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3. ENVIRONMENTAL EFFECTS OF THE PROPOSED CHANGES TO SCOTTISH PLANNING POLICY

3.1 This section of the Environmental Report sets out the findings from the assessment of the proposed substantive changes to national planning policy.

3.2 It firstly summarises the key proposed changes to the SPP, and subsequently explains their respective environmental effects and effects of reasonable alternatives to them. Recommendations arising from the assessment are set out. The potential for cumulative and synergistic effects on the environment arising from the combined policy changes is discussed. The full findings from the analysis of each key change are set out in Appendix 2.

Summary of predicted environmental effects

Key Change 1: Skiing Developments. No separate section on skiing developments has been included in the draft 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.

3.3 Description of change: The policy specifically relating to skiing development, as contained in NPPG12, has not been included in the consolidated SPP. This is because the requirement for a sector specific policy has diminished since the policy was adopted in 1997, and its protective policies are reflected in other relevant subject areas contained within the SPP. When adopted, NPPG12 was envisaged as only having a 5 year lifespan.

3.4 The assessment therefore considers the environmental effects of removing policy on skiing developments that:

• prioritises the expansion of facilities in existing areas,
• sets out criteria for new centres and
• provides for associated off-slope development in nearby settlements,

3.5 Based on the assumption that the changes could lead to an increase in skiing development beyond existing centres which is not necessarily proactively or strategically planned, ⁵⁶ but that the risk of this is low, the following environmental effects are predicted:

• Minor effects on biodiversity, given the particular value of upland areas for biodiversity, as noted in the Scottish Biodiversity strategy and the potential effects that can arise from recreational activity in these areas. Whilst climate change may lead to arctic-alpine habitats and the species depending on them such as dotterel and snow bunting becoming more vulnerable over the long term, climate change impacts are also likely to reduce the risk of any large scale skiing developments occurring.
• Minor conflicts with climate change mitigation goals arising from an increased risk of increased travel by car to more remote skiing locations and associated emissions. This effect would depend on the level and location of any future skiing developments but is not, from a national perspective, expected to be significant.
• Some minor risks to the upland water environment, given its generally high quality and likely sensitivity to this type of recreation development. Similar issues for soil were identified in the assessment.
• Possible minor adverse effects on the cultural and scenic value of landscapes including vulnerable areas such as wild land. These are not, however, expected to be significant given the assumption that the likelihood of large scale permanent skiing development is low.

3.6 Links with the broader content of the draft SPP: The identified environmental effects will be avoided or minimised by the broader content of the SPP, as follows:

• Biodiversity and landscape: paragraphs 89 to 107 of the draft SPP provide the policy framework for protection of natural heritage resources. The hierarchy of designations sets out a robust framework for decision making on developments that could affect the natural environment. Reference to the European Landscape Convention reflects the increased status of broader landscapes including those of cultural heritage value, and this in turn should minimise any risks to non-designated landscapes arising from the proposed policy change. The need to protect wild land is also noted in the draft SPP.
• Climate change: Paragraphs 37 and 185 of the draft SPP note the importance of planning in responding to climate change, with the former stating that this will be explored further in guidance on planning for sustainable development. The contribution to mitigation targets is also emphasised in relation to the transport policy section (paragraph 120) which states that there is a need to reduce the need to travel by car, as part of a wider contribution to climate change mitigation.
• Water: Paragraph 92 of the draft SPP notes the importance of protecting the water environment, covering lochs, ponds, watercourses and wetlands.

3.7 Alternative: The only reasonable alternative considered as part of the policy making process was retention of the existing NPPG12 policy statements within the draft SPP. Although it is not expected that this alternative would generate any significant environmental effects, there are risks that continuing to concentrate this type development in existing skiing centres could lead to capacity being breached over the long term.

3.8 Recommendation: The assessment shows that there is not a strong environmental requirement to explore any further options or to reject the change as a proposed policy amendment within the draft SPP. As explained above, mitigation is already provided within the broader text of the draft SPP.

Key change 2:Coastal classification. The requirement to classify all the coast into one of the three types in the development plan has been removed from the draft SPP. However, the distinction between the types has been retained to act as a general guide to development on the coast.

3.9 Description of change: It is proposed that the requirement to classify the coast into one of three types in the development plan is excluded from the draft SPP. This could mean that although many development plans would continue to undertake such an assessment, in some areas a different approach to coastal planning within development plans may be assumed. It is important to note that recommended levels of protection for different types of coastal area have, however, been retained within the draft SPP. This includes a preference for development requiring a coastal location to be focused on the developed coast, with development on the undeveloped coast only being appropriate where it is socially or economically justified, and a presumption against development on the isolated coast.

