SEA
| What is the policy saying? Summary of key existing policies | What important policies have been included or removed? Substantive changes | What other minor changes or omissions have been made? Minor changes | Comments |
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SPP2 Economic Development | Planning should strongly support economic development, both new and expanding businesses, where consistent with other national and local policies. | No substantive changes to the policy anticipated. | - Reference to safeguarding sites of national importance removed: NPF refers to high amenity sites.
- Specific mention of corporate headquarters removed.
- Reference to dialogue with stakeholders removed, as covered by planning reform.
- Changes focus on consistency of terminology and removal of duplication across national plans and policies.
| No significant environmental effects from minor changes, individually or collectively. No further assessment required. |
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SPP3 Planning for Home | Sufficient land to support an increased supply of the right homes in the right places should be identified through the planning system, and the system should be used to facilitate the construction of well-designed, good quality housing in sustainable locations. | No substantive changes to the policies anticipated. | - Annex A: Housing Land Audits is advice not policy and will be removed.
- Reference to Housing Market Partnerships removed.
- Policy on housing in rural areas covered in rural development section.
- Alterations to structure and wording to enable clearer and more concise explanation of policy. Removal of duplication and advice.
| No further assessment required. |
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SPP4 Planning for Minerals | Minerals are vital to the Scottish economy and the planning system should take a positive approach to ensuring an adequate supply of minerals. The planning system must ensure that minerals extraction only takes place where impacts on local communities and the environment can be made acceptable. | No substantive changes anticipated. | - Removal of specific references to conservation of natural and built heritage, green belts, agricultural land and rural economy because these are covered elsewhere in SPP.
- Detail regarding noise, dust and air quality, groundwater and surface water, and mineral waste is not provided as these fall within broader regulatory regimes.
- Removal of more detailed requirements for restoration bonds.
- Reduction of the text on working with communities.
- Alterations to structure and wording to enable clearer and more concise explanation of policy. Removal of duplication and advice.
| Changes focus on removing duplication - with other policies within the SPP and in terms of coverage of the planning system when combined with wider regulatory regimes. No further assessment required. |
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SPP6 Renewable Energy | The planning system should support achievement of targets for the generation of electricity from renewable sources. The policy sets out how the planning system should manage the process of encouraging, approving and implementing renewable energy proposals when preparing development plans and determining planning applications. | Annex A Spatial Framework for Wind Farms over 20 MW has been incorporated into the main body of the SPP. This has led to: - retention of para 1 that emphasises the importance of clarity and that development plans should set out broad areas of search, protected areas and criteria for assessing proposals in other areas.
- removal of consultative approach: now covered by the section on community involvement.
- inclusion of para 3: policies should be based on the principle that wind farms should be accommodated where feasible.
- retention of the criteria applicable to areas where wind farms could be encouraged.
- retention of criteria for broader areas where development may be feasible.
- retention of the criteria of other natural heritage interests, project viability and grid in areas beyond designations.
| - Removal of background information on sustainable development, climate change and renewable energy.
- Restructuring of spatial framework to provide more straightforward explanation, with reduction in level of detail provided in the text and removal of duplication.
| The SEA reviewed the incorporation of Annex A - Spatial Framework throughout the drafting process. It was concluded that this did not constitute a change that would generate significant environmental effects. As a result, it was scoped out of the fuller SEA process and ER. No further assessment required. |
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SPP7 Planning and Flooding | New development should not take place if it would be at significant risk of flooding from any source or would materially increase the probability of flooding elsewhere. Drainage is a material consideration and sustainable drainage will be required wherever practicable. For coastal and watercourse flooding a Risk Framework characterises areas for planning purposes by their annual probability of flooding and gives the planning response. | No substantive changes to the policy are anticipated at this stage, although this should be revisited later in 2009 as the implications of the Flooding Bill become clearer. | - Policy on SUDS has been clarified but not changed.
- Removal of background information and explanation of responsibilities.
- Alterations to the structure and wording to enable clearer and more concise explanation of policy. Removal of duplication and advice.
| No further assessment required at this stage. |
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SPP8 Town Centres and Retailing | The planning system should identify and promote town centres as part of a network of centres and seek to focus development in existing town centres by using a sequential approach to development. | No substantive changes anticipated. | - Removal of reference to mezzanine floor restrictions.
- Examples of vitality and viability indicators are not included in revised text.
- Definitions removed to glossary.
