National Planning Framework 4 - draft: consultation analysis

Impact Assessments

The following Impact Assessment Reports, along with supporting information, have informed and been published alongside the draft NPF4:

• Strategic Environmental Assessment: Environmental Report.
• Society and Equalities Impact Assessment Report.
• Partial Business and Regulatory Impact Assessment.

The number of respondents commenting at Questions 59 - 70 tended to be lower than at other questions. A small number of respondents submitted more detailed responses. As with all other comments, these are available to the Scottish Government.

Strategic Environmental Assessment: Environmental Report

The consultation asked five questions about the SEA: Environmental Report.

Question 59 – What are your views on the accuracy and scope of the environmental baseline set out in the environmental report?

Around 50 respondents made a comment at Question 59, with a number of respondents noting that they agreed, or agreed in principle, with the environmental baseline set out.

Positive comments about the accuracy and scope of the baseline set out included that it is comprehensive, appropriate and proportionate to enable the impacts of implementing NPF4 to be suitably measured through monitoring arrangements. Elements which respondents particularly welcomed included:

• The extensive use of maps.
• The identification of key pressures and trends affecting the baseline.
• Recognition of the undesignated historic environment.

However, there were also some broader concerns. These included that there are many caveats, the baseline is not far-reaching enough, and that the lack of data for the last 3-4 years, especially in the water and pollution context, is problematic. There was also a concern that the baseline appears to be centred on analysis and statistics principally provided by NatureScot. There was a call for an independent scientific review of the accuracy and scope of the environmental baseline, to ensure that this is the correct starting point.

There was also a view that the environmental baseline is very optimistic, including in relation to biodiversity losses, the condition of our soils, and the state of our freshwaters and some marine habitats.

Comments relating to the overall scope included that:

• The longstanding decline in biodiversity and woodland cover is given less attention than the positive aspects of the natural environment in Scotland.
• The marine environment is outwith planning jurisdiction.
• There is no recognition that some of the greatest impacts, such as that of agriculture on the condition of protected sites, are not managed or directed by the planning process.

There were also a number of specific aspects that respondents wished to see covered. These included:

• The Key Pressures and Trends section could recognise a number of positive interactions between the historic environment and other policy areas.
• The Action Areas section does not use an appropriate measure of the contribution of scheduled monuments. and it is not clear whether the scheduled monument data that is given has informed or influenced the development of the action areas. Also, the data insights do not include any other historic environment assets and places, such as listed buildings and conservation areas. This may have led to a lack of recognition of the contribution historic environment resources can make to the delivery of the spatial strategy.
• The baseline for biodiversity, flora and fauna should additionally, where relevant, include World Heritage Sites, such as St Kilda.
• There should be specific mention of Local Landscape Areas.

Other topics that respondents wanted to see covered in the environmental baseline included:

• In relation to ND7 (Island Hub for Net Zero), reference to Scapa Flow MPA.
• Increased wave heights.
• The possibility of changing windspeeds, notably extreme gusts, which will affect not only residential properties and their design, but also electricity network resilience and renewable energy generation technologies.
• The contribution of soil biology/biodiversity to the sequestration of carbon and how the inappropriate application of pesticides and fertilisers contributes to carbon losses through depletion of soil biota.
• Temperate rainforests, which are of significant national value and are under extreme threat from invasive species, overgrazing and direct loss.

It was also suggested that a map of remnant ancient woodland in Scotland should be added.

In terms of content that respondents wished to see changed, there was reference to:

• The coverage of the significance of the increased volatility in weather.
• References to 'nuisance', for example in relation to noise. It was suggested that these should be replaced with 'adverse' impact. It was noted that 'nuisance' has a legal definition which is not part of the NPF4.

It was also suggested that Appendix B (Relevant Plans, Policies and Strategies) should be cross-referred to within NPF4 itself.

Finally, it was suggested that the accuracy and context of the predicted environmental effects could be improved by the full delivery of the Better Biodiversity Data Project. The focus will be on delivering a world-leading data management system for the whole of Scotland – linking through local, regional and national data collection, use and analysis.

Question 60 – What are your views on the predicted environmental effects of the draft NPF4 as set out in the environmental report?

Around 40 respondents made a comment at Question 60.

Some of these respondents either noted that they agreed, or agreed in principle, with the predicted effects. However, it was also suggested that the assessment is inadequate or optimistic. It was also described as hard to validate and there was a call for further detail on how biodiversity, climate and environmental targets are decided upon, and are to be measured and enforced.

Further comments included that the assessment should cover or include:

• An estimation of the effects of a successful reduction in greenhouse gases.
• The possibility that global warming is other than anthropogenic.
• The impact of the removal of greenspace, and particularly the last greenspace, on communities.

It was also suggested that the significance of NPF4 in meeting the requirements of relevant environmental legislation is not made clear in the SEA. An example given was that in relation to ND7 (Island Hub for Net Zero), it is noted that consideration needs to be given to the implications of European sites. There is, however, no mention of meeting the requirements of the Habitat Regulations in either the mitigation/opportunities section or the text of ND7 in the draft NPF4.

Habitats Regulations Appraisal (HRA) and national developments

It was noted that in the Initial Screening Record for the HRA, the draft spatial strategy and all the draft planning policies, have been scoped out as having no likely significant effects. It was also noted that only a partial HRA process appears to have been carried out in respect of some proposed national developments.

However, it was suggested that Policy 19 (Green energy) should be screened in, as it clearly supports more renewable energy development across the whole of Scotland, and does not guide these away from European sites specifically. This was considered to be of particular concern given that LDPs are no longer required to contain spatial locational guidance for onshore wind (which previously listed European sites as 'Areas of Significant Constraint').

It was suggested that, at this advanced stage of the NPF4 process, the draft HRA should have been provided for comment, and that this information must be made available before any further consultation and Parliamentary scrutiny is undertaken. It was also noted that NPF4 should not be approved by Parliament, and cannot be brought into effect or adopted, until the competent authority, in this case the Scottish Government, has undertaken full appropriate assessment.

ND7. Island Hub for Net Zero

There was agreement that ND7 should be screened in, and also suggestions for other issues to be considered. These included that:

• The reasoning should have included potential for any onshore wind development in Orkney, Shetland and the Outer Hebrides to affect SPAs.
• The summary of foraging distances during the breeding season appears to have only included some species.

Other points raised included that:

• The screening report has considered all Ramsar sites as if they were European sites. While this approach is welcome, it does not match the policy within NPF4 itself where impacts on Ramsar sites are assessed according to their underlying designation.
• Islands also have a relatively limited amount of available land for development. This makes taking a place-based and plan-led approach to the delivery of this national development even more important. This should be supported by a requirement for collaborative working. Working in this way will ensure that the full range of benefits to development can be achieved, by making sure that an inclusive understanding of planned development is achieved.

