National Planning Framework 4 - draft: consultation analysis

Part 2 - National Developments

National developments are significant developments of national importance that will help to deliver our spatial strategy. Eighteen national developments are proposed to support the delivery of our spatial strategy. This designation means that the principle of the development does not need to be agreed in later consenting processes, providing more certainty for communities, business and investors.

Question 19 – Do you think that any of the classes of development described in the Statements of Need should be changed or additional classes added in order to deliver the national development described?

Question 20 – Is the level of information in the Statements of Need enough for communities, applicants and planning authorities to clearly decide when a proposal should be handled as a national development?

Around 280 respondents commented at one or both of Questions 19 and 20.

General comments on national developments

A number of issues were raised in relation to the implications of national development status, including suggestions that:

• It would be helpful to explain how national developments might interact with Regional Spatial Strategies and with the action areas identified in Part 1 of the draft NPF.
• Links between different national developments, and between national developments and related policies, should be highlighted.
• Guidance will be needed with respect to how to balance the competing priorities of different national developments.

It was also suggested that national developments should carry a presumption in favour of planning consent. However, in relation to the Hierarchy of Development Regulations, it was noted that:

• There may be proposals that would contribute to delivering a national development but that individually do not constitute a national or major development.
• Reference to classes of development may cause confusion as some of the proposals listed would not be considered to be 'development' from a planning perspective.

It was also suggested that more clarity is needed around the process to be followed when submissions for planning permission are made, and an explanation (or separate guidance) on what national development status means in terms of the development management process was requested. Concerns were raised with respect to the complexity of the application process, and it was argued that the provisions are more onerous than would be applicable to 'ordinary' development.

Meeting the needs of stakeholders

It was suggested that there should be greater reference to the importance of community participation and involvement in relation to national developments, along with further information on how this can be supported.

Question 20 asked whether the level of information provided in the Statements of Need is enough for communities, applicants and planning authorities to clearly decide when a proposal should be handled as a national development. Some respondents commented on the Statements overall, with views both that the level of information provided is sufficient and that it is not.

Points made by respondents who broadly agreed that the Statements of Need are appropriate included that using the major development threshold is helpful, as authorities and stakeholders are familiar with this concept. It was also noted that when developments are submitted for formal consideration they will be site/area specific, making it easier for local communities and interested stakeholders to understand the nature of the proposal.

Concerns raised by those who did not think the level of information is sufficient included that listing classes of development under larger projects may create ambiguity regarding whether a specific proposal is or is not included. It was also argued that the proposed approach is likely to increase workload for planning authorities as proposals will need to be screened to establish the status of the development under the NPF4 classes of development and the Hierarchy of Development Regulations. Also in relation to assessment of proposals, the use of the terms 'such as' and 'including' was seen as unhelpful.

Some of those who did not think the level of information provided is sufficient called for more information or for greater clarity, with further suggestions including that:

• Additional information could be provided through up-to-date websites for each national development, facilitated through a central portal.
• NPF4 should use the terminology in the Hierarchy of Development Regulations to make it easier to decide when a proposal should be handled as a national development.
• Different groups of stakeholders may require information to be presented in a way that best suits their needs. In particular, it was suggested that the Statements of Need may not be accessible to communities or non-technical audiences.

In terms of specific information it was noted that, although life cycle greenhouse gas emissions are considered, other consequences of the proposed national developments have not been set out. There was reference to how each project may influence population movements, the supply chain and where people work and live.

Selection of national developments

It was suggested it would be helpful to set out the rationale for selecting those chosen and why some are conceptual, and others are existing proposals. Respondents were also looking for explanations regarding why:

• The parameters of some national developments carried forward from NPF3 have been changed?
• Some NPF3 national developments have not been carried forward into NPF4?

The absence of a mechanism for local authorities to resubmit candidate national developments was highlighted.

Although respondents were not asked directly, a number did comment on whether they supported some or all of the national developments proposed. A small number of respondents simply offered overall support for all of the national developments, while others referenced their particular support for one or more of them.

There were also a number of respondents who appeared to support the overall theme of a national development, for example that High Speed Rail or Strategic Renewable Electricity Generation and Transmission Infrastructure should be a national development, but then went on to raise a number of issues or concerns about the national development as currently described. Some of the issues raised related to the location of the national development and were sometimes focused on it being expanded to other parts or all of Scotland. Others were focused on one or more of the classes of development as currently described.

These issues, along with concerns raised by the small number of respondents who noted that they did not agree with one or more of the national developments set out, are covered further below.

Comments on the proposed national developments

The analysis below presents a brief summary of comments made in respect of each of the 18 national developments. It focuses on the questions posed in relation to the classes of development and whether the Statements of Need is enough for communities, applicants and planning authorities to clearly decide when a proposal should be handled as a national development.

National developments to deliver sustainable, liveable places

ND1. Central Scotland Green Network (CSGN)

Around 45 respondents commented on the CSGN, some simply noting support for its continued designation as a national development. It was suggested that the CSGN is an effective way to demonstrate the importance of connecting national developments with policies, and links to a number of individual policies were suggested, including Policy 3 (Nature crisis) and policies under the Distinctive places theme. Making clear links to ND4 (Urban Sustainable, Blue and Green Drainage Solutions) and to the Central urban action area's strategic action 20 (Re-imagine the urban fringe) were also suggested. There was also a call for adaptation to climate change through sustainable blue and green infrastructure to be highlighted as one of the important functions of the Network.

It was also reported that status as a national development is not of itself enough to ensure that development plans will fully incorporate the national policy. Greater detail and more guidance on how LDPs and spatial strategies should be used to articulate and deliver national developments was suggested. It was noted that many planning authorities within the CSGN have produced supplementary planning guidance relating to the Network, and there was concern that this could be lost or watered down. Some respondents proposed specific actions with respect to taking the priorities of the CSGN forward.

In terms of the area that is to be covered, it was suggested that there is no reason to exclude the north Fife coast. There were also calls for the CSGN to be expanded to be a Scotland-wide national development, or for the creation of a Scottish Nature Network.

With respect to public access, it was observed that clear requirements for provision and protection of public access to land and routes included in SPP are absent from NPF4. It was argued that NPF4 should make clear reference to the need for planning decisions and developments to protect existing local paths (including key informal routes), and to facilitate non-motorised connectivity for the purposes of health, social inclusion and modal shift. There was also a request to make clear that shorter routes as part of local path networks, as well as longer distance routes, are required and to recognise the different benefits that both types of routes bring to people and their local communities.

With respect to nature-based solutions and connectivity of habitats, comments included that:

• Highlighting woodland and peatland as a priority may undermine the value of other habitats; the statement 'nature-based solutions for climate change adaptation and mitigation may include woodland expansion and peatland restoration as a priority' should be replaced by a steer to consider habitat priorities as defined by local nature networks.
• The second sentence should be amended to read that 'the connectivity of biodiversity rich areas may be enhanced through nature networks for all habitat types, including corridors and stepping stones to provide enhanced natural capital and improved ecosystem services'.

