National Planning Framework 4: integrated impact assessment post adoption statement

4. How the Integrated Impact Assessment has been taken into account

4.1. Environmental Report and supporting information

4.1.1 The Integrated Impact Assessment Environmental Report^[22] set out the assessment findings for the draft NPF4^[23]. Overall, the following likely significant environmental effects were identified:

4.1.2 Biodiversity, flora and fauna: The emphasis on protecting and enhancing biodiversity was identified as being likely to lead to significant long term cumulative positive effects on biodiversity, flora and fauna, including through new policies on enhancing biodiversity.

4.1.3 Climatic factors: Collectively, the draft policies and proposals were identified as being likely to have significant long term positive effects on climatic factors, contributing to reduced greenhouse gas emissions, and helping to facilitate a transition to net zero. As they embed actions to increase community and infrastructure resilience to extreme weather events, the policies and proposals can also support adaptation to climate change.

4.1.4 Air: Policies and proposals which reduce emissions overall are likely to have cumulative positive effects on air quality. Negative impacts on noise and air quality, including dust and odour, may arise during construction of the national developments. These will be temporary and local in nature, and will be managed at the stage when specific projects are brought forward for consent.

4.1.5 Water: The overall focus on climate change and climate change adaptation will have cumulative positive effects on water through increased focus on flood risk, water shortages and coastal erosion. It was identified that draft NPF4 policies and proposals may also help improve water supply and waste-water systems. It was noted that proposals for waterfront developments and new development at ports and harbours may negatively impact water during construction and operational phases, and will require management at the stage when specific projects are brought forward for consent.

4.1.6 Soil: Aspects of the draft NPF4 were identified as likely to have positive cumulative benefits for soils. Policies relating to woodland expansion and green infrastructure can help improve soil stability and drainage, and can help to improve the quality of places. Positive cumulative effects on soils can also arise through an emphasis on the reuse of derelict and vacant land, with secondary positive impacts on water quality. The potential for negative effects on soils was identified as arising from some of the proposed national developments.

4.1.7 Cultural heritage and Historic Environment: Significant positive cumulative effects were identified given the emphasis within the draft NPF4 on protecting and enhancing locally, regionally, nationally and internationally valued historic assets and places. Draft policies and proposals relating to woodland expansion and green infrastructure can also act to improve the setting of historic assets. The potential for negative effects was also identified, including from some national development proposals.

4.1.8 Landscape and Geodiversity: The Environmental Report identified the potential for some proposed national developments and draft policies to result in negative effects on landscapes. Initiatives such as the Central Scotland Green Network and national walking and cycling routes provide opportunities to protect and enhance townscapes and landscapes and to increase experience and enjoyment of these. Draft policies which aim to increase woodland and forestry were identified as having the potential to improve landscape character, depending on the scale and nature of change. It was noted that support for peatland protection and restoration could also benefit some iconic and culturally significant landscapes.

4.1.9 Material Assets: The focus on an infrastructure first approach within the draft NPF4 was identified as having potential to ensure that places function effectively and development improves, rather than detracts from quality of life. It was noted that promoting greater coordination of infrastructure works and planning, at both the regional and local scales, can minimise the potential for negative indirect and cumulative effects, for example through reduced disturbance during construction stages and through reduced fragmentation of green infrastructure and nature networks. An increase in development, for example housing or renewable energy, could lead to increased pressures on existing land uses through increased competition between land uses and with other forms of development.

4.1.10 Population and Human Health: The draft policies and proposals were identified as having potential to give rise to significant benefits for population and human health. Health and wellbeing benefits may arise where policies and certain national developments lead to more people walking, wheeling and cycling. Positive impacts could also arise from improved sense of place, including benefits for communities. These can be maximised where a focus is given to areas currently experiencing levels of disadvantage.