ND8. Industrial Green Transition Zones

It was noted that the delivery of infrastructure to support ND8 has the potential for significant effects on the site and setting of both terrestrial and marine historic environment assets, and that the SEA identifies a potential adverse effect. It was also reported that the reuse of existing infrastructure has the potential for positive effects where assets of historic significance can be reused and maintained, particularly designated industrial heritage.

With specific reference to the flood protection scheme at Grangemouth, it was suggested that coastal squeeze should be included in the predicted environmental effects section.

ND10. Hunterston Strategic Asset

Comments included that, in addition to Kelburn Castle, there are a number of other nationally important heritage assets that may be affected by ND10. This includes some scheduled monuments, and also the category A listed building Hunterston Castle and its associated designed landscape. It was suggested that project level proposals will need to give detailed consideration to such impacts, and identify mitigation to minimise them.

It was also noted that the site is an existing port and its operational activities are anticipated to be in line with other ports situated around the coastline of Scotland. It was suggested that matters of shipping are outwith the planning jurisdiction, and that the UK Marine Policy Statement would be the principal policy statement in this regard.

ND12. Strategic Renewable Electricity Generation and Transmission Infrastructure

It was suggested that the delivery of projects to support ND12 has the potential for significant environmental effects. This includes effects on the site and setting of both terrestrial and marine historic environment assets.

There was also a concern that, despite recognition that the development types included within ND12 have a high likelihood of causing significant effects on European Sites, it has then been screened out from requiring HRA Stage 2 – Appropriate Assessment solely on the grounds of non-spatial definition.

It was also noted that there will be no other means of directing development away from European sites, or providing other mitigation, at a strategic/plan level. It was suggested that recognition of the cumulative pressures on European sites and the need to avoid them, along with the need to fully assess the impacts of any further developments, should be made within NPF4.

Other comments included that:

• A partial HRA process raises potential legal risks for any proposals coming forward under ND12. There was a request for the Scottish Government to confirm that the HRA has been subject to a full legal review and to review the implications of designating non-spatial national developments.
• A plan-led approach would give more certainty for communities, developers, decision-makers and consultees. It will also ensure that ND12 is in line with NPF4 Policy 1 (Plan-led approach to sustainable development). Taking this approach would not change the fact that site specific assessments, and consenting processes, are critical to sustainable outcomes.

Other national developments

Comments on other national developments included that:

• ND1. Central Scotland Green Network. Opportunities to maximise landscape benefits should also tie in with local heritage and larger designations such as Gardens and Designed Landscapes and Battlefields.
• ND4. Urban Sustainable, Blue and Green Drainage Solutions. Any opportunities to enhance and promote access to the historic environment should be maximised. While negative effects have been predicted, there is also the potential for positive effects. Innovative water management in placemaking can use historic environment assets as part of drainage solutions. A good example of this is the Glasgow Smart Canal project.
• ND5. Circular Economy Materials Management Facilities. Reuse of materials in replacement schemes for buildings and features can be positive in terms of the character and appearance of our places and spaces. ND5 may have a positive role to play in the availability of materials. This is important in the context of an increased focus on the reuse and maintenance of our existing assets.
• ND14. Clyde Mission. The key role that the historic environment can play in successful placemaking was noted. It was suggested that there is potential for positive effects through: promotion of proactive care; maintenance and climate change adaptation of historic environment assets; and increased understanding of and sustainable access to historic environment assets. It was suggested that these potential positive effects are most likely to be realised effectively through the integration of enhancement measures at a high level, as well as at the project level.
• ND16. Dundee Waterfront. It was noted that all zones have the potential to impact on the site and setting of historic environment assets, with the port area particularly sensitive. The port area also contains much infrastructure of historic environment interest which presents the opportunity for positive reuse.
• ND18. Stranraer Gateway. Stranraer's historic environment is a key placemaking asset and all project proposals should recognise this.

Question 61 – What are your views on the potential health effects of the proposed national developments as set out in the environmental report?

Around 35 respondents commented at Question 61, with those comments tending to be brief. They included broad notes of agreement with the potential health effects as set out, but also that positive impacts do rest on the positive environmental impacts identified being achieved.

Other general issues raised included that prioritising biodiversity and nature recovery through planning policy has immense potential for restoring human health and wellbeing. In particular, mental health within the population could really benefit if the protection and expansion of native habitats is actively demonstrated, and visible to the community. However, an alternative view was that Scottish Government energy policies are causing mental anguish for communities, who are witnessing the destruction of their precious land and seas. There was specific reference to families living near windfarms, turbine noise and flicker.

Other comments included that there should be reference to:

• The water environment. It was reported that energy, transport and some land management pollution changes and reductions could well contribute to welcome health benefits, especially in the atmospheric environment. However, it was also suggested that the situation is much less clear for the water environment.
• The dangers of the toxic epoxy resins from turbine blades as a future unknown risk.
• The health benefits that can be achieved from e-mobility and how alternative fuels can improve air quality and health by removing internal combustion engine vehicles from the roads, in favour of more sustainable forms of transport.
• Particulate matter (PM) pollutants (both PM10 and PM2.5 sizes) largely produced by road traffic. Lack of reference to these particulates was suggested to be a major omission.

It was also noted that, in relation to Policy 10 (Sustainable transport), there is no mention of noise, and no reference is made to the Design Manual for Roads and Bridges.

In terms of specific areas, a respondent questioned whether there will be health benefits associated with plans for Aberdeen Harbour. With regard to training opportunities and employment, it was thought doubtful that people from Torry will be qualified to take advantage of these opportunities, including because the prevalence of chronic illness and mental illness is high and educational attainment relatively low. It was also suggested that health inequalities will be exacerbated by removing the community's last accessible green space.

Question 62 – What are your views on the assessment of alternatives as set out in the environmental report?

Around 30 respondents made a comment at Question 62, with comments tending to be brief. They included that the assessment is potentially very useful, or that respondents agreed with it in principle. Alternatively, it was suggested that not enough detail has been provided, that the assessment is inadequate, or is focused on the interests of the Central Belt.

There was also a view that reasonable alternatives should have been identified, particularly where adverse environmental effects are likely. For example, given that the discussion of alternatives to Policy 19 (Green energy) recognises that it is difficult to predict how impacts may differ between the proposed policy and current SPP, and that keeping the existing SPP approach would mean a greater level of protection may be afforded to sites and species, it was suggested that the existing approach should be retained.

The assessment of the alternative national developments was welcomed, although it was assumed that further assessment will consider the environmental impact of proposals in further detail.