Designation and classes of development

Comments on designation and classes of development included that:

• Class (a) should specify change of use of land and engineering works or other operations to deliver green infrastructure, habitat creation or enhancement that results in emissions sequestration, adaptation to climate change or biodiversity enhancement. While these may not be 'new or extensions' to green infrastructure, they may enhance existing areas.
• Not all greenspaces benefit from multi-functional uses and this could compromise existing biodiversity value on site.
• Rather than 'creation of blue space' there should be integration of blue within all green thinking.
• Class (d) could be extended to include providing space for markets for local farming produce.
• Class (e) should be amended to read 'Routes for active travel and/or recreation that incorporate new or enhanced green infrastructure'.

It was also argued that local food production is not just a concern for central Scotland and that land for food production should be a national development in its own right, and not just a class within the CSGN.

Deciding when a proposal should be handled as a national development

There was a view that NPF4 should more clearly define what the CSGN is, along with how its delivery will be aided through planning, and it was suggested that specific reference to individual delivery projects within the CSGN could be included in the statement of need.

With respect to the location of the CSGN, it was noted that this is a Scottish Government partnership initiative, and that the boundaries are not set by the Green Action Trust. Issues highlighted with respect to the extent of the Network as illustrated included that:

• The Perth and Kinross Council area is not within the CSGN as is suggested by the figures on page 31 and 45.
• If the Loch Lomond and Trossachs National Park is not covered, the map should be amended accordingly.

Clarity with respect to boundaries was seen as important since NPF4 will be part of the development plan.

ND2. National Walking, Cycling and Wheeling Network (NWCWN)

Around 45 respondents commented on ND2. Inclusion of the NWCWN as a national development was welcomed, although it was also argued that the policy has limited applicability for reducing routine car journeys in rural Scotland. The importance of investment to deliver the network was highlighted, including a view that significant infrastructure investment, over and above existing budgets, will be required. Clarity was also requested with respect to which active travel routes are currently considered part of a national network, how routes would demonstrate that they form part of the national network, and how the network will be supported at a regional and local level.

It was also argued that there should be a greater focus on routine, local pedestrian and cycling environments, rather than too great an emphasis on a national network. Local pavements were observed to be the most important active travel infrastructure for most disabled people.

In terms of content of the statement of need, it was suggested that a clearer statement of the need for wider active travel connections to existing services is needed, and that this may require improvements to existing infrastructure beyond the immediate development site. It was argued that delivery of this type of improvement may be hindered by the developer contributions policy, so a connection to the national development is vital.

Other suggestions included that:

• The relationship with STPR2 Active Travel Infrastructure recommendations should be clarified.
• Terminology should be consistent with STPR2, which uses the term 'mobility hubs'.
• Confusion with the Sustrans 'National Cycle Network' should be avoided.
• The value for recreation, and to the tourism sector, should be mentioned.
• Specific long distance walking routes and local active travel networks could be referenced.

With regard to the creation of the NWCWN, there were calls to maximise opportunities to embed climate resilience and to ensure opportunities to manage surface water for the wider catchment area are not missed, blocked or made significantly more difficult or expensive to deliver in the future. Other recommendations included that:

• The need for road space reallocation should be recognised.
• Routes should run through, and be linked to, blue-green infrastructure and designed to conserve biodiversity and maintain the surrounding landscape. Guidance on protecting existing/surrounding landscape when making planning decisions on new road infrastructure should be provided.
• Key services and amenities should be signposted across the network to ensure safe routes for public access, while discouraging people from diverging away from pathways where they may cause unintentional damage to the landscape.

In terms of access to the network itself, points raised included that:

• The need for segregated cycle lanes should be addressed.
• Upgrading must include removing barriers to disabled people using adapted bikes, tricycles and mobility equipment.
• Barriers should not be created for other forms of multi-use access available under the Land Reform (Scotland) Act 2003, such as horse-riding.

Designation and classes of development

Comments with respect to designation and classes of development included that The Town and Country Planning (Hierarchy of Developments)(Scotland) Regulations 2009 do not include active travel infrastructure within the transport infrastructure category of major development. It was suggested that many individual elements that create a national network would not be considered as major developments as they will be shorter than the 8 km distance cited in the 2009 Regulations. The connected point was that there should be support for smaller sections of routes to contribute to, and be part of, the national development.

It was also argued that the designation and classes of development should be strengthened to reference 'a nationally-connected network that facilitates short, medium and longer distance journeys and linkages between settlements, visitor destinations and to multi-modal hubs.' However, there were also concerns that a requirement for a route to create 'linkages to multi-modal hubs' could exclude most of the network that is currently proposed.

Other suggestions included that:

• There may be situations where routes are not suitable for all users in the short term, for example steep routes that may only be suitable for cycling or walking until they can be upgraded; the text should be amended to '...suitable for a range of users for walking and/or cycling and/or wheeling…'.
• Additional classes should be added to include, where relevant, land for sustainable travel rather than just routes for active travel.
• The designation and classes of development should be expanded to include and reference routes for active travel and recreation.

In addition to the 'Lifecycle greenhouse gas emissions assessment' it was proposed that there should be a similar assessment of the impact on physical activity and health.

Deciding when a proposal should be handled as a national development

It was suggested that the interpretation of this national development could be extremely broad, and that more clarity is required on what proposals or routes would be part of a national network. Clarity was also sought as to whether 'new/and or upgraded routes suitable for a range of users for walking, cycling and wheeling' would align with Part 6 of the Hierarchy of Development Regulations, and therefore be a major development.

ND3. Urban Mass/Rapid Transit Networks

Around 30 respondents commented on ND3. Points raised included that this national development is supported, but also that it should include Dundee or should be extended to be a Scotland-wide development. The need for stronger public transport connectivity in rural areas was also highlighted and it was suggested that visitor/leisure journeys – such as into the National Parks – should be referenced.

Other issues raised included that a joined-up strategy should take account of new active travel routes as part of the NWCWN recommendations in STPR2, and other strategies and route maps. It was suggested that the alignment with STPR2 recommendations 11 (Clyde Metro), 12 (Edinburgh and South East Scotland Mass Transit) and 13 (Aberdeen Rapid Transit) should also be made clear.

Other issues highlighted included that:

• Placemaking, place quality, health and wellbeing and sustainable investment for inclusive economic growth should all be referenced.
• There should be a greater emphasis on bus prioritisation.
• The need to ensure that networks are climate resilient, particularly to the impact of extreme weather events, should be emphasised.
• Opportunities to manage surface water for the wider catchment (with an adaptation and resilience focus) must not be missed, blocked or made significantly more difficult or expensive to deliver in the future. It was reported that creating networks to move people and vehicles can also create space and connections for blue-green infrastructure, and positively support the Scottish Government Water Resilient Places policy recommendations.
• Mass transit expansion must be designed holistically with associated active travel provision to ensure safety, as well as boosting active travel. Specific reference should be made to ensuring segregated cycle provision alongside tramlines, and the provision of safe crossing points of the tramlines for both cyclists and pedestrians.
• Wildlife road mitigation, such as the use of more mammal tunnels, wildlife road signage and appropriate fencing to protect existing habitats, should be considered.