4.1.11 Early and emerging findings from the Habitats Regulations Appraisal concluded that, subject to detailed design and the implementation of avoidance and mitigation measures, including further study and assessment where necessary, projects brought forward under each proposed National Development could be delivered without adverse effect on the integrity of any European site, either alone or in-combination with other currently known plans or projects, with the exception of specific classes of development relating to Scapa Flow and Dundee Waterfront. Subsequent changes made to address these issues are set out in Section 6 – 'Reasons for selecting National Planning Framework 4 as adopted'.

Assessment Recommendations

4.1.12 The Environmental Report identified opportunities for potential positive effects to be enhanced, and for negative effects to be mitigated, as policies and proposals are applied through the planning system. In general terms, development has the potential for largely localised adverse environmental effects on each of the SEA topic areas. Effects are likely to be influenced by the scale and nature of development, and the sensitivity of the receiving environment. Many of the planning policies in the NPF4 as adopted seek to mitigate such effects through the application of detailed criteria to be applied at planning application stage.

4.1.13 The Environmental Report set out a range of proposed mitigations relevant to the Spatial Strategy, including:

• Effects on biodiversity should be minimised through siting and design, and enhancement measures applied in keeping with national policy. Policy 3 of the NPF4 as adopted sets out that development proposals will contribute to the enhancement of biodiversity, and stipulates careful planning and design as a way to minimise adverse impacts.
• Focus should be given to designing buildings, infrastructure and spaces which are adaptable to climate change. 'Adaptable' is one of the 'Six Qualities of Successful Places' set out in the NPF4 as adopted.
• Opportunities should be sought to maintain, restore and repurpose historic assets to support sustainable placemaking. This closely aligns with the policy intent of Policy 7 (Historic assets and places) of the NPF4 as adopted.
• Development proposals should be designed to a high quality so that the scale and nature of the development contributes positively to the character and sense of place of the area. The NPF4 as adopted contains provisions for protecting character and sense of place including through Policies 14 (Design, quality and place), 16 (Quality homes), 17 (Rural homes), 20 (Blue and green infrastructure), and 29 (Rural development).

4.1.14 Also identified in the Environmental Report were opportunities for positive effects to be maximised, particularly where a focus is given at planning and consenting stages to opportunities for multiple benefits to arise. For example, through the role of natural solutions in flood risk management and support for a transition towards net-zero which leads to benefits not only for climate mitigation and adaption, but also for biodiversity.

4.1.15 Where policies support reduced pressure on, and improved sustainability of, natural and built assets, the environmental assessment anticipated positive impacts arising for climatic factors, material assets and population and human health, particularly where this could lead to wider environmental benefits such as improved ecosystem health and increased resilience to the impacts of climate change. Furthermore, the potential for wider benefits was also identified where a focus is given to improved placemaking, including through the support for sustainable modes of travel and improved access to goods and services and high quality open spaces. NPF4 includes 6 overarching spatial principles which have been further strengthened to support the planning and delivery of sustainable, liveable and productive places. NPF4 as adopted includes a new table on page five setting out how the spatial principles fit into the overall framework.

4.1.16 Table 7.1 of the Environmental Report^[24] set out the recommendations identified for individual proposed national developments which will be relevant where detailed project proposals are brought forward through the planning application process. NPF4 as adopted is clear the National Developments are intended to be examples of the Place Principle and placemaking approaches. They should be delivered in a way which helps to apply the principles, opportunities, challenges and policy identified in NPF4 in the round. Their contribution to addressing the global climate emergency and nature crisis, community wealth building and just transition will be of particular importance.

4.2. Society and Equalities assessments

Equalities Impact Assessment

4.2.1 The EQIA has supported the development of NPF4. The Scottish Government considered the three elements of the Public Sector Equality Duty:

• Eliminate unlawful discrimination, harassment and victimisation;
• Advance equality of opportunity between people who share a protected characteristic and those who do not; and
• Foster good relations between people who share a protected characteristic and those who do not.

4.2.2 The EQIA helped highlight potential issues which may impact disproportionately on those with particular protected characteristics.