- Alterations to structure and wording to enable clearer and more concise explanation of policy. Removal of duplication and advice.
| No further assessment required. |
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SPP10 Planning for Waste Management | The policy supports a planned approach to the identification of sites for waste management installations using a range of technologies. Landfill opportunities should be safeguarded and waste facilities protected from in appropriate surrounding development. Encourages the provision for waste separation and collection of recyclable material in new developments. | No substantive changes anticipated. | - Removal of background information and explanation of SEPA's role in planning.
- Alterations to structure and wording to enable clearer and more concise explanation of policy. Removal of duplication and advice.
- Sections on model policies, land raising, sewage and other process sludges, design and site waste management plans not included as they constitute guidance.
- Reduction in detail on waste management, proximity principle, working with communities and need.
- Policy on taking pollution, including odour, into account when deciding on locations for thermal treatment plants has been clarified following advice from SEPA.
| No further assessment required. |
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SPP11 Open space and physical activity | The planning system should seek to protect and enhance open space and opportunities for sport and recreation. Open space audits should be undertaken to inform open space strategies. Guidance should be provided in the quality and accessibility of open space in new developments. | No substantive changes anticipated. | - Reduction of background text on the value of open space and physical activity.
- Removal of detail on open space audits and strategies.
- Removal of specific mention of stadia, actions by separate council departments and quality factors.
- Reduced text on local authority developments.
| No further assessment required. |
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NPPG12 Skiing Developments | States that the planning system should provide for the growth of skiing in locations where there are not likely to be adverse effects. While the development of new areas is not ruled out, the policy provides mainly for the consolidation and improvement in the range and quality of facilities at existing ski centres. | No separate section on skiing developments to be included in the draft consolidated SPP (all existing policy now excluded) as broader policies cover all relevant considerations. This means that development plans will no longer be required to include specific policies on skiing development, although relevant areas may choose to retain or include specific policies. | No minor changes. | The SEA assesses the effects that removing this subject area in its entirety could have on the environment. This has sought to ensure that no environmental gaps arise from the consolidation process. |
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NPPG13 Coastal Planning | The coast should be classified for planning purposes as developed, undeveloped or isolated and different responses are required to development proposals in these areas. Isolated and undeveloped coast should be protected. Developed coasts should be the focus for development which requires a coastal location. | The requirement to classify all the coast into one of the three types in the development plan has been removed, but the distinction between the types has been retained in the context of development management, to act as a general guide to development on the coast. | - Reduction of the explanation of types of coastal area.
- No information on non-statutory plans included.
- Removal of additional guidelines for development which may require a coastal location.
| The SEA explores whether removal of requirement for classification of the coast within development plans is likely to generate any significant environmental effects. |
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NPPG14 Natural Heritage | Planning plays a key role in ensuring land requirements are met in ways which do not erode environmental capital. Sets out the key tools that planning can use to protect the environment. It notes the importance of a strategic approach to biodiversity protection, and explains the hierarchy of natural heritage designations, and the importance of protecting the wider environment. Also covers woodland and trees, lochs, ponds, water and wetlands. Explains role of non-statutory designations and refers to use of the precautionary principle. | Local designations are now limited to two types: special landscape areas and local nature conservation areas to prevent proliferation of local designation types. | - Alterations to detailed wording and removal of duplication.
- Increased emphasis on habitat networks and connectivity.
- Some references are made to updated environmental policy context (i.e. European Landscape Convention).
| Whilst there are apparently substantive changes to the policy to reflect the updated context and guidance on local designations, no clear shifts in the policy direction were identified that could generate any significant environmental effects. As a result, no further assessment has been undertaken. |
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SPP15 Planning for Rural Development | Planning's role in rural development is to enable opportunities for development in sustainable locations. Rural diversification should be embraced to help businesses expand or start new enterprises in relevant circumstances. New development should not undermine countryside character and quality. | No substantive changes anticipated. | - Reduction of explanation provided and restructuring to combine key policy messages and remove duplication.
| No further assessment required. |
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SPP16 Opencast Coal | Coal is required as part of the mix. Planning authorities are responsible for determining individual development proposals. There should normally be a presumption against development unless the proposal is environmentally acceptable, or can be made so by planning conditions / agreements, or the proposal provided local or community benefits which clearly outweigh the likely impacts to justify consent. | No substantive changes anticipated. | - Sections on appraisal of proposals and assessment of disbenefits and benefits reduced.
- Annex on the Coal Authority removed.
- Alterations to structure and wording to enable clearer and more concise explanation of policy. Removal of duplication and advice.
- Less text on impact on communities, but need to take communities into account is retained.