Designation and classes of development

Comments on designation and classes of development included that support for new road infrastructure to deliver low carbon mass/rapid transport projects should be applied strictly. It was suggested that this would ensure ND3 is not interpreted as applying to new road infrastructure beyond that which is already committed.

Several additional points were made specifically with reference to the Clyde Metro, including that enabling/ancillary development, such as high density mixed used development linked to Metro Interchanges, stations or key stops, should form part of the designation for this national development.

ND4. Urban Sustainable, Blue and Green Drainage Solutions

Around 25 respondents commented on ND4. While this national development was welcomed, it was also argued that the principles apply beyond Glasgow and Edinburgh and that Sustainable, Blue and Green Drainage Solutions should be extended to other cities and urban areas, or should be a Scotland-wide national development.

It was also suggested that the word 'drainage' should be removed from the title to ensure that these developments are not seen as solely having a drainage function. It was thought that the emphasis should be on the planning and delivery of multi-functional blue and green solutions, with a clear link to the CSGN (ND1) proposed.

It was also suggested that the statement of need should clarify the language used with respect to Sustainable Urban Drainage Systems (SuDS). It was noted that while designed to mimic natural approaches to the management and treatment of surface water, SuDS are engineered solutions. Since the statement of need states an ambition to minimise the use of built engineered structures, it was argued that it should be made clear that SuDS are a key part of blue green infrastructure.

Other suggestions included that the statement of need should:

• Highlight the success of the Glasgow and Edinburgh Strategic Drainage Partnerships, due to the collaborative nature of these partnerships and their approaches to innovation, decision-making and shared action.
• Reference catchment-scale approaches and improving water quality. It was reported that better management of surface water drainage has the potential to contribute to reducing downstream impacts on water quality and ecosystems, including estuarine and coastal waters, and could form a useful part of a broader source-to-sea policy.

Opportunities to link a nature-based approach to this national development, and to a wider nature network, were also highlighted.

Designation and classes of development

Comments on designation and classes of development included that it is unclear whether this is meant to apply to any form of major development that requires a drainage or water management solution. It was also suggested that the classes of development should mirror those for ND1, to enable opportunities for creating national level developments that support both.

Deciding when a proposal should be handled as a national development

It was suggested that clearer wording is required on policy requirements for consideration as a national development, and that it is currently unclear whether national development status would apply to any form of major development that requires a drainage or water management solution.

With respect to the scale of development that might be required to qualify as national development, it was argued that both the delivery of small retrofit opportunities, and large-scale infrastructure, will be required. It was suggested that it is not clear how this mix of large- and small-scale interventions would be supported as a national development.

ND5. Circular Economy Materials Management Facilities

Around 20 respondents commented on ND5. Several respondents expressed support for this national development, including that materials facilities could play a significant role in delivering greater sustainability in the construction and demolition industries. It was suggested that the statement of need should highlight the forthcoming waste targets route map, setting out new policies and interventions to improve recycling rates, and making the case for a national need for additional waste management infrastructure.

A possible conflict between expressed support for national waste management developments and the site-specific constraints that might apply, was also highlighted. There was a call for more direction and detail in relation to how facilities would manage any emissions and mitigate localised impacts, including on neighbouring communities and the wider environment.

It was argued that continued use, followed by repair, are the top value purposes in the circular economy and that, in the context of climate change and adaptation, maintenance and repair should be a national priority. Policies on circular economy and waste management were argued to concentrate too much on operational waste and carbon management and not enough on embedded or embodied carbon and energy.

There was a view that the designation may confer limited benefits to the waste management industry, and that the scope of development covered is somewhat limited. Rather than limiting the scope of national development to the four classes of waste development specified, it was suggested that NPF4 should enable delivery of a network of integrated waste management facilities. It was argued that the national development should reflect waste management as an essential service that can deliver carbon reductions through sustainable management of waste.

Other comments include that:

• A statement of support for smaller scale versions of the types of developments identified should be included since, if not explicitly included in the national development designation, such small-scale facilities might have to provide more justification for need than larger scale 'major' facilities.
• Although there is potential to support increased circularity in the construction sector, maximising the benefits will require facilities to be located close to the supply and demand of secondary materials to avoid unnecessary transportation of large volumes of material.
• There should be an emphasis on opportunities for material storage and reuse in building repair, maintenance, and construction.

Designation and classes of development

Comments on designation and classes of development included that:

• Individual classes should be clarified.
• Terminology should be amended to follow that used in the waste hierarchy, and to be consistent with the Waste Framework Directive. It was reported that 'repurposing' is not terminology used in the waste hierarchy or in waste regulation.

Deciding when a proposal should be handled as a national development

There was a view that the statement of need does not provide an adequate level of information for clear decisions to be made; to avoid unintended outcomes, there was a call for clarity with respect to how ND5 will be delivered. There were also calls for definitions of the classes of development listed and greater clarity with respect to the type of proposals that would be accepted, for example with respect to the scope, size and parameters of facilities. In particular, it was suggested that it may be helpful to set out what is not in the scope of this national development in terms of end-of-life waste infrastructure. Clarification that residual waste treatment facilities are excluded was also suggested.

ND6. Digital Fibre Network

Around 25 respondents commented on ND6. The majority of comments were brief and largely limited to expressions of support. The importance of connectivity was highlighted in relation to remote access to services, Mobility as a Service, and reducing unnecessary travel. However, it was also noted that 'high speed broadband' is rapidly being overtaken by 'fibre to premises', and it was suggested this should be made a national strategic objective.

Respondents also highlighted the importance of:

• Preventing harm to existing wildlife/sealife habitats and biodiversity.
• Prioritising, addressing and mitigating impacts on the most valued and sensitive sites.
• Considering safeguards for health in relation to routes and masts.

It was also noted that some proposals do not require planning permission.

Designation and classes of development

Comments on designation and classes of development were limited to a query in relation to is meant by a green data centre.

National developments to deliver sustainable, productive places

ND7. Islands Hub for Net Zero

Around 25 respondents commented on ND7. General points included that it is not clear why net zero projects are national developments only if they are proposed in the Western Isles, Shetland and Orkney Island groups, and that consideration should be given to supporting these more widely. In particular it was argued that the national development could be extended to include Highland in light of, for example, Opportunity Cromarty Firth.

It was also suggested that the title of this national development is confusing and that it could be mistaken for the Islands Centre for Net Zero, a project initiative supported through the Islands Growth Deal.

With respect to the description section, it was suggested that amendments are necessary to reference:

• Scapa Deep Water Quay development.
• Extension of Hatston Pier, Kirkwall.
• The link with offshore wind and ScotWind.

It was also noted that the Orkney Research and Innovation Campus, mentioned as 'proposed' in the text, is already under development.

Other comments included that:

• It is important that the role the islands have in demonstrating the role of marine energy, as part of the wider energy system, is recognised in NPF4 and that appropriate use classes are included to facilitate this.
• Support for ports as near-Arctic marine transport and logistics hubs is welcomed but requires further definition.
• The handling of ultra-large container ships at Scapa Flow seems to be an unlikely inclusion for a number of reasons, including that such ships will not be early to decarbonise. It was also suggested, however, that the need and opportunity are greater than since the initial NPF4 consultation.