3.10 The following environmental effects are predicted as a consequence of this proposed policy change:

• Adverse effects on the biodiversity of coastal areas which may be individually minor but could become cumulatively more significant over the long term. Coastal habitats can be particularly vulnerable to development, are often internationally or national protected, and have experienced significant levels of decline over a prolonged period. ⁵⁷ Their vulnerability may also be heightened by climate change impacts. Whilst the draft SPP does not alter the preference for targeting development on the developed coast, the lack of a regular review of coastal classification within development plans may mean that growing issues of biological capacity and changing environmental sensitivities in the dynamic coastal environment are overlooked. This could have particular impacts on areas that were previously identified as developed coast, where environmental change has been particularly rapid and development pressure is likely to continue.
• Some minor landscape effects may also arise, given the particular value and sensitivity of coastal landscapes. Similar effects may arise for vulnerable coastal heritage resources. Lack of a regular updating of the classification of the coast may mean that opportunities to positively manage changing coastal landscape capacity and cultural heritage sensitivity are overlooked.

3.11 Links with the broader content of the draft SPP: The identified environmental effects will be avoided or minimised by the broader content of the SPP, as follows:

• Coastal planning: Paragraph 73 of the draft SPP sets out the broader policy relating to the coast. This notes the value and importance of the developed coast, as well as wider areas and states that its assets should be protected from inappropriate development. It also states that development plans should provide strategies for coastal protection and priorities for enhancement and regeneration.
• Biodiversity and landscape: paragraphs 89 to 107 of the draft SPP provide the policy framework for protection of natural heritage resources. The hierarchy of designations sets out a robust framework for decision making on developments that could affect the natural environment. Reference to the European Landscape Convention reflects the increased status of broader landscapes, and this in turn should minimise any risks to non-designated coastal landscapes arising from the proposed policy change.

3.12 Alternative: The only reasonable alternative considered as part of the policy making process was retention of the existing requirement to classify the coast. It is not, however, expected that this would necessarily address the environmental issues identified in the assessment, and so no significant positive environmental effects were predicted from this policy alternative.

3.13 Recommendation: The assessment shows that there is not a strong environmental requirement to explore any further options or to reject this as a proposed policy amendment. The broader content of the draft SPP, as set out above, means that there is no need to propose additional mitigation measures.

Key change 3 : Transport - parking standards. The requirement for certain types of development to comply with national maximum parking standards is not included in the draft SPP..

3.14 Description of change:SPP17 requires that at and above specified development size thresholds, national maximum parking standards apply and that special measures are required if councils seek to exceed the standards. This has not been included in the draft SPP. It does not specifically refer to the requirement to meet national maximum parking standards, but maintains an emphasis on regionally defined maximum parking standards for on-site parking at new development.

3.14 As a result, the assessment focuses only on the effects which may arise from the specific exclusion of national standards from planning policy. It is important to note, however, that this requirement will still be referred to in advice issued by the Government and exclusion from the SPP does not reduce the status of the existing wider commitment to use of maximum rather than minimum parking standards as part of a demand management strategy.

3.15 The assessment concluded that the policy change is unlikely to generate any significant environmental effects, as it is only applicable to a limited number of developments. However, the following minor environmental effects were predicted from this policy change:

• Possible minor and local adverse effects on health, as the policy could reduce levels of physical activity where car transport is prioritised in the place of walking and cycling networks. Indirect effects may also arise in some areas as a result of increased air pollution arising from car transport generated by large scale development. These effects are not expected to be significant, given the likely requirements for transport impact assessment at the project level.
• Negative effects in relation to the environmental and resource performance of the transport sector, including with regard to climate change related emissions. Whilst significant negative effects are unlikely as local standards will still apply, the proven benefits of national maximum parking standards in helping to promote the use of more sustainable transport could be reduced as a result of this policy change.
• Negative impacts on air quality in some areas, although this will depend on the location and scale of developments and the effectiveness of local and regionally defined maximum parking standards in reducing reliance on the car.

3.16 Links with the broader content of the SPP: The identified environmental effects will be avoided or minimised by the broader content of the SPP, as follows:

• Transport and parking: Paragraph 125 of the SPP notes the continuing policy commitment to locally defined (as opposed to the national) maximum parking standards as part of the delivery of a modal shift.
• Transport and health: Throughout the SPP, the importance of prioritising active and public transport options is emphasised. Opportunities for this are noted in relation to business, town centres and planning for homes. In addition, the section on transport (paragraph 120) reflects on the Scottish Government's broader commitment to reducing emissions from the transport sector and notes the role of planning in achieving this.
• Air quality: Whilst the policies on transport in the draft SPP do not specifically refer to air quality, the broader commitments to reducing emissions and achieving a modal shift indirectly support air quality objectives and should assist with mitigating the potential effects identified above.

3.17 Alternatives: The only reasonable alternative that has been considered as part of the assessment is continuing to include the existing table of national maximum parking standards for specific types and scales of development. Whilst more positive effects could be expected from this alternative, these are also not expected to be significant.