4.2.3 Participation: Evidence shows that people want to be involved in shaping the places where they live, work or stay. The Scottish Government wishes to encourage people from all protected groups to participate in public life by engaging in shaping the way their communities develop and being involved more proactively in decision-making. However, levels of perceived influence over local decision making have been consistently low over recent years, and across all subgroups of the population. The Scottish Government is committed to providing guidance on effective community engagement in local development plans.

4.2.4 Housing and accommodation: Meeting the housing needs of people living in Scotland including, in particular, the housing needs for older people and disabled people, is one of six statutory outcomes for the NPF.

4.2.5 Housing and accommodation needs have particularly been raised under the age, disability and race characteristics but are important across a range of societal subgroups.

4.2.6 NPF4 as adopted seeks to encourage, promote and facilitate the delivery of more high quality, affordable and sustainable homes, in the right locations, providing choice across tenures that meet the diverse housing needs of people and communities across Scotland.

4.2.7 Policy 16 (Quality Homes) will support proposals for newhomes that improve affordability and choice. This could include: adaptable and wheelchair accessible homes; affordable homes; a range of size of homes such as those for larger families (which may have a positive outcome for certain black and ethnic minority groups); and homes for older people.

4.2.8 We know that many Gypsy/Travellers prefer to live on private sites, which can help support independence, self-sufficiency and security. But they have often found it difficult to access the planning system and get the appropriate permission to develop their own sites.

4.2.9 NPF4 includes a policy for public or private, permanent or temporary sites on land not identified for this use in the development plan. Making provision for the development of private sites can help Gypsy/Travellers to maintain their traditional lifestyle.

4.2.10 Spaces and Places: Recent evidence has reflected upon how development of the built environment has not captured and reflected how different people use spaces and places. The evidence is particularly strong under both the disability and sex characteristics but there is also evidence relating to the LGBTQ+ community.

4.2.11 Consultation responses suggested that people were supportive of the concept of local living and 20 minute neighbourhoods but had concerns around how the policy would be implemented. The revised draft NPF4 was amended to reflect a more flexible approach to this in rural areas through wider emphasis on 'local liveability'. The Government is committed to providing further guidance on local living and 20 minute neighbourhoods. Local living can provide an opportunity for places to be shaped to enable people to meet the majority of their daily needs within a reasonable distance of their home, preferably through walking, wheeling and cycling or using sustainable transport. Local input will be vital in shaping what this looks like, particularly in rural areas. This should lead to the reduction of barriers to people's access to equal opportunities in the built environment, and to economic, green and open space and play opportunities.

4.2.12 Connectivity: Connectivity is not only about transport and travel, but also digital connectivity and the day to day interactions which were missing to a certain extent during the recent lockdown.

4.2.13 Evidence suggests that being older or disabled, living in a deprived area or living in social housing are risk factors for exclusion from access to digital services. NPF4 as adopted supports support the roll-out of digital infrastructure across Scotland, to deliver appropriate, universal and future proofed digital infrastructure across the country so that local living is supported and the need to travel is reduced.

4.2.14 Transport is a key policy area for NPF4. NPF4 as adopted will support developments that prioritise walking, wheeling, cycling and public transport for everyday travel and reduce the need to travel unsustainably. There will be benefits for people of all ages arising from an increase in local living and the creation of walkable, liveable and thriving places. The aim is to provide and encourage sustainable travel options, provide communities with local access to the wide range of facilities, services, work and opportunities for socialising, leisure and play activities that they need to support a healthier and flourishing community.

4.2.15 Health and Wellbeing: Improving the health and wellbeing of the people of Scotland is one of the six statutory outcomes for the NPF. Evidence suggests that planning and places play a crucial role in supporting health and physical activity, for example with our support for 20 minute neighbourhoods, greenspace, active travel and in managing access to food, food production, community growing, etc.