Some respondents focused on concerns about the protection of World Heritage Sites and Marine Protected Areas (MPAs) associated with Orkney, Shetland, and the Western Isles, including St Kilda. It was noted that these areas are rich in cultural and natural heritage, and it was argued that national development status must not be used to override the protection and preservation of heritage assets, including but not limited to those found at Scapa Flow.

It was also observed that the statement of need does not recognise the importance of Scotland's islands for a wide range of internationally and nationally protected species and nature sites. It was suggested that there should be emphasis on the need for developments to avoid negative impacts, comply with relevant legislation, have a net positive impact and act as good example of sustainability.

Designation and classes of development

Comments on designation and classes of development included that this national development has the potential for significant impacts on nature. As the classes involved are extensive, it was suggested that it will be essential that development can be assessed for impacts on nature, in particular the cumulative effects on Special Protection Areas (SPAs) and marine mammals.

Comments on the individual classes listed included that:

• It would be helpful to clarify whether development providing employment in class (a) applies only to employment directly related to the Islands Hub for Net Zero.
• Class (b) should read 'exceeding 50 megawatts capacity' to reflect the Electricity Act threshold.
• In class (d) the description of infrastructure is unclear. Also, if a containerised solution is adopted by the sector, this classification under the 2009 Regulations may not be the most appropriate solution for green hydrogen.
• With respect to class (f), the proposal for floating structures to be introduced to support offshore wind might not be covered by text drawn to only include the present terrestrial proposals. The text could be made more flexible to accommodate a wider range of project opportunities across these locations.
• Both (f) and (g) should be amended to support 'quays' rather than the singular 'quay'.
• (h) should be amended to include specific reference to Sullom Voe (rather than 'Shetland') so it reads 'oil terminal modifications at Scapa Flow and Sullom Voe…'. It was noted that it is also possible oil terminals may grow to be more than just 'terminals' in the light of plans to use renewables to produce a variety of synthetic fuels.

There were also requests for additional classes to be added to include: a specific reference to the 'ORION Clean Energy Project' in Shetland and its related requirements for development; and aquaculture as a potential recipient/co-located activity to hydrogen energy.

Lifecycle greenhouse gas emissions assessment

With respect to the emissions assessment it was noted that production of 'renewable hydrogen' requires significant volumes of water, so when calculating the carbon cost of hydrogen production, the cost of water production and transportation should be included. Since island water supplies are often limited, the impact of water used for hydrogen on the local water environment and the ability of Scottish Water to provide resilient potable water services, should be considered.

ND8. Industrial Green Transition Zones (IGTZs)

Around 30 respondents commented on ND8. IGTZs were welcomed, although it was also suggested that Aberdeen, Sullom Voe, Opportunity Cromarty Firth and industrial and service bases within the Inner Moray Firth should be added to the proposed locations at St Fergus, Peterhead, and Grangemouth.

Also with respect to location, amending ND8 to refer to 'St Fergus, Peterhead, Grangemouth and surrounding area' was suggested, as was the addition of a red line boundary plan to define the geographical extent of the proposed IGTZs. It was proposed that the 'Scottish Cluster' IGTZ should encompass a broad area, including Peterhead, St Fergus and adjacent coastal land, in order to provide sufficient space for major industrial and energy infrastructure projects. It was also argued that IGTZs must not be located to the detriment of existing green spaces.

As an area of great national and international importance, it was argued that Peterhead should be given weight more comparable to Grangemouth within the national development.

CCS was considered to have a crucial role in decarbonising industry, with applications in relation to capturing carbon dioxide (CO₂) from industrial fossil fuel uses, processes such as cement manufacture, production of hydrogen from natural gas (blue hydrogen) and energy from waste (EfW) plants. It was also noted that the geology of the North Sea presents an economic opportunity for Scotland to offer a CO₂ storage service. Amendment of the statement on the Grangemouth Investment Zone, to make clear that any storage would take place in the North Sea, was suggested.

It was also suggested that the national development should commit to improving the economic efficiency of hydrogen production by investing in the use of by-products, and should also reference: desalination plants to facilitate hydrogen production; use of hydrogen derivatives, alongside hydrogen, particularly for the purposes of fuelling; and the use of hydrogen or hydrogen derivatives in gas blending, particularly at St Fergus.

Since the Scottish Government has committed to having 5GW of green hydrogen in Scotland by 2030, it was suggested this target should be acknowledged. An increased focus on established technologies such as wind, solar and battery storage was also suggested.

Other respondents expressed opposition to the production of blue hydrogen from fossil fuel with CCS as an alternative to renewable energy technologies. It was argued that this national development should not support the use of CCS as a means to extend the lifespan or operating capacity of existing fossil fuel plants, or enhanced recovery of oil and gas. While the statement that 'if any IGTZ is found to be incompatible with Scotland's transition to net zero, Scottish Government policy will change accordingly' was noted, the mechanism by which such a finding might be reached was seen as unclear. A precautionary approach was advocated, with relevant technologies thoroughly scrutinised prior to approval. The need to ensure the potential of existing carbon storage capacity is achieved as the first principle was also noted.

Concerns were also raised with respect to the reference to bioenergy in the statement of need. It was argued that burning wood for energy is not carbon neutral and that bioenergy should be removed from the classes of development.

Some respondents commented on issues related to flooding. It was suggested that developments should be designed to be adaptable and resilient to the impacts of future climate change to ensure that future investment in these areas can be made with minimal risk. It was also noted that some development types may be covered by flooding legislation and will not be considered within the planning system.

Issues raised specifically in relation to Grangemouth included that:

• In the interest of community wellbeing, town centre regeneration should be in advance of, or in tandem with, proposed industrial expansion.
• To reduce congestion and negative environmental impacts, port access needs to be managed in a way that segregates port road traffic from community road traffic.
• Flood protection scheme proposals will have significant impact on the community and need to be implemented sensitively.

It was also suggested that the Grangemouth Flood Protection Scheme may have significant adverse impacts on the Firth of Forth SPA, but that the appropriate assessment it not yet available. It was argued that significant enhancement of biodiversity should be provided, in addition to any works required as part of mitigating and/or compensating for the adverse effects of the development.

Although recognition of the potential to repurpose existing infrastructure was welcomed, it was argued that circular economy principles could be more clearly integrated into IGTZs. As an illustration, it was suggested proposals for CCS or renewable energy solutions should require consideration of future maintenance and the reuse potential of materials used.

Designation and classes of development

Comments on designation and classes of development included that class (d), and potentially (b) and (g), will occur in the marine environment and are therefore subject to marine rather than terrestrial plans. Other suggestions included that:

• Class (d) does not refer to the potential for hydrogen production offshore, only to offshore storage of captured carbon.
• Class (f) should also include explicit reference to storage as well as the production of hydrogen.
• Class (g) 'on or near-shore geological storage of hydrogen' seems unnecessarily restrictive, given that it excludes off-shore.
• Class (h) should include explicit recognition of the import and export of CO₂ within the need for port facilities for the handling and transport of CO₂.
• Class (i) should be removed.
• Class (o) should be amended to add 'and/or electricity infrastructure'.
• Class (p) should be amended since the port of Grangemouth does not support passenger vessels.