- Section on operational considerations removed, as this is covered by wider environmental regulation.
| No further assessment required. |
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SPP17 Planning for Transport | Land use planning should assist in reducing the need to travel and creating the right conditions for greater use of sustainable transport modes. The settlement strategy should be related to the capacity of the strategic transport network. Development likely to affect trunk and other strategic roads should not adversely impact on the safe and efficient flow of traffic. Local maximum parking standards should be developed. | Requirement for application of national maximum parking standards removed. Section on new junctions onto motorways and the strategic road network adjusted to reflect the current position of Transport Scotland. | - Sections on types of transport modes removed and policy incorporated into general text resulting in reduction in level of detail and removal of duplication and advice.
- Section on assessing development proposals reduced.
- Alterations to structure and wording to enable clearer and more concise explanation of policy.
| The SEA explores the implications of the removal of national maximum parking standards and increased provision of new junctions onto strategic roads in relation to environmental objectives. |
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NPPG19 Radio Telecommunications | Siting and design of telecommunications development are the key issues to be addressed through the planning system. Options for site selection and base station design are set out and the role of the planning system in relation to emissions and health is explained. | No substantive changes anticipated. | - Removal of all policy context, background information, advice and information about permitted development rights.
- Section on determining planning applications removed.
- Alterations to structure and wording to enable clearer and more concise explanation of policy.
- Significant reduction of discussion around emissions and health, but core policy position that emissions of radio frequency radiation are controlled and regulated under other legislation, therefore planning authorities should not treat emissions as a material consideration is retained.
| No further assessment required. |
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SPP20 The Role of Architecture and Design Scotland | This SPP sets out the role of Architecture & Design Scotland and repeats policy messages from Designing Places | Role of A+ DS is not planning policy, therefore will not be included in the consolidated SPP. Other policy messages are a repeat of Designing Places, which will be retained as a separate document. | N/A | Whilst apparently substantive changes, no significant effects are expected from this omission. No further SEA of this topic area is therefore proposed. |
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SPP21 Green Belts | Green belt designation should be used as a long term land use planning tool to provide clarity and certainty on where development will and will not take place. There is presumption against inappropriate development in green belts. Where necessary the proposed release of green belt land should be taken forward as part of a long term settlement strategy in the development plan. | No substantive changes anticipated. | - Removal of detail from the development planning and development management sections.
- Section on management not included.
- Alterations to structure and wording to enable clearer and more concise explanation of policy
| No further assessment required. |
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SPP22 Planning for Fish Farming | Planning authorities should use the development plan to support fish farm development where environmental and other impacts can be addressed satisfactorily. Plans should identify sensitive areas and potential development areas. | No substantive changes anticipated. | - Section on policy background removed.
- Less detail incorporated on working with communities, natural heritage, the historic environment and other regulatory controls and codes of practice.
- Alterations to structure and wording to enable clearer and more concise explanation of policy
| No further assessment required. |
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SPP23 Planning and the Historic Environment | The planning system can contribute to the delivery of the Government's objectives for the historic environment. Planning authorities should ensure that development plans provide a framework for protection, conservation and enhancement of the historic environment in which development impacts can be properly assessed. The historic environment can accommodate new uses while retaining its special character. The aim should be to identify the best viable use that is compatible with the fabric, setting and character of the historic environment. | No substantive changes anticipated. | - Alterations to structure and wording to enable clearer and more concise explanation of policy.
- Information on authorities' wider powers relating to the historic environment have been removed.
- Model policies not included.
| No further assessment required. |
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1.18 Taking into account the sifting process shown in the table above, and proposed additions to the policy, this Environmental Report focuses on the following key proposed changes:
1. No separate section on skiing developments has been included in the draft consolidated SPP. This means that although development plans will no longer be required to include specific policies on skiing development, relevant areas may choose to retain or include specific policies.
2. The requirement to classify all the coast into one of the three types in the development plan has been removed, although the distinction between the types retained to act as a general guide to development on the coast
3. National maximum parking standards applied to specific types and scales of development have been removed from national planning policy.
4. Amendment of the policy on new junctions on trunk roads and motorways.
5. Policy on protection of prime quality agricultural land has been strengthened in the SPP.
6. A new section on community engagement has been included.
1.19 At this point in the process, it is not considered necessary to undertake further assessment work that considers the environmental effects of the remainder of the draft SPP, as this is in effect a re-presentation of an existing policy, as opposed to a new policy proposal.
1.20 However for each of the proposed policy changes, the broader content of the draft SPP has been taken into account to ensure that the environmental effects of the policy as a whole are fully understood.
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