3.18 Recommendation: The assessment shows that there is not a strong environmental requirement to explore any further options or to reject this as a proposed policy amendment. No significant environmental effects are expected and as a result no specific mitigation measures have been proposed in response to this proposed policy change.

Key change 4: Transport - new junctions. Adjustment of the policy on new junctions on trunk roads and motorways.

3.19 Description of change: The existing SPP states a general presumption against new junctions onto motorways or trunk road junctions, except where nationally significant economic growth or regeneration benefits can be demonstrated. The draft consolidated SPP replaces this with statements that new junctions are not normally acceptable and that exceptions would arise where national or regionally significant benefits can be proven. This is a subtle adjustment, but has been included in the assessment given the potential environmental sensitivity of the topic area.

3.20 Taking into account the minor nature of the changes that are likely to arise from this policy change, the following environmental effects are predicted:

• Conflicts between the policy change and wider transport policy aspirations to reduce emissions and increase the modal share of more sustainable forms of transport.
• Impacts on air quality, given the established link between transport emissions and concentrations of air pollution around major settlements and infrastructure. In some cases additional well planned and strategically located junctions may initially reduce congestion and therefore emissions, but this may be overtaken by negative effects in the long term.
• Minor negative effects on health and population arising from the emphasis that the policy change would place on car transport as compared to active travel, and in terms of long term secondary effects on health resulting from an increase in air pollution. Most effects on communities living close to any proposed new junctions would be temporary, arising during the construction stage. As a result of opportunities for project level mitigation, these effects are not expected to be significant.
• Minor adverse effects on water and soil arising from construction of additional junctions, with potential for longer term effects as a result of pollution generated by associated traffic generation.
• Similar potential for adverse effects arising for landscape, biodiversity and cultural heritage. This may arise from the land take required for construction of new junctions, or more indirectly as a result of the potential increase in road traffic and infrastructure that may develop over the longer term. Effects are not expected to be significant as a result of opportunities for scheme level mitigation.

3.21 Links with the broader content of the draft SPP: The identified environmental effects will be avoided or minimised by the broader content of the SPP, as follows:

• Transport, emissions and air quality: Broader policy on transport (paragraphs 120 -124) continues to emphasise an overall commitment to minimising transport emissions, thereby reducing the risk of significant adverse effects on these environmental topics.
• Health and population: the new section on community involvement in the planning process (discussed below) should, together with policies on environmental protection, reduce adverse environmental impacts on health and population.
• Water and soil: Paragraph 92 of the SPP notes the importance of protecting the water environment, covering lochs, ponds, watercourses and wetlands. Although soil is only referred to in relation to renewable energy developments and prime quality land (see below), transport policy (paragraph 121) notes the need to take into account environmental constraints within the planning process.
• Landscape and biodiversity: paragraphs 89 to 107 of the draft SPP provide the policy framework for protection of natural heritage resources. The hierarchy of designations sets out a robust framework for decision making on developments that could affect the natural environment. Reference to the European Landscape Convention reflects the increased status of broader landscapes, and this in turn should minimise any risks to non-designated coastal landscapes arising from the proposed policy change.
• Cultural heritage: Paragraphs 79 to 88 provide continuing protection for the historic built environment, thereby mitigating against any significant adverse effects arising at the project level from this proposed policy change.

3.22 Alternatives: The only reasonable alternative that has been considered as part of the assessment is maintaining the existing planning policy on the creation of new junctions onto the trunk roads network. Given the subtlety of the policy change and the continuation of wider regulation, project level design and mitigation, it is considered unlikely that continuation of the existing policy would substantially reduce the risk of negative environmental effects from the policy change.

3.23 Recommendation: The assessment has highlighted some potential environmental effects that will require mitigation. Mitigation will be largely deliverable at the project level, and will be deliverable through existing regulatory and consenting regimes. Whilst the SEA does not specifically support introduction of the policy change, no major issues have been identified that suggest that it cannot be implemented without generating significant adverse environmental effects.

Key change 5: Prime agricultural land. Strengthening of policy on prime agricultural land to indicate the limited circumstances under which its development may be acceptable

3.24 Description of change: The draft SPP introduces enhanced protection for prime quality agricultural land, as follows: "Prime quality agricultural land is a finite national resource. Development on prime agricultural land should not be permitted unless it is an essential component of the settlement strategy or is necessary meet an established need, for example for major infrastructure development, where no other suitable site is available. Small scale development, including housing, directly linked to rural businesses may also be permitted. Renewable energy generation development or minerals extraction may be acceptable where restoration proposals will return the land to its former status."

3.25 The following assessment is based on the assumption that in most cases this could result in a displacement of development pressure away from prime quality greenfield land in favour of a further increase in the uptake of lower quality or brownfield land. Changes may be particularly significant along the east coast where prime quality land is concentrated.