In terms of specific alternatives that respondents wanted to see included or given greater coverage, observations included that:

• In relation to Policy 19 (Green energy) and Policy 32 (Natural places), there should be an additional alternative. This should maintain the protection of non-designated sites and species, as well as wild land, but allow specific applications to go ahead, if they can show (in a measurable way) that the climate benefits of the project would outweigh the harm, or if the harm in that particular area could be shown to be negligible.
• There should be alternatives that are in the best interest of the community, such as using the industrial estates already available, and not destroying green sites.
• There is no reference to nuclear power.
• Regarding North East Transport Investment, the potential effects on the historic environment are likely to include negative effects on the site and setting of historic assets and places from the introduction of new transport infrastructure. There will also be effects on existing historic infrastructure such as stations, bridges and access structures.
• Regarding the Climate Evolution Zone including Blindwells, Cockenzie and the ETZ, developments in this area have the potential to impact on the Inventory of Historic Battlefields site of the Battle of Prestonpans, and this is not mentioned.
• In the assessment summary covering the Ardeer Peninsula, the potential for effects on the historic environment caused by the redevelopment of the ICI complex at Ardeer should be noted.

There were also references to the potential impact on the historic environment needing to be considered in relation to: Edinburgh, East Lothian and Midlothian Innovation Zone; Freeport on the Clyde; National Low-Carbon Freight Network; West Edinburgh; Zero Carbon Innovation Zones; Lochaber Smelter; and space ports.

Parts of the assessment with which respondents disagreed, or wished to see amended, included:

• The suggestion that renewable green energy generation could lead to a negative impact on biodiversity. It was suggested that there is now ample evidence showing that solar photovoltaics increase biodiversity net gain and generate natural capital.
• The reference to the electric vehicle network refers to electric vehicles being quieter. It should be changed to state that electric vehicles are quieter when travelling at low speeds.

It was also noted that the summary assessment findings for the space industry and space ports do not include any identified effects on the historic environment, but that significant impacts have been identified in relation to historic environment assets, including scheduled monuments. It was seen as important that potential impacts on historic environment assets are considered at an early stage of project development.

Question 63 – What are your views on the proposals for mitigation, enhancement and monitoring of the environmental effects set out in the environmental report?

Around 35 respondents made a comment at Question 63.

While some respondents noted their agreement with the proposals for mitigation, enhancement and monitoring, others saw them as inadequate, probably unenforceable, or suggested that insufficient information has been provided.

Other comments included that there is a real danger that NPF4 will not protect and enhance biodiversity to the extent needed to deliver transformational change; without a clear mechanism for delivering enhancement, and clear wording to ensure the mitigation hierarchy is followed and protected sites are protected, the assumed mitigation is unlikely to be delivered.

An associated point was that NPF4 will be influential in determining the focus and content of LDPs as well as determining development proposals. Given this, it was described as imperative that the findings of the SEA lead to actions which are embedded in NPF4, and that the SEA is not used as a barrier to implementation but as an opportunity to incorporate strong environmental principles throughout NPF4.

With specific reference to mitigation, comments included that this should not be used as an excuse for allowing otherwise unacceptable environmental degradation or damage.

In relation to monitoring, it was suggested that the Environmental Report does not appear to set out any detailed monitoring arrangements, making it difficult to comment on the suitability of the monitoring programme. It was assumed that further information will be published at a later date.

With regard to the national developments, comments included that:

• There seems to be a lack of appreciation of the potential influence of detrimental change to biodiversity throughout the mitigation subunits. It was suggested that improvement of biodiversity should be included and inherent in any and every approach for mitigation, enhancement and monitoring of environmental effects.
• In relation to ND7 (Island Hub for Net Zero), it is doubtful that providing low carbon transport options to sites to reduce car dependency would address the most serious environmental impacts directly related to renewable energy generation, renewable hydrogen production, infrastructure and shipping, and associated opportunities in the supply chain. As such, it was questioned why it has been included under specific mitigation/opportunities for this national development in the SEA.
• In relation to ND12 (Strategic Renewable Electricity Generation and Transmission Infrastructure), there is reference to screening options being considered to minimise the visual impact of developments. It was argued that screening may be an option in some circumstances, but there will be many developments for which siting and design will be of more relevance in minimising visual impact and this should be acknowledged.

Society and Equalities Impact Assessment

The consultation asked seven questions about the Society and Equalities Impact Assessment.

Question 64 – What are your views on the evidence and information to inform the society and equalities impact assessment?

Around 25 respondents made a comment at Question 64. General comments included that the evidence and information appear reasonable, or that the breadth and scope of the baseline information is good. However, there was also a view that the evidence and information, or the EQIA process, is not objective. It was also suggested that the recommendations within the EQIA could be more strongly reflected in NPF4's policies, for example, in relation to housing need, equality and human rights.

In terms of the assessment process, comments included that:

• The non-technical summary should be a living document, especially given the long-term nature of NPF4.
• Robust data measuring and evaluation, including an ongoing impact assessment, will allow for in-plan adjustments to particular policies found not to be meeting desired equality outcomes.

It was suggested that the Equality and Human Rights Commission's measurement framework for equality and human rights may assist both government and local authorities with the collection of equality data.

There was also a recommendation that Equality, Diversity and Inclusion (EDI) benchmarks, measures and reporting be carried out in order to track and monitor progress on EDI on an annual basis, as well as society and equalities impact assessments.

It was also suggested that, in addition to having IIAs to refer to, there would be value in the final NPF4 being accompanied by a simplified graphic that would map key provisions of NPF4 against high-level outcomes (including those derived from duties covered by the assessments); this could act as a useful reminder as to what is sought, what is aimed to be delivered and in what manner.

In relation to the evidence used, it was noted that the EQIA references a broad evidence base and cites various reports that are not referred to in the draft NPF4, including: Social Renewal Advisory Board Report (2021); Social Capital in Scotland Report (2020); Public Health Priorities in Scotland (2018); and the National Standard for Community Engagement. It was described as heartening to see that such a body of evidence has been considered, but it was noted that the confinement of this evidence base to the EQIA requires that this be read in order for the policies in NPF4 to be understood in their entirety.

Comments about specific information used included that:

• The inclusion of Public Health Scotland evidence and comments is welcome.
• In relation to population and human health, the conditions of children and families in poverty and experiencing deprivation have worsened during the COVID-19 pandemic and it is likely that the detailed information included within the current draft is outdated.
• Evidence and information can now be drawn from the Census for Showpeople. Prior to Scottish Gypsy/Travellers receiving legal status as an ethnic group, they were treated 'as if' they had that legal status. Given that Showpeople, by virtue of being widely considered as part of a wider travelling community, experience the same social and to a lesser degree economic discrimination and disadvantages due to their lifestyle, the Scottish Government should offer a similar status. The current anomaly means that Showpeople experience similar social discrimination yet none of the protections ascribed to other communities, and this creates a vacuum in the planning process.

Finally, it was noted that while the EQIA cites a comprehensive range of evidence to show how planning may impact on protected groups, this is presented without criticism or comment, and it is therefore left up to the reader to interpret how to use this information to deliver equal outcomes for all groups.