Addition of classes in relation to port-related infrastructure and freight facilities was also requested in relation to the port of Grangemouth.

ND9. Pumped Hydro Storage

Around 20 respondents commented on ND9. Comments in relation to the location of ND9 included that it should not be described as 'all Scotland' in view of the specific requirements of topography and landform. It was also suggested, however, that the text and map should be expanded to include pumped hydro schemes with permission or otherwise identified as vital for strategic reasons, not just the single one noted. Coire Glas, Red John and Sloy were all referenced. There was a view that prioritising Cruachan pre-judges the delivery timelines for other schemes, and it was argued that all pumped hydro storage above 100MW in capacity should be considered as a national development.

Consideration of wider potential energy storage technologies and opportunities within this national development was also suggested.

Other issues raised included that:

• Creation of local economic and community benefits and employment opportunities should be referenced.
• The potential impacts on the natural environmental and biodiversity are not mentioned in the challenges and opportunities section. Serious concerns were raised with respect to potential impacts on wild migratory fish species.

Designation and classes of development

Comments on designation and classes of development included that:

• Class (b) should be amended to add '...related to the pumped storage development'. Otherwise, it would seem to apply to all electricity generating structures.
• Since pumped hydro storage facilities can require both transmission and distribution infrastructure to export electricity to the grid, class (f) should read 'new and/or replacement transmission and distribution connections directly linked to the pumped hydro scheme.'

ND10. Hunterston Strategic Asset

Around 15 respondents commented on ND10. It was requested that the location 'Hunterston Port and Hunterston A power station site' should be amended to incorporate Hunterston B power station and the marketable employment land at Hunterston Estate identified in the Hunterston Strategic Development Area as defined in North Ayrshire's Adopted LDP. It should also be noted that Hunterston B has commenced the decommissioning phase. A red line boundary plan to confirm the geographical extent of the site was suggested.

With respect to strategic context, it was suggested it would be helpful to reflect the national scale of opportunity of a blue economy centred at Hunterston and a planned marine centre at Ardrossan.

The need for careful early planning was highlighted in relation to potential negative effects on a number of nationally important natural assets, including Southannan Sands Site of Special Scientific Interest (SSSI) and Ailsa Craig SPA. It was noted that the draft NPF references a community wealth building approach at Hunterston, and it was suggested that one aspect of this might be to involve community representatives in helping to manage natural capital assets, notably the SSSI.

Other comments included that:

• Development activity must be planned strategically to avoid impacts to ancient woodland.
• More clarity is needed around how this national development relates to the Place Principle and placemaking, and how Hunterston could relate to the CSGN.
• Sea, road and rail connectivity, and access requirements for the site, should be included and should be linked to STPR2 recommendations on improving the resilience of the trunk road network, including the A78.

It was also suggested that the requirement to 'work within the capacity of the transport network' could impede future developments at Hunterston, and that a potential need for road and rail network improvements should be recognised.

Designation and classes of development

Comments on designation and classes of development included requests for several amendments to the text as drafted, including that:

• Class (c) should be amended to read 'facilities for marine construction, energy generation, technology fabrication and decommissioning'.
• Class (d) should be amended to read 'facilities for marine energy servicing, to include renewable energy generation, testing, assembly, manufacture, servicing, maintenance, training, research and development'.
• Class (h) should be extended to include emerging small nuclear reactors, subject to appropriate legislation and regulation. Also, that class (h) should be extended to include 'electricity transmission infrastructure' given the presence of existing high voltage transmission infrastructure.

An additional class was also proposed for a 'Aquaculture, research and development centre', and a reference to a proposed digital hub at Hunterston and any associated infrastructure needs was suggested.

With respect to class (f), it was argued that for consistency the language used to describe CCS and/or low carbon hydrogen should follow that used in relation to Grangemouth. The intention to enable CCS was welcomed and it was suggested that there could be potential for CO₂ captured in Ireland, or the west of the UK, to be transported by ship to Hunterston, then by pipeline, road or rail to St Fergus for storage.

Lifecycle greenhouse gas emissions assessment

With respect to the emissions assessment, it was noted that production of 'renewable hydrogen' requires significant volumes of water so when calculating the carbon cost of hydrogen production, the cost of water production and transportation should be included.

ND11. Chapelcross Power Station Redevelopment

Around 15 respondents commented on ND11, including a view that there should be a greater emphasis on renewable energy to take advantage of the transmission lines and national grid infrastructure.

Other points related to protection of the natural environment and included that:

• Redevelopment should be designed to retain and enhance an extensive area of nature-rich unimproved grassland. Embedding this natural asset into the green infrastructure of the site, as part of a placemaking approach, will help provide multiple benefits for the local community.
• The potential for habitat creation/enhancement in the area should be acknowledged.
• Development activity must be planned strategically to avoid impacts to ancient woodland.

Designation and classes of development

Comments on designation and classes of development included that the description of the designations and classes of development that are related to CCS and / or low-carbon hydrogen should be consistent across national developments. Other points raised included that 'Low carbon hydrogen' will contribute to carbon emissions and continued fossil fuel dependence and should not be supported.

Lifecycle greenhouse gas emissions assessment

With respect to the emissions assessment, it was noted that production of 'renewable hydrogen' requires significant volumes of water, so when calculating the carbon cost of hydrogen production, the cost of water production and transportation should be included.

ND12. Strategic Renewable Electricity Generation and Transmission Infrastructure

Around 65 respondents commented on ND12. This was the national development that attracted the highest level of comments, and some responses were extensive. Issues that are also discussed in the analysis relating to Policy 19 (Green Energy) are not covered in detail here.

Although aspects of this national development were welcomed, some respondents called for clarity that, in the planning balance, there should be significant weight attached to development that contributes directly to achieving net zero. A presumption in favour of such development was also requested. It was also suggested that ND12 should reference Policy 19 (Green energy).

Although a small number of respondents agreed with the requirement that renewable energy generation developments should equal or exceed a threshold of 50 megawatts (MW) capacity in order to qualify for national development status, this threshold was also questioned, and how development on a scale of less than 50MW capacity should be treated in decision-making was queried. Some respondents argued that it should be recognised that even small-scale projects provide a valuable contribution to meeting renewables targets, or that it should be clear that the absence of national development status for sub-50MW schemes should not be used by decision makers to question the need for a development. It was also suggested that the 50MW threshold should be reduced to 20MW, that smaller schemes could be handled in aggregate, or that all renewable energy generation and storage schemes should be included.

An alternative view was that the threshold should be raised, for example to development exceeding 100MW capacity, since the benefit of such large-scale projects can clearly be seen to be of national importance. It was suggested that development below the threshold would then be determined locally in accordance with placemaking principles and the development plan.

The 50MW threshold was also questioned since development exceeding 50MW capacity is subject to provisions of the Electricity Act. On a related point, it was noted that the 50MW threshold under S36 of the Electricity Act applies only to onshore generation, with a threshold of 1MW applying to offshore generation. It was argued that, if this cannot be rationalised, then the position and handling of offshore developments between 2 and 49MW should be considered. There were also calls for explicit reference to offshore wind, including the onshore elements of offshore renewable energy developments, and the anticipated role of ports and harbours in supporting offshore wind. References to both ScotWind Leasing and INTOG Leasing were suggested.