3.26 On balance, it is expected that the policy should contribute positively to achieving long term growth, development and regeneration in a sustainable way. The following environmental effects were identified in the assessment:

• Positive effects on biodiversity, landscape and cultural heritage. Agricultural land can have special qualities, supporting a range of habitats and species and forming the setting of settlements. Agricultural land can be a valued part of cultural landscapes, heritage and identity in its own right. The assessment explored each of these environmental assets and noted that although prime quality agricultural land does not necessarily hold any greater value than other areas, ongoing programmes of sustainable management and enhancement would be supported by the policy change, and this in turn could generate long term positive effects.
• Positive effects on water and soil, with the change supporting wider emerging policies within the Scottish Soil Framework, Flooding Bill and River Basin Management Plans.
• General support for the sustainable management of land and resources generally and complementarity with the climate change agenda. In particular, protection of open areas including prime land should enhance the scope to respond to the challenge of long term adaptation to the impacts of climate change.

3.27 Links with the broader content of the draft SPP: No negative environmental effects were identified in relation to the above policy change. The policy change has the potential to minimise the environmental effects of a range of other development types that are promoted within the broader draft SPP and is not expected to result in any direct conflict with broader policy aspirations within the draft SPP.

3.28 Alternatives: No other reasonable alternatives to this proposed change were explored during the course of the assessment.

3.29 Recommendation: On the basis of the positive environmental effects identified above, the assessment has recommended that the proposed policy change is included in the draft SPP. No requirements for mitigation have been identified.

Key change 6: Community engagement. Additional text reflecting planning modernisation.

3.30 Description of change: A new section has been included in the draft SPP that sets out the Government's expectations relating to community engagement in the planning system. This notes the increased status of engagement in the modernised planning system, reflecting the Planning etc. (Scotland) Act 2006. The policy text notes the opportunities this will provide for communities to be engaged in shaping the future of their area, and for planning authorities to provide a clearer basis for plan and decision making. The policy states that planning authorities and developers should ensure appropriate and proportionate steps are taken to involve communities in development planning and development management.

3.31 This policy addition has not been subjected to a detailed assessment against the SEA objectives and criteria, as its effects will be largely indirect and will only emerge as the SPP is implemented. However, it is expected that the change will have positive effects on population and human health as it reinforces the importance of community involvement in shaping plans and decision making. The change will also support the more inclusive approach to environmental management that is promoted within wider PPS such as the European Landscape Convention.

3.32 Links with the broader content of the draft SPP: This policy change supports the broader content of the draft SPP by emphasising a cross sectoral requirement for involvement in the planning process. .

3.33 Recommendation: The SEA findings support the inclusion of this additional policy statement within the draft SPP.

Exploration of potential cumulative and synergistic effects

3.34 This section of the Environmental Report brings together the identified environmental effects of each part of the draft SPP, to help identify any cumulative and synergistic effects arising from the changes to the policy as a whole. Whilst no significant effects are expected from the individual policy changes, it is important to check that these effects are not amplified as a result of their combined effects. The analysis also helps to ensure that no spatially cumulative effects result in unacceptable levels of pressure being placed on particular areas. The role of the consolidated SPP in influencing the hierarchy of development plans underlines the importance of examining the scope for cumulative effects.

3.35 The table below brings together the findings from the assessment of individual changes, to help identify potential for cumulative and synergistic effects. No significant cumulative or synergistic effects have been identified from the combined policy changes, but the analysis highlighted the following potential issues:

• Cumulative effects (shown in red):

? on increasing the share of transport by sustainable mode arising from the combination of the two proposed changes to transport policy. Given that each change will only have minor effects on these criteria, and the effects are not closely interlinked (e.g. concentrated on particular types of development or in a single location), these are not expected to be significant.

? on transport emissions including CO ₂ from the changes to transport policy combined with the changes to skiing policy. Similarly, effects may arise cumulatively on air quality as a result of the changes to transport policy and the proposed policy on protection of prime quality agricultural land. However, significant cumulative effects are not expected from these effects as they are generally minor, avoidable through project level mitigation and would be geographically dispersed.

? on landscape arising from the combined changes. However, this was not considered to be a likely cumulative effect as change would occur in different areas and landscape types (e.g. the coast, upland and transitional areas), and effects would be minor and localised.

• Synergistic effects (shown in blue):

? as a result of the interaction of biodiversity, cultural heritage and landscape change in coastal areas, when combined with the impacts of climate change. These effects would be long term and are not expected to be significant in light of the broader protection for the coast that is included in the SPP.

? from the interaction of impacts on water, soil, and biodiversity arising from the construction of additional road junctions. These potential localised synergistic effects are not considered significant from a national perspective in light of established mitigation and regulatory regimes.

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