Question 65 – Do you have any comments on the findings of the equalities impact assessment?

Around 20 respondents made a comment at Question 65.

General comments included that while it is welcome that 'improving equality and eliminating discrimination' is a stand-alone outcome of NPF4, there is also a need to apply an equality lens/priority to each of the other required high-level outcomes and the ensuing strategies, developments and policies.

It was suggested that more could be done to emphasise the cross-cutting nature of improving equality and eliminating discrimination. For example, it was suggested that most, if not all, of the actions and policies identified in the draft NPF4 can and should identify how they will support this high-level outcome. The concern was, if not considered from the outset, there is a risk that inequalities will be overlooked, reinforced, perpetuated or exacerbated at implementation stage. It was suggested that in order to move beyond 'suggestions' and 'potential', there needs to be clear evidence and strategies throughout NPF4 on how this will be achieved in practice.

Other comments and suggestions included that:

• The need to comply with the Public Sector Equality Duty should be referenced in the NPF4 and it should be made clear that the duty applies from the strategic policy level right through to the decision-making process. For example, the specific duties that require EQIAs when producing LDPs.
• Cross-cutting themes of sex, disability, race and age should be specifically considered at each stage of the planning process. Links should be made to equality-related policies nationally, regionally and locally.
• References to the Place Standard Tool are welcome, but consideration should also be given to the Health and Wellbeing Outcomes.
• NPF4 is unclear on the interplay between the policies set out in Part 3 – National Planning Policy, existing legal duties set out in the Town & Country Planning (Scotland) Act 1997, the Human Rights Act 1998 and the Public Sector Equality Duty. It would be helpful if the document set out all existing duties and made clear connections to the policies.

It was also noted that there is also currently no statutory requirement under the Equality Act 2010 for the findings for an EQIA to be actioned in practice; it is therefore crucial that the most important equalities considerations are explicitly embedded within the draft NPF4 itself, if Scotland is to achieve a more equitable future.

The recognition that there are a number of societal groups that experience challenges in both engaging with the planning system, and having the system meet their needs, was welcomed. However, there was a concern that there is a lack of consideration throughout NPF4 on how this will actually be tackled. It was suggested that it would be beneficial to understand the barriers to engagement faced by low-income households, particularly those in the priority groups, in participating in engagement on planning decisions. It was hoped that understanding these barriers, and ensuring planning authorities have the processes in place to remove them, will ensure wider engagement with these groups.

Question 66 – Do you have any comments on the findings of the children's rights and wellbeing impact assessment?

Around 20 respondents made a comment at Question 66. General comments included that the involvement of children and young people in the preparation of NPF4 is welcome. It was also reported that Play Scotland has undertaken consultations across Scotland with children and young people which could contribute to the Children's Rights and Wellbeing Impact Assessment (CRWIA).

There was a concern that the conclusions drawn in the CRWIA are simplistic, and that children's human rights and wellbeing would be better protected by much more explicit mention and signposting to other relevant policy objectives, such as the SHANAARI principles (Safe, Healthy, Achieving, Nurtured, Active, Respected, Responsible and Included) and Getting it right for every child (GIRFEC).

Other comments included that while the Impact Assessment includes a good range of evidence, it misses out a few key pieces of place-based research of relevance:

• The Children and Young People's Commissioner Scotland report, 'Scot Youth and COVID 2'. In terms of key themes set out within that report there was reference to wanting to feel safe and included, and to hearing and understanding issues in local areas and improving opportunities for all children and young people.
• A research project (yet to be published) on Enabling Independent Active Travel for Young People in Scotland (funded by Sustrans) was also reported to be highly relevant. The project included working in collaboration with young people and their parents to produce in-depth Active Travel maps.
• A Place in Childhood and Play Scotland's evidence review for the Place Standard tool.

In terms of general issues or themes, it was suggested that the planning process can make a critical difference to tackling poverty and noted that tackling child poverty is a priority for the Scottish Government. Associated suggestions included that a greater focus on child poverty would ensure that this is given suitable priority within planning decisions; it was noted that child poverty is only mentioned once within the draft NPF4.

There was also a concern that there is no mention of UNCRC Article 15: The right to freedom of association, which includes gathering and organising their own activities in public spaces.

Question 67 – Do you have any comments on the Fairer Scotland Duty and the draft NPF4?

Around 15 respondents made a comment at Question 67, with general comments including that it is good to see the Fairer Scotland Duty reflected.

Particular aspects of the Impact Assessment that were welcomed included the recognition that income is a strong determinant for people's ability to respond to, and recover from, climate change impacts and that our future places and spaces need to contribute to improving equality and eliminating discrimination. It was also noted that the assessment has identified a number of key policies which will help tackle inequalities and poverty, including NPF4's spatial strategy, thematic policies and proposed national developments.

However, there was also a concern that the draft NPF4 has an urban bias, or specifically is biased towards the Lothians. There was an associated need for equality of access to services across Scotland, including through necessary and timely investment, for example in digital and transport infrastructure.

It was noted that the Scottish Government has published guidance on how to comply with the Fairer Scotland Duty, including how a 'strategic decision' is to be defined. The list of examples of strategic decisions includes many that are relevant to NPF4, such as the preparation of LDPs, LHSs and locality plans, and it was suggested that the need to comply with the Fairer Scotland Duty should be referenced.

Question 68 – Do you have any comments on the consideration of human rights and the draft NPF4?

Around 35 respondents made a comment at Question 68. The most frequently-made comment was that it is disappointing that there is not currently a specific Human Rights Impact Assessment. Further connected comments included that housing is a human right, but there is no reference to this in NPF4, nor any of the supporting documents. It was suggested that it is vital that Articles 17 and 25 of the Universal Declaration of Human Rights be afforded weight in the preparation of NPF4.

Other comments included that:

• The document does not specify what is encompassed by 'human rights'. It should specifically state whether or not its definition of human rights has a linguistic basis rather than simply a cultural one.
• The consideration of human rights should include potential impacts on the Gaelic language.
• Although the draft NPF4 specifically mentions meeting the needs of disabled people, the focus appears to be only on those who are not in paid work and/or who need supported housing.
• Inflicting national policies on local communities is a violation of their human rights. It was also suggested that there is no real consideration of the human rights of the communities most affected by any developments.

Question 69 – Do you have any comments on the islands impact assessment?

Around 20 respondents made a comment at Question 69. General comments included that no consideration has been given to the island communities affected by development policies. There was specific reference to the treatment of the islanders of Orkney and Shetland, and it was suggested that there needs to be more proactive engagement with island communities about planning.