With respect to new and/or replacement high voltage electricity lines and interconnectors, it was argued that limiting national development status to infrastructure of 132kV or more may diminish the role of projects below this threshold. Designating all grid infrastructure (whether or not at 132kV) as nationally significant, in order to de-bottleneck a heavily constrained system, was proposed.

Some respondents considered the implications of the 'all Scotland' location. There were requests for plan-led development, spatial guidance or a more detailed strategy laying out where there is a presumption in favour of wind. One suggestion was to create a separate wind energy national development, with specific guidance on where the areas of search for these developments should be. It was argued that the text requires a caveat that while need is apparent, location is something that requires to be determined by consideration of a range of local factors.

The need to avoid unintended and potentially damaging consequences in other policy areas was also highlighted, including in terms of the six qualities of successful places. It was argued that an approach in line with the Place Principle would provide a positive and more collaborative way forward. With respect to landscape, there was a suggestion that landscape considerations and requirements must be reflected in NPF4 to ensure that risks are managed effectively. Poorly planned onshore renewable energy infrastructure (including placement of junctions and cables, and the creation of access roads) was said to have devastating impacts on landscape. It was also argued that an understanding of the cumulative effect of successive developments on the accommodative capacity of the landscape is required.

In terms of natural assets, there were calls to avoid habitat fragmentation, and to ensure protection of sensitive natural assets, such as irreplaceable ancient woodland. A plan-led approach and identification of potential constraints at an early stage was recommended. It was also argued that:

• National development status should focus on the reuse of existing infrastructure, such as repowering existing onshore wind development sites.
• Policy relating to the nature crisis and peatland protection should be referenced, and there should be clear recognition that green energy still needs to address these policy requirements.
• Mitigation measures identified in the Integrated Impact Assessment's (IIA's) Environmental Report should be pulled through to NPF4.

Designation and classes of development

Comments on designation and classes of development included that:

• As noted above, the proposed 50MW capacity threshold set out in class (a) should be reconsidered.
• Classes (a) and (b) should be amended to recognise all renewable energy developments, and upgrades to the grid, as constituting national development.
• It should be made clear that class (b) relates to the high voltage electricity transmission network which is the electricity network involved with the transmission of voltages of 132kv or above.
• What is meant by 'replacement' should be clarified since there are circumstances where the replacement of an electricity line is not subject to the requirement for statutory consent. The term 'new and/or upgraded' used in NPF3 was thought to provide a clearer definition.
• It is not clear whether the reference to 'high voltage electricity lines' includes buried cables to deliver offshore renewable electricity to onshore substations and the text should be amended to 'high voltage electricity lines, cables and interconnectors…'.
• With respect to class (c), it was noted that there is no clear statement linking onshore developments to offshore generation. It was suggested that the designation and classes of development should be amended to more closely reflect ND4 (Enhanced High Voltage Energy Transmission Network) from NPF3.

Other factors that respondents suggested should be referenced in relation to ND12 included the increased energy demands and infrastructure requirements of the decarbonisation of transport, including public transport and mass transit, road and rail freight and logistics, and personal travel.

Some respondents suggested additional classes of development that might be added, including that green hydrogen should be specifically included as a class of development within ND12.

Deciding when a proposal should be handled as a national development

Comments included that, although the reference to a 50MW trigger is clear, there is no further guidance relating to how a proposal should be assessed and determined. It was also argued that spatial references – currently absent from ND12 – would be key to giving local authorities clarity on when a proposal should be handled as a national development.

A further suggestion was, since communities may be unfamiliar with what constitutes a transmission network compared to a distribution network, ND12 could be better worded to make clear that it relates to the high voltage electricity transmission network.

ND13. High Speed Rail

Around 30 respondents commented on ND13. While high speed rail was supported, comments often related to areas of the country that will not benefit from current proposals, with references to southern Scotland, Dundee, Aberdeen and Inverness.

Other points raised included that:

• The relationship to STPR2 recommendation 43 (Major station masterplans) and Recommendation 45 (High speed and cross border rail enhancements) should be set out, including the need for further work to determine the future of high speed rail in Scotland.
• To avoid detrimental impacts, the impact on locally liveable neighbourhoods should be considered. Any route should not affect current and future development areas, their residents, or prejudice delivery of land uses approved through existing consents.
• The statement should recognise the need to embed protection of ancient woodland, veteran trees, and other sensitive biodiversity assets at the outset of project planning. New and enhanced green corridors should be delivered for biodiversity.
• Scottish Government funding priorities and cost recovery proposals for qualifying developments should be included.

Designation and classes of development

Comments on designation and classes of development included that:

• Class (a) does not mention high speed lines.
• Major station masterplans and high speed rail termini should be included.
• A holistic approach to delivery of rail infrastructure, and other types of development alongside it set out in the IIA, should be more clearly referenced in the national development; this would ensure that its role in supporting low carbon, efficient use of land as part of an improved placemaking agenda is clear.

It was also noted that works which benefit from permitted development rights are not impacted by the Hierarchy Regulations, and so are not caught by definitions of national development. It was reported that the definition captures many items which would normally be permitted development, and that would benefit from deemed consent and not needing planning permission. It was suggested that this principle could also apply to transport infrastructure in relation to ND10 (Hunterston) and ND18 (Stranraer Gateway).

National developments to deliver sustainable, distinctive places

ND14. Clyde Mission

Around 15 respondents commented on ND14. National development status for Clyde Mission was welcomed, including as aligning with the Glasgow City Region Climate Adaptation Strategy and Action Plan. It was suggested that combining the Clyde Mission with ND4 (Urban Sustainable Blue and Green Drainage Solutions), as well as relevant policies on coastal change, flood risk and water management, would help the area adapt to the impacts of climate change. It was also argued that it will be important to consider both the whole hydrological system, and the impacts of climate change on communities along the Clyde, to avoid development that might exacerbate upstream flooding or require hard engineering solutions to mitigate sea level rise and/or storm surge. A commitment to further modelling and analysis was suggested.

Concerns were also raised with respect to the implications for ND14 of a Future Functional Floodplain (as outlined in Policy 13). It was reported that introduction of a Future Functional Floodplain would result in a flood risk constraint affecting over 50% of most development sites and, in combination with Land Use Vulnerability guidance, would render sites virtually undevelopable. It was argued that a proportionate response to flood risk is required, recognising both the hazards posed by different types of flooding and that different responses may be acceptable, depending on the nature of the risk.

Comments about location included that the description is ill defined. It was suggested that 'up to around 500 metres from the river' should be amended to read 'where any part of an application site is within 500 metres from the river'. It was also suggested that it should be made clear that this designation relates to rural Clydesdale as well as urban reaches, and to coastal and estuarine environments.