4.2.16 Outdoor spaces for play, sport and recreation can make a significant contribution towards creating more liveable and healthier places. Children experience a range of health, wellbeing and educational benefits from outdoor play and learning in and connecting with nature.

4.2.17 Places are important for physical and mental health and overall wellbeing. NPF4 as adopted supports active travel and opportunities for play and recreation. Cognisance of locations of concern for suicide is included in addition to support for green infrastructure and health and social care services and infrastructure.

4.2.18 The reuse of vacant and derelict land and properties can contribute to climate change targets and support biodiversity, health and wellbeing improvements and resilient communities by providing much needed greenspace, growing spaces and other community benefits. NPF4 as adopted prioritises the use of brownfield, vacant and derelict land and properties, including supporting appropriate temporary uses where proposals for permanent development are unlikely to be imminent.

Child Rights and Wellbeing Impact Assessment

4.2.19 The Scottish Government found that the proposals do not impinge negatively upon articles of the United Nations Convention on the Rights of the Child (UNCRC) or the indicators of wellbeing and that it was considered that there were no issues that will impact negatively upon children and young people. The articles of the UNCRC which were considered to be particularly relevant to NPF4 were: Article 12, Article 24, Article 27 (1-3), and Article 31^[25].

4.2.20 Policy interventions identified through the CRWIA include:

• Updated policy on design, quality and place, requiring plans and proposals to reflect the six qualities of successful places. The NPF4 as adopted ensures this is the case through Policy 14 (Design, quality and place).
• Reference made to the UN Convention of the Rights of the Child such that young people must be encouraged to play an active role in the planning system. The cross-cutting outcome 'A Fair and Inclusive Planning System' within the NPF4 as adopted incorporates the UNCRC into its ambition.
• Policies on blue and green infrastructure, play, recreation and sport require an understanding of needs and assets and seek opportunities for enhancement. Policy 21 (Play, recreation and sport) of the NPF4 as adopted protects against loss of children's outdoor play provision and seeks to design-in new opportunities for play in the natural and built environment.
• A new policy on health and safety which aims to improve health and reduce health inequalities. The NPF4 as adopted has a specific Health and safety policy (Policy 23).

Fairer Scotland Duty Assessment

4.2.21 The updated evidence base, findings, and decision of the Fairer Scotland Duty Assessment can be found in full in Appendix A.

Island Communities Impact Assessment

4.2.22 A range of potential issues for islands communities relevant to the NPF4 were identified, along with recommendations for possible mitigation. The following paragraphs set out how these recommendations have been incorporated into the NPF4 as adopted.

4.2.23 Support for young people to remain, move or return to the islands: To reverse past depopulation, planning can help to sustain communities in more peripheral and fragile areas in a way that is compatible with the low carbon agenda and resilient to climate change impacts. Local liveability will benefit people as well as the planet. Island and coastal communities will need a bespoke approach to building networks of 20 minute neighbourhoods to further strengthen their long term resilience and self-reliance. Sustainable and fair access to affordable healthier food will support future resilience and broader objectives including reduced child poverty and improved health outcomes.

4.2.24 Policy 15 (Local Living and 20 minute neighbourhoods) of the NPF4 as adopted outlines an approach to 20 minute neighbourhoods within settlements which considers local context and settlement patterns, as well as reflecting the particular characteristics of each place. Policy 17 (Rural Homes) and Policy 29 (Rural Development) outline an approach to rural areas, which includes our island communities, that requires development to reflect the particular needs and characteristics of the area while ensuring natural and cultural assets are safeguarded and enhanced. Both policies as adopted also demonstrate flexibility towards our most remote places to ensure that development can help sustain and grow fragile communities.

4.2.25 Employment, training and higher education opportunities: Sea ports are a focus for investment in the blue economy and further diversification of activities could generate additional employment across the area. Potential for business development ranges from long-distance freight to supporting the cruise and marine leisure sectors and decommissioning opportunities. New infrastructure and repurposing of land will help to shift industrial activity towards supporting the offshore renewables sector.