Respondents highlighted a range of issues that affect island communities, including:

• Housing, with limited opportunities for young families and for older people wishing to downsize from too-large homes into smaller, more convenient houses in less isolated places. It was noted that the lack of affordable housing is the number one challenge and this impacts on everything else, from sustainability of the local economy to the provision of essential services and the viability of school rolls.
• Childcare provision, and the need to plan for it.
• Lack of stable employment, and especially the gendered nature of work. It was suggested that there is a distinct gendered job creation approach, with typically male industries like construction, ports and renewables being focused on.

Other comments included that it is essential to enhance the private sector economy, especially in islands, as global challenges may jeopardise overall national income and the ability to support the desired size and functions of the public sector.

Although an assessment dedicated to island communities was welcomed, it was noted that many mainland communities experience similar issues of fragility and isolation. There was a query as to how these communities might receive the dedicated focus and actions that has been applied to island communities.

In terms of the Island Communities Impact Assessment (ICIA) itself, comments included that:

• It underlines the disadvantages experienced by island communities, particularly young people, and the corresponding need to ensure that NPF4 takes due account of these.
• There is a clear and strong case for including impacts on the Gaelic language. This will require additional analysis, including of the varying degrees of use of Gaelic across Scotland's islands.

With reference to the information presented in the ICIA, comments included that it is difficult to see how it can be used to assess whether NPF4 will have significantly different effects between islands and mainland communities, and also between different island communities. There were also suggestions that the evidence base should include a number of Economic Reviews for Orkney.

Implications of Policy Changes for Island Communities

Comments about this part of the ICIA included several comments specific to Orkney, including a need to acknowledge that Orkney has a higher population density and very different settlement pattern to other island and rural areas and will require a bespoke approach appropriate to the LDP spatial strategy. It was also suggested that the ICIA and NPF4 should acknowledge differences in the demographic characteristics of island communities like Orkney, where there has been overall population growth in recent decades, but with increases and declines in certain elements of its demographic. It was argued that, to support sustainable island communities in the long term, it is particularly important to grow the population of young and working-age people and that planning policy, investment and public services and facilities need to target these particular demographic challenges. The availability of good quality affordable housing was seen as a major barrier to inward migration and economic development.

Other points raised in relation to Orkney included that:

• Agriculture and fishing form a major part of the economy, with both sectors particularly vulnerable to the consequences of EU Exit.
• Orkney has the poorest residential superfast broad band coverage in Scotland.

Potential issues and mitigation

Comments about this part of the ICIA included that island specific flexibility needs to be more clearly articulated within NPF4 planning policies, including policy provision for island planning authorities to take forward bespoke islands approaches to: the appropriate application of the 20-minute neighbourhood concept; planning for affordable housing, rural housing and rural business development; aquaculture; and coastal development.

With respect to infrastructure, it was noted that the ICIA identifies the need for adequate infrastructure for the number of tourists attracted to the islands. It was argued that Policy 31 (Rural places) should specifically identify provisions to enable development proposals that contribute towards the sustainability of tourism, such as targeted strategic investments in tourism infrastructure and the development of more small-scale facilities.

The need to provide adequate infrastructure, including harbour facilities and grid connections, to realise the transformative potential of renewable energy and zero carbon fuels was also highlighted, although it was suggested that the draft NPF4 focuses on the net zero potential of islands without adequate consideration to other island issues identified in the ICIA. Specifically in relation to Orkney, it was argued that, given the scale and positive impact of the Orkney Harbours development projects, and their ability to deliver on national priorities, it would be appropriate to include the Orkney Harbours as a stand-alone National Development in NPF4.

Finally, it was observed that the ICIA recognises that people living and working on islands are best placed to help decide how their communities can grow in a way that meets their needs, so it is essential that they are involved in planning their future development. It was suggested that this statement needs to be reinforced through NPF4 planning policies to enable island planning authorities to address island specific issues in LDPs, as well as through Local Place Plans.

Partial Business and Regulatory Impact Assessment (BRIA)

Question 70 – Do you have any comments on the partial business and regulatory impact assessment?

Around 45 respondents made a comment at Question 70.

General observations included that little tangible information on costs is provided.

A number of respondents noted their concern that the cumulative resource burden of NPF4 on planning authorities is not recognised in the Partial BRIA. The BRIA's suggestion that replacing most local policies with national planning policies will free up time and resources for local authorities to focus on spatial elements in their development plans was questioned. There was also doubt that the introduction of a MATHLR for each planning authority will reduce the workload of local authorities.

It was argued that:

• While there is always an assumption that the impact on local authorities will be cost neutral, experience shows that this is not the case and an assessment exercise setting out the financial and resource impacts for all local authorities is needed.
• Planning authorities will require additional resources, as well as investment in skills development to enable assessments to be undertaken in new work areas. NPF4 needs to be accompanied by a resource and skills plan, akin to what is being developed in England for its National Planning Framework, which sets out the resource impact and how this is to be addressed.
• The most significant impacts of limited local authority resources will be on those businesses that are dependent on the planning system for identifying new sites for their ongoing operations including house builders and developers, the renewable energy sector, digital network providers and the minerals and aquaculture sectors.

General observations about the potential impact of NPF4 on business included that:

• Paragraph 62 of the Partial BRIA does acknowledge that there are several new requirements that are likely to have cost implications for businesses. However, there remains a lack of clarity in what the details of these requirements will be.
• There should be more detailed consideration of the resources which will be required to ensure the policies designed to address the nature crisis can be fully implemented.

Impact on development

There was a concern that NPF4 in its current form could limit development, rather than enable it. Further comments included that:

• The Partial BRIA suggests that the introduction of national planning policies which form part of the development plan will provide greater certainty to developers and considerably reduce the number of occasions where they will need to engage with the planning system on the development of policies that affect their businesses. However, these benefits will only be fully realised if the national planning policies are sufficiently clear and robust.
• There remains a risk of tension between policy principles that gain support at national level but that may be challenging to implement due to local circumstances, empowering community planning, and local policy responses.
• NPF4 sets a higher bar than was previously the case regarding the allocation of sites for residential development. However, as currently written, NPF4 will not provide the certainty required for developers when developing their planning proposals.

Other specific resource implications

Respondents also identified potential resource requirements associated with delivering NPF4. These included that:

• There is no reference to additional costs that will be incurred by local roads authorities in meeting requirements set by draft NPF4 around aspects such as Local Place Plans, sustainable transport, active travel, and 20-minute neighbourhoods.
• Community wealth building is one of the policy changes highlighted in the Partial BRIA, and it is noted that this may result in potential costs to developers who are asked to contribute to community wealth building objectives. However, the policy is vague, and a more detailed policy could be useful for businesses as well as for planning authorities.
• Some of the changes introduced by NPF4 potentially create an additional imperative for Historic Environment Scotland to update, maintain and create new guidance notes to support decision-making. This is expected to have resourcing and cost implications beyond their current baseline for the maintenance of these guidance notes. Other key agencies may also need to update their national level guidance in the light of other changes throughout NPF4.
• Regarding Policy 28 (Historic assets), the general requirement for heritage assessments in support of applications which could significantly impact on historic assets, while beneficial in some circumstances, could result in increased costs for developers, and may mean that Historic Environment Scotland and planning authorities will spend more time and resource reviewing these outputs. There was a question as to whether these heritage assessments would bring significant value to the process when existing assessments already exist.
• Other aspects of the delivery of NPF4 will have resource implications for key agencies, such as Historic Environment Scotland. There was reference to engaging in the consenting processes for national developments and engaging more intensively with applicants and authorities on the reuse of our most significant places.