Other suggestions included that:

• A key outcome should be for learning from the collaboration of the Scottish Government, local authorities, key agencies and universities to be shared to support regeneration and land reuse in areas with similar challenges.
• Improved sustainable transport in support of the five mission areas should be emphasised, and the relationship with Clyde Metro highlighted.
• Opportunities for sustainable high value growth identified within the Strategic Development Frameworks for Govan – Partick and the River Clyde merit incorporation within the development description.
• The opportunity to deliver biodiversity enhancements has not been recognised and should be included to maximise wellbeing impacts, create high quality places and mitigate the loss of biodiversity along the Clyde.
• In order to address the issue of scale and to support local living and adapting to climate change, the classes of development should be presented in reverse order, such that strategic and infrastructure issues are placed first.
• Connections to the Loch Lomond and the Trossachs National Park, via the Vale of Leven, could be recognised.
• Integration of the historic environment and heritage skills could be explored.

Designation and classes of development

As a general point it was suggested that, since several national developments include port-related development, there could be a more general 'presumption in favour of port development aligned with Scotland's strategic goals'. With respect to this national development, it was suggested that the classes of development should be presented in reverse order, progressing from strategic and infrastructure first to detailed individual sites.

Clarification was requested with respect to the intended scope of development that might be given national development status, including that, as drafted:

• Any 'major' development identified in the list of classes, and within 500m of the Clyde, would be a national development.
• A significant number of developments might be covered. As an example, it was suggested that separate applications for different phases of residential development on the Queens Quay site in Clydebank could be considered national developments.

A concern was raised that, as drafted, ND14 could lead to development of greenfield sites. To avoid an implication that greenfield (and therefore potentially natural floodplain) development along the Clyde from source to mouth, within 500m of the river and coastal edge, would have national development status, clarification was sought that class (b) only applies to vacant and derelict sites.

Clarification was also requested as to whether ND14 applies to vacant and derelict sites only, or brownfield land more generally – the latter having a wider definition which includes vacant and derelict land, as well as other previously used land.

Amendment to (d) was requested to make clear that, for safety or public security reasons, 'new and/or upgraded active and sustainable travel and recreation routes and infrastructure' should be compliant with the Scottish Outdoor Access Code (2005) with respect to an exemption from freedom to roam legislation.

Deciding when a proposal should be handled as a national development

As noted above, some respondents felt that the locations in which major applications become part of the national development are not adequately defined.

There was also a view that, while the catchment-area approach is welcome, the scale could create challenges in terms retaining the clear direction needed and the delivery of meaningful opportunities.

ND15. Aberdeen Harbour

Around 15 respondents commented on ND15. Points raised included that reference should be made to the Port of Aberdeen North and South Harbours, rather than Aberdeen Harbour and Aberdeen South Harbour. Also with respect to location there were views that:

• The area to which the designation applies is unclear.
• Greenfield land near the south harbour should be explicitly excluded.

There were also calls to:

• Reference delivery of the proposed ETZ. The ETZ was seen as an integral part of the Port of Aberdeen South Harbour proposals to secure a green energy transition, and it was argued that NPF4 should make clear that benefits to Aberdeen City can only be secured if the economic opportunity at Port of Aberdeen South Harbour, including the ETZ, is realised.
• Broaden the national development to reflect the Freeport zone being considered and reinforcing existing linkages and future opportunities for synergies between Aberdeen Harbour and the IGTZ in Northern Aberdeenshire.
• Broaden the scope of the national development to help to address causes of deprivation in the vicinity by delivering a sustainable, nature-rich, 20-minute neighbourhood to help regenerate Torry and its quality of environment.
• Adopt a placemaking approach to direct development to optimum areas, focusing on strategic connections including blue-green infrastructure. It was suggested that this should highlight the existing blue-green infrastructure, such as St Fittick's Park, as well as identifying opportunities for enhancement.
• Focus on regenerating existing industrial land, rather than reorganising land use, around the South harbour.
• Make greater reference to how biodiversity, and its importance to communities, will be accommodated.

Clarification was sought with respect to what is meant by a 'development in the location', and how far from the existing North or South Harbours this could be. Whether development has to have some relationship with the harbour, and how this is determined, were also queried.

Designation and classes of development

Comments on designation and classes of development included that:

• Class (c) 'new and/or upgraded green infrastructure' requires further explanation.
• It is of concern that 'buildings and facilities for commercial, manufacturing and industrial uses' covered in class (d) should be considered a national development. A more appropriate approach might be to seek a Masterplan for this area.
• It is not clear whether class (d) applies to both Aberdeen Harbour and Aberdeen South Harbours and whether it relates specifically to renewable and net zero carbon technologies.
• With respect to class (e), it should be made clear that support for hydrogen production relates only to green hydrogen.
• There should be explicit reference to hydrogen pipelines and storage alongside existing references to hydrogen production.

Additional uses were also requested in respect to the proposed ETZ, including in relation to: port-centric manufacturing and distribution; offshore technology; decommissioning, energy transition and renewable energy.

Deciding when a proposal should be handled as a national development

It was argued that both the boundary of the area to which the designation applies, and whether a proposal needs to be related in some way to harbour use, are unclear.

16. Dundee Waterfront

Around 10 respondents commented on ND16. Continued designation of Dundee Waterfront as a national development was welcomed. However, it was also suggested that not all of the Dundee Waterfront development to date has been positive, including because of the need to cross a number of lanes of traffic to reach the Waterfront.

A shift in emphasis from economic revitalisation to include a more balanced place-based aspiration for Dundee Waterfront was suggested, or that there should be more emphasis on how Dundee as a whole will benefit, including bringing together low carbon innovation, the environment, Dundee's location along the Firth of Tay and community benefits. An opportunity to create strategically important green and blue space that could serve as a regional hub, and catalyst for a Tayside green and active travel network, was highlighted.

It was suggested that to protect the internationally important nature conservation sites of the Tay Estuary, a requirement to include consideration of environmental effects should be reflected in the same way as for Aberdeen Harbour.

Designation and classes of development

Comments on designation and classes of development included that:

• A spatial dimension is required to direct development and identify suitable uses. This should also highlight the existing natural heritage assets, such as the Riverside Nature Park, as well as identifying opportunities for enhancement.
• The Waterfront should be an area for active travel and a car-reduced zone.
• Class (d) should be reworded to 'new and/or upgraded active travel and sustainable transport routes', since sustainable transport links in this area integrate more than active travel infrastructure, for example bus infrastructure.
• Consideration should be given to whether the addition of land reclamation for port expansion is a sustainable approach to development. It was noted that reclamation can adversely affect coastal morphology, exacerbate erosion and impact upon natural flood management infrastructure. It was also noted that reclaimed land can also add to the flood risk management financial burden, if protection from rising sea levels is required in the longer term.
• Land reclamation for port expansion will require detailed Habitats Regulations Appraisal (HRA) at the project stage, and may require consideration of derogation arguments.

Deciding when a proposal should be handled as a national development

As noted above, the location information currently provided was not thought to be sufficient.

ND17. Edinburgh Waterfront

Around 10 respondents commented on ND17, with general points including that there should be read across to ND1 (CSGN), ND2 (NWCWN) and ND4 (Urban Sustainable, Blue and Green Drainage Solutions).