It was also suggested that Business and Regulatory Impact Assessments should be carried out for any unwanted compulsory purchases of Showmen's Yards.

Regulation

The intention of the Scottish Government to work with a range of stakeholders to develop an appropriate Monitoring Programme for NPF4 was welcomed, as were the references to the monitoring programme complementing, and potentially combining with, wider planning performance work including Planning Performance Frameworks and Royal Town Planning Institute work on monitoring outcomes. The production of a Post-Adoption Statement was also welcomed.

It was suggested, however, that it would have been helpful to stakeholders if some of the detailed content in the Regulatory Impact Assessment had been referenced in the draft NPF4, particularly in relation to the overall vision to 2045 and, for example, the references to the impact of Brexit and global trends on the Scottish economy.

Annex 1 - Organisations responding to the consultation

Active Travel-related Third Sector Organisation or Campaign Group

• CoMoUK
• Cycling Dumfries
• Cycling Scotland
• Cycling UK in Scotland
• Paths For All
• Ramblers Scotland
• Scottish Rights of Way & Access Society (ScotWays)
• Spokes, The Lothian Cycle Campaign
• Sustrans Scotland

City Region or Strategic Development Planning Authority

• Clydeplan (Glasgow and the Clyde Valley Strategic Development Planning Authority)
• Coastal Communities Network, Scotland
• Edinburgh & South East Scotland City Region Deal

Community Council or Residents' Association

• Ardross Community Council
• Assynt Community Council
• Bishopbriggs Community Council
• Broom, Kirkhill and Mearnskirk Community Council
• Cambusbarron Community Council
• Cramond & Barnton Community Council
• Culter Community Council
• Cupar Development Trust
• Dalry Community Council
• Durness Community Council
• Fossoway and District Community Council
• Gartcosh Tenant and Residents Association
• Grangemouth incl. Skinflats Community Council
• Grassmarket Residents' Association
• Hillhead Community Council
• Isle of Mull Community Council
• Jackton & Thorntonhall Community Council
• Joint Forum of Community Councils in West Lothian
• Kemback Pitscottie and Blebo Community Council
• Kilmacolm Residents' Association
• Kilmun Community Council, Argyll
• Kingseat Community Council
• Kintore and District Community Council
• Kirkmahoe Community Council
• Leith Harbour and Newhaven Community Council
• Liberton & District Community Council
• Linlithgow and Linlithgow Bridge Community Council
• Maybole Community Council
• Mid Deeside Community Council
• Midlothian Federation of Community Councils
• Monkton Community Council
• Mount Vernon Community Council
• New Town & Broughton Community Council
• Newtonhill, Muchalls & Cammachmore Community Council
• Northern Corridor Community Forum
• Stepps and District Community Council
• Symington Community Council
• The Royal Burgh of Forfar Community Council
• Tiree Community Council
• West Kilbride Community Council
• Westhill and Elrick Community Council

Culture or Heritage Company, Association, Trust or Representative

• American Cultural Resources Association
• AOC Archaeology Group
• Archaeology Scotland
• Architectural Heritage Society of Scotland
• Association of Local Government Archaeological Officers
• Battle of Prestonpans [1745] Heritage Trust
• Biggar and District Civic Society
• Chartered Institute for Archaeologists
• Creative Lives
• Culture Counts
• Dundee Civic Trust
• Historic Houses
• Museums Galleries Scotland
• Music Venue Trust
• Scottish Strategic Archaeology Committee
• Shetland Amenity Trust
• Society of Antiquaries of Scotland
• The Cockburn Association
• The Federation of Archaeological Managers and Employers
• The National Trust for Scotland
• The Scottish Civic Trust
• Theatres Trust

Development, Property or Land Management Company or Representative Body

• A & J Stephen (Builders)
• Allan Water Homes Limited
• Avant Homes (Scotland)
• Bancon Homes
• Banks Group Ltd
• Barratt & David Wilson Homes North Scotland
• Barratt David Wilson Developments (East Scotland)
• Barratt David Wilson Developments (Scotland Region)
• Barratt Homes West Scotland
• Bellway Homes
• Bellway Homes East Scotland
• Burness Paull LLP
• Cala Homes (East) Limited
• CALA Homes (West) Limited
• CALA Homes North Ltd
• Campion Homes Ltd
• Cape Marco Ltd (Company No.12373899)
• CHAP Group (Aberdeen) Ltd
• Crosswind Developments Ltd
• Cruden Homes (West) Ltd
• D J Laing Homes Limited
• Dandara East Scotland Limited
• Dawn Homes
• Dundas Estates and Development Company Limited
• E&A Partnerships Ltd
• Ediston Homes Ltd
• Elan Homes (Scotland) Ltd
• Gladman Developments Limited
• Global Mutual
• Guild Homes (Tayside) Limited
• Hadden Homes
• Hallam Land Management
• Hargreaves Land
• Headon Developments Limited
• Home Group Limited
• Homes for Scotland
• Kirkwood Homes Limited
• Lovell Partnerships
• Mactaggart & Mickel
• Malcolm Allan Housebuilders Ltd
• McTaggart Construction Ltd
• Midsteeple Quarter
• Miller Homes Ltd
• Moda Living
• Montagu Evans LLP per The University of Edinburgh
• Morris Leslie Group
• NPL Group
• Ogilvie Homes
• Orchard Brae Ltd.
• Pat Munro Alness Limited
• Paul Traynor Panacea Homes
• Peel L&P
• Peel NRE Limited
• Persimmon Homes
• Ravenscraig Limited
• RDK Construction Ltd
• Robertson Living Limited
• Robertson Residential Group
• Ryden LLP
• Savills
• Scotia Homes Ltd
• Scottish Land & Estates
• Scottish Property Federation
• SGN Place Limited and SGN Commercial Services Limited
• Shawfair LLP
• Sovereign Centros
• Springfield Partnerships
• Springfield Properties North
• Springfield Properties PLC
• Stewart Milne Homes
• Stirling Developments Limited
• Taylor Wimpey (East Scotland)
• Taylor Wimpey (West Scotland)
• Taylor Wimpey and Hallam Land Management Ltd
• Tulloch Homes Limited
• Turnberry Homes Ltd
• Unite Group Plc
• Walker Group
• Watkin Jones Group PLC
• West Town Edinburgh Ltd
• Whiteburn Projects Ltd
• Winchburgh Developments Limited

Energy-related Supplier, Developer, Association or Body

• 3R Energy Ltd
• Abei Energy Group Ltd
• Ampyr Energy UK Developments
• Association for Decentralised Energy
• BayWare. UK Ltd
• Belltown Power UK
• Community Energy Scotland
• Community Power Outer Hebrides
• Community Windpower Ltd
• Coriolis Energy
• Drax Group
• EDF
• EDP Renewables
• Electricity Supply Board (ESB)
• Energiekontor UK Ltd
• Energy Transition Zone Ltd
• Ennoviga Solar Ltd
• ERG UK
• European Marine Energy Centre (EMEC) Ltd
• Force 9 Energy
• Fred. Olsen Renewables
• GreenPower International Ltd
• GRIDSERVE Sustainable Energy Ltd
• Hitachi Energy
• Inch Cape Offshore Limited
• INEOS FPS Ltd
• Infinergy & Boralex
• Jura Wind Ltd
• Low Carbon Wind Development Co Ltd
• MCS Charitable Foundation
• MERED Limited (renewable energy developer)
• Muirhall Energy
• National Grid Gas Transmission
• Ocean Winds UK
• Orsted
• Red Rock Power Limited
• RenewableUK
• RES
• RWE
• Scottish Power Energy Networks Holdings Limited
• Scottish Renewables
• ScottishPower Renewables
• SGN
• Shell UK Limited
• Solar Energy Scotland
• Solar2 Limited
• SSE Renewables
• SSE Thermal
• SSEN Transmission
• Statera Energy
• Statkraft UK Limited
• Teindland Wind Farm Ltd
• The Farm Energy Company
• The Orkney Renewable Energy Forum
• Uniper
• Ventient Energy
• Wind2 Limited
• WKN GmbH

Environment or Natural Heritage-related Third Sector Organisation or Campaign Group

• Aberdeen Climate Action CIC
• Badenoch & Strathspey Conservation Group
• Biofuelwatch
• Buglife - The Invertebrate Conservation Trust
• Cairngorms Campaign
• CATES
• Community of Arran Seabed Trust (COAST)
• Community Woodlands Association
• Deeside Climate Action Network (CAN)
• Dovesdale Action Group
• F.R.I.E.N.D.S. (For Real Issues Environment Nature Disabled Stevenston)
• Fields in Trust
• Friends of St Fittick's Park
• Friends of the Earth Scotland
• Friends of the Earth Tayside
• Galloway and Southern Ayrshire UNESCO Biosphere
• Galloway National Park Association
• Green Action Trust
• Greenspace Scotland
• Iona Community Environmental Network
• John Muir Trust
• Keep Potterton Green
• Missing Salmon Alliance
• Mountaineering Scotland
• North East Mountain Trust
• Plantlife International
• Reforesting Scotland Thousand Huts
• RSPB Scotland
• Scottish Badgers
• Scottish Biodiversity Information Forum (SBIF)
• Scottish Environment LINK
• Scottish Geology Trust
• Scottish Rewilding Alliance
• Scottish Wild Land Group
• Scottish Wildlife Trust Aberdeen & Aberdeenshire Local Group
• Scottish Wildlife Trust, Ayrshire Group
• ScrapAntics CIC
• South Seeds
• SWT Lothians Group (Planning Team)
• The Association for the Protection of Rural Scotland
• The Scottish Wildlife Trust
• Transition Edinburgh [who organised a community consultation from which this response is drawn]
• Woodhall, Faskine and Palacecraig Conservation Group
• Woodland Crofts Partnership
• Woodland Trust Scotland
• Zero Waste Scotland

Housing Association

• Castle Rock Edinvar (trading as Places for People Scotland)
• DGHP part of the Wheatley Group
• Home in Scotland
• Lochalsh & Skye Housing Association
• Ore Valley Housing Association
• Scottish Borders Housing Association
• Tshousing

Local Authority

• Aberdeen City Council
• Aberdeenshire Council
• Angus Council
• Argyll and Bute Council
• City of Edinburgh Council
• Clackmannanshire Council
• Comhairle nan Eilean Siar
• COSLA
• Dumfries and Galloway Council
• Dundee City Council
• East Ayrshire Council
• East Dunbartonshire Council
• East Lothian Council
• East Renfrewshire Council
• Falkirk Council
• Fife Council
• Glasgow City Council
• Improvement Service
• Inverclyde Council
• Midlothian Council
• Moray Council
• North Ayrshire Council
• North Lanarkshire Council
• Orkney Islands Council
• Perth and Kinross Council
• Renfrewshire Council
• Scottish Borders Council
• Shetland Islands Council
• SOLACE Scotland
• South Ayrshire Council
• South Lanarkshire Council
• Stirling Council
• Tayside RSS local authorities
• The Highland Council
• The Society of Local Authority Lawyers and Administrators in Scotland
• West Dunbartonshire Council
• West Lothian Council

NHS

• NHS Fife
• NHS Forth Valley
• NHS Grampian
• NHS Greater Glasgow & Clyde
• NHS Tayside
• Public Health Department NHS Fife
• Public Health Scotland
• Scottish Directors of Public Health Group (SDsPH)
• The Scottish Ambulance Service

Other

• The Religious Society of Friends (Quakers in Scotland)
• West Fife and Coastal Villages SNP branch

Other Infrastructure-related Company or Representative Body

• Cellnex UK
• EQUANS UK and Ireland
• Mobile UK
• Openreach
• RPM (REG Power Management Limited)
• Scottish Environmental Services Association
• Scottish Water.
• Storegga
• The Metropolitan Glasgow Strategic Drainage Partnership

Other Private Sector

• Airbnb
• Aldi Stores Ltd
• Ballogie Estate Enterprises
• Bourne Leisure Limited
• Cooke Aquaculture Scotland Ltd
• Dobbies Garden Centres Ltd
• EPC-UK
• Flood Re
• Lidl Great Britain Ltd
• Loch Duart Ltd
• Marks and Spencer plc
• McDonald's Restaurants Ltd
• Mowi Scotland
• North West Highlands Geopark Ltd
• Scottish Salmon Company
• Scottish Sea Farms
• Scottish Stone Group
• Stora Enso
• Tesco Stores Limited
• The Sub Club, King Tuts Wah Wah Hut, SWG3, Barrowland Ballroom, 02 ABC & 02 Academy.
• TWUK Ltd
• Welbeck Estate