Several points were made about location information, which was described as vague or ill-defined. The term 'initial focus' was queried, and it was suggested that, as drafted, it could be argued that any major development in Edinburgh constitutes a national development. It was suggested that the intended extent of Leith and Granton would be better expressed via a map or plan.

It was argued that a focus on Leith to Granton needs to be set in the context of the wider coastal environment, and that the potential for negative effects on landscape and seascape need to be addressed. It was noted that a detailed assessment of a number of internationally and nationally important natural assets will also be required at project stage. Other comments included that the area's biodiversity should be protected and enhanced; the Leith Dock Locks SPA was highlighted in particular.

It was also recommended that the mitigation measures set out in the IIA should be included and strengthened.

Designation and classes of development

Comments on designation and classes of development included that:

• In addition to development of new and/or upgraded active and sustainable travel routes, access to the foreshore should be accommodated.
• In addition to designating green and blue infrastructure as a class of development, reference the Edinburgh Nature Network should also be included.

Deciding when a proposal should be handled as a national development

As noted above, the location information currently provided was not thought to be sufficient.

ND18. Stranraer Gateway

Around 15 respondents commented on ND18. It was suggested that the text relating to Stranraer should have a greater focus on the quality of life, wellbeing, and sustainability of the town, and should include 20-minute neighbourhoods, recreational areas, blue-green infrastructure and active travel. Highlighting and seeking opportunities to enhance Loch Ryan as a valuable natural asset was recommended, and the addition of habitat creation/enhancement to include provision for breeding shoreline waders was requested. It was also noted that development activity must be planned to avoid impacts to ancient woodland.

There was also a view that there is no justification for the regeneration of one town to be made into a national development.

Designation and classes of development

Comments on designation and classes of development included that:

• The relationship to STPR2 Recommendation 40: Access to Stranraer and ports at Cairnryan should be set out.
• There is no reference to active and sustainable travel connections to and within the area. Classes of development should more clearly support multi-modal transport infrastructure.
• Improved connections between Stranraer rail station and Cairnryan ferry terminals should be included. In particular, it was argued that a high-quality cycle route from Stranraer to Cairnryan would provide a sustainable travel option for both tourists and local people.
• Relocation of Stranraer rail station can play a key role in unlocking the East Pier for development.

It was also noted that Stranraer is being considered for the potential Cairnryan Border Control Post, which is the subject of a Scottish Government Special Development Order.

Question 21 – Do you think there are other developments, not already considered in supporting documents, that should be considered for national development status?

Around 260 respondents made a comment at Question 21.

Many projects were suggested to be of national importance, or to merit national development status. Projects listed are grouped broadly by subject area, although clearly some could fall under more than one heading. Some respondents made a case for retaining the national development status of projects that were listed as such in NPF3 but are not listed as national developments in the draft NPF4. These are marked with an asterisk.

Suggested extensions and amendments to the 18 proposed NPF4 national developments have been noted in the analysis above at Questions 19 and 20.

Housing

• Delivery of new housing.
• Smart clachans.
• Self-build development.
• Housing for older people/housing with care.
• Demonstration projects to show how large-scale new places or settlements, with a high proportion of quality housing, can be delivered while achieving net zero/zero carbon aims.
• Retrofitting and adaptation of existing housing.

Repopulation

• A Western Islands and North of Scotland repopulation area.

Rural

• Rural development - understanding the specific needs of rural areas.

Agriculture/food

• Food production and security or food growing and harvesting.

Environment

• A mapped national Scottish Nature Network.
• Existing National Parks, and the creation of new National Parks.
• Control of invasive non-native species.
• Moray Forest.
• Moray Coast Natural Heritage Park.
• Perth – The Biodiversity Capital of Scotland.

Circular economy/waste management/materials

• Circular, sustainable management of Scotland's scrap steel in Scotland.
• National coordination of waste management infrastructure needs, and a plan for closing incineration plants.
• Transformation of sites on the Vacant and Derelict Land Register to deliver net zero and wellbeing objectives.
• A national programme for establishing Scottish materials and products supply, looking at the reuse of products, as well as the use of local materials.

Infrastructure

• Coastal defence civil engineering projects.
• Cross sector, catchment-wide initiatives to introduce natural flood risk management measures.
• Improved mains water supply.
• Communications resilience.

Transport/public transport

• STPR2.
• Decarbonising transport.
• Strategic Transport Enhancement.
• North West Strategic Transport Corridor.
• Bus Service Improvement Partnerships.
• Major public transport interchanges - making public transport more accessible and attractive for disabled people and the general public.
• Expanded, fully electrified rail network.
• Southern Scotland Transport Network, including extension of the Borders Railway.
• Reston Station.
• Glasgow Airport.
• Islands airports.
• Strategic airport enhancements.*

Active travel

• The Borderlands Project 'Destination Tweed' long distance path.

Roads

• Electric A9 project.
• Vehicle charging infrastructure.
• Toll of Birness junction improvements.
• Dualling of the A96.

Energy generation/transmission and storage

• Nuclear power and small nuclear reactors.
• Microgeneration.
• Wind energy development.
• Cromarty Firth as a key location for the development of Scotland's offshore wind industry and for an offshore wind hub.
• Tidal stream energy generation.
• Geothermal energy.
• Hydrogen development, regardless of location.
• Blackhillock sub-station and the proposed hydrogen corridor between Aberdeen and Inverness.
• Buckie Harbour servicing offshore wind farms.
• Coire Glas Hydro Pumped Hydro Storage Scheme.*
• Batteries.

Energy efficiency/transition

• Perth Smart Energy City Programme, aiming to make Perth one of the first UK cities to be net zero, using smart and off grid energy systems.
• Energy Demand Reduction.*
• The transition away from oil and gas in the North East.
• Large-scale adoption of renewable and low carbon fuels at a national level.
• District heating.

Ports and harbours

• Scapa Flow floating harbour.
• Orkney Harbours (as a standalone project rather than as part of ND7)
  • a) Scapa Deep Water Quay (Scapa Flow)
  • b) Orkney Logistics Base (Hatston).
• Transhipment Container Hub development project.
• Fraserburgh Harbour Masterplan.
• Freight on the Forth.*
• HMNB Clyde and the development of the Maritime Change Programme.

Historic assets

• Long-term maintenance and conservation of historic environment assets, especially (but not limited to) sites currently considered of national importance.

Specific developments

• West Edinburgh.
• Europark.
• South of Scotland NCIZ.
• Shawfair.
• Perth West and a Regional Logistics, Fulfilment and Business Innovation Park.
• Ravenscraig.*
• Redevelopment of Dounreay.
• Redevelopment of Longannet.
• Machrihanish employment zone.
• The cities of Aberdeen, Dundee, Edinburgh, Glasgow, Inverness, Perth and Stirling.

Science/technology

• Aerospace and space cluster around Prestwick Airport and the Airport.*
• The Moray Aerospace, Advanced Technology and Innovation Campus Moray Growth Deal Project.
• Spacehub Sutherland.
• Life/marine science cluster at Scottish Association for Marine Science, Dunbeg/Oban.
• Edinburgh Biomes at the Royal Botanic Garden Edinburgh.
• Ongoing funding for the Better Biodiversity Data Project.