Other Representative Body, Faculty, Network

• Aberdeenshire Local Outdoor Access Forum
• Association of British Insurers
• Association of Scotland's Self-Caterers
• Botanical Society of Britain and Ireland Committee for Scotland
• British Holiday & Home Park Association (Scotland)
• Chartered Institute of Ecology and Environmental Management (CIEEM)
• CIHT
• CIWM Scotland
• Committee of the Faculty of Public Health in Scotland
• Community Transport Association
• Confederation of Passenger Transport Scotland
• Confor
• Conservation Officers Group
• DTA Scotland
• Edinburgh Chamber of Commerce
• Federation of Small Businesses
• Glasgow Chamber of Commerce
• Health and Social Care Alliance Scotland
• Institute of Acoustics
• Law Society of Scotland
• Mineral Products Association (Scotland) Ltd
• NFU Scotland
• Royal Environmental Health Institute of Scotland
• Royal Yachting Association Scotland
• Salmon Scotland
• Scottish Agritourism
• Scottish Chambers of Commerce
• Scottish Community Alliance
• Scottish Flood Forum
• Scottish Grocers' Federation
• Scottish Out of School Care Network
• Scottish Retail Consortium
• Scottish Sports Association
• Scottish Tree Officers Group
• Scottish Women's Convention
• Stirling Area Access Panel SCIO
• SURF - Scotland's Regeneration Forum
• The Association of Environmental Clerks of Works
• The Mobility and Access Committee for Scotland
• Transform Scotland

Planning, Architecture or Housing Representative Body or Campaign

• Built Environment Forum Scotland
• CIH Scotland
• Communities Housing Trust
• Heads of Planning Scotland (HOPS)
• Housing and Place Delivery Forum
• Institution of Civil Engineers Scotland
• Landscape Institute
• Paradigm Asset Management Group Ltd
• PAS (Planning Aid Scotland)
• Planning Democracy
• Royal Institution of Chartered Surveyors (RICS)
• RTPI Scotland
• Rural Housing Scotland
• Scotland's Landscape Alliance
• Scottish Crofting Federation
• Scottish Federation of Housing Associations
• Spatial Planning, Health and Wellbeing Collaborative
• The Chartered Institute of Building
• The Industrial Communities Alliance Scotland
• The Royal Incorporation of Architects in Scotland (RIAS)
• The Scottish Housing with Care Task Force

Planning, Development, Architectural or Environmental Consultancy

• Aquatera Ltd
• ASH Design + Assessment Limited.
• Assemble Collective Self Build
• Aurora Planning Limited
• Barton Willmore
• BiGGAR Economics
• David Bell Planning Limited
• Derek Scott Planning
• Ferguson Planning
• Halliday Fraser Munro
• Holder Planning
• Marcus Trinick QC
• Meicplan.associates
• ORS Plc
• Pegasus Consultancy Ltd
• Rick Finc Associates
• Ristol Consulting Limited
• Scottish Futures Trust
• Shepherd and Wedderburn LLP
• Wright Planning & Development Ltd

Public Body, Commission or Taskforce

• Architecture and Design Scotland
• Bòrd na Gàidhlig
• Cairngorms National Park Authority
• Climate Change Committee
• Creative Scotland
• Crown Estate Scotland
• Equality and Human Rights Commission
• Food Standards Scotland
• Highlands and Islands Enterprise
• Historic Environment Scotland
• Key Agencies Group
• Loch Lomond and Trossachs National Park Authority
• Ministry of Defence
• NatureScot
• Nuclear Decommissioning Authority
• Scottish Enterprise
• Scottish Environment Protection Agency
• Scottish Land Commission
• South of Scotland Enterprise (SOSE)
• Sportscotland
• The Coal Authority
• VisitScotland

Regeneration or Planning Partnership or Trust

• ASPIRE Orkney Ltd
• Astley Ainslie Community Trust
• Ayrshire Growth Deal
• Caithness and North Sutherland Regeneration Partnership
• Central Scotland Green Network Partnership Group
• Climate Ready Clyde
• Clyde Marine Planning Partnership
• Coalfields Regeneration Trust
• Crichton Carbon Centre, Southern Uplands Partnership and the Heather Trust (joint submission)
• Inner Forth Futures
• NorthWest2045 www.northwest2045.scot
• Opportunity Cromarty Firth (consortium)

Research, Academic Group or Think Tank

• British Geological Survey
• Dynamic Coast
• Forest Policy Group
• Glasgow Centre for Population Health
• Hydro Nation Chair Research and Innovation Programme
• Royal Botanic Garden Edinburgh
• Scottish Carbon Capture & Storage (SCCS)
• SPECTRUM
• The Royal Society of Edinburgh
• UK Green Building Council (Scotland)
• University of Groningen
• University of Strathclyde (Sustainable Strathclyde)

School or Nursery

• Carnock Primary School
• KLAS Care C.i.C
• Larbert Village Primary School
• Musselburgh Burgh Primary School
• Ravenswood Primary School
• South Morningside Primary School
• Tomintoul Nursery

Third Sector, Community or Campaign Organisation

• A Place in Childhood
• Age Scotland
• Asthma + Lung UK Scotland
• Campaign for Borders Rail
• Child Poverty Action Group in Scotland
• Children in Scotland
• Community Central Hall
• Community Land Scotland
• Corra Foundation
• Edinburgh Poverty Commission
• Foundation Scotland
• Galloway Mines Action Group
• Highland Good Food Partnership
• Includem
• Inclusion Scotland
• Inverkeithing Trust
• MND Scotland
• Nourish Scotland
• Obesity Action Scotland
• OneKind
• Parenting across Scotland
• PLACE Edinburgh
• Play Scotland
• Revitalise Moniaive
• RoSPA
• Save Shetland
• Scotland Against Spin
• Scottish Community Development Centre
• Scottish Mediation
• Scottish Obesity Alliance
• Scottish Older People's Assembly
• Scottish Rural Action
• Shelter Scotland
• South Lanarkshire Good Food Forum
• South of Scotland Community Housing (SOSCH)
• The British Horse Society
• The Community Growing Forum
• Third Sector Dumfries and Galloway
• Voluntary Health Scotland

Transport Partnership

• Nestrans
• South East of Scotland Regional Transport Partnership (SEStran)
• Strathclyde Partnership for Transport
• Tayside and Central Regional Transport Partnership (Tactran)
• The Joined Regional Transport Partnership
• ZetTrans

Transport-related Body, Association or Provider

• Aberdeen Harbour Board
• AGS Airports Limited
• Airlines UK
• Airport Operators Association
• British Aviation Group
• Clydeport Operations Ltd
• Forth Ports Limited
• Fraserburgh Harbour
• Lichfields on behalf of Edinburgh Airport Limited
• Network Rail Infrastructure Ltd
• Orkney Islands Council: Orkney Harbour Authority
• Society of Chief Officers of Transportation in Scotland (SCOTS)
• UK Major Ports Group