4.2.26 Examples where opportunities are supported by the NPF4 as adopted include the National Development 'Energy Innovation Development on the Islands' which recognises a number of broad locations where diversification to renewable energy industries can support the potential of the Islands and the industries.

4.2.27 Access and affordability of transport: Communities will need resilient transport connectivity to maintain accessibility and lifeline links and further innovation will be required to help modernise connections and decarbonise transport systems. A net zero islands air network and decarbonisation of ferry services will help to secure the viability and service stability of island and remote coastal communities. An Islands Connectivity Plan will consider the role of ferries, fixed links and low carbon aviation in securing lifeline links and marine access for both leisure and freight.

4.2.28 The regional spatial priorities for the North and West Coast and Islands as set out in the NPF4 as adopted seek to ensure a more resilient future for island communities, including through decarbonising transport and reducing fuel poverty.

4.2.29 A variety of housing types, sizes and tenures to meet people's needs and a lack of affordable housing: Scotland's National Islands Plan aims to grow the population and economy, improve transport and housing, and ensure island communities are served by the facilities, jobs, education and services they need to flourish. Communities will needgreater choice and more flexible and affordable homes to support varying needs. This can be achieved to an extent by refurbishing the existing building stock to reduce the release of embedded carbon, as well as by delivering more affordable, energy efficient new homes. There is a clear need for affordable housing provision across the region to improve choice and access to homes, and in some areas to help offset the impact of second home ownership and short-term lets on the market.

4.2.30 The NPF4 as adopted supports the refurbishment of existing building stock and the delivery of energy efficient new homes through policies 16 (Quality homes) and 17 (Rural homes).

4.2.31 Speed and reliability of internet connections: Improved digital connectivity is a priority to sustain current businesses and create 'smart' communities. Investment in ultrafast broadband will ensure every property is connected and improve mobile coverage. This will unlock opportunities for rural businesses and remote working, and make future community growth more feasible. Full benefits will be realised by actively tackling the digital divide by building skills, literacy and learning and addressing the financial barriers to internet access. Key projects include the Outer Hebrides Giga Fibre Network and the North Isles Fibre Project.

4.2.32 National Development 12 'Digital Fibre Network' within the NPF4 as adopted supports the continued roll-out of world-class broadband, prioritising those areas with weaker networks as part of the Reaching 100% (R100) programme and Project Gigabit, including urban, island specific and rural enhancements.

4.2.33 Influence over decisions made by local and national government: A place based approach is at the heart of creating a more sustainable and fair Scotland. The planning system should apply the Place Principle which commits us to taking a collaborative place based approach to future development. This must involve working with stakeholders and local communities to create liveable, healthier and sustainable places that improve lives, builds economic prosperity and contribute to net zero and environmental ambitions. People living and working on islands are best placed to help decide how their communities can grow in a way that meets their needs and so it is essential they are involved in planning their future development.

4.2.34 The introduction of Local Place Plans (LPPs) should support island communities in developing their aspirations. LPPs must have due regard to NPF4 as well as Local Development Plans which cover a similar area.

4.2.35 Adequate infrastructure for the number of tourists attracted to the islands: Targeted investment in tourism infrastructure will ensure the coast and islands can capitalise on their rich natural assets, heritage and culture to support better quality and more stable jobs in the sector whilst providing a positive experience for visitors and residents. Planning can help to ensure that the Rural Tourism Infrastructure Fund is targeted at places where the pressure is most significant. Regionally and locally there is a need for smaller scale investment across the area and in other parts of Scotland to put in place low maintenance facilities which better support and manage the impact of informal tourism including camping, campervans and day trips.

The NPF4 as adopted supports development proposals for new or extended tourist facilities or accommodation, including caravan and camping sites, in locations identified in the Local Development Plan (LDP) (Policy 30). The same policy also ensures compatibility with the surrounding area in terms of the nature and scale of the activity and that impacts, e.g. from increased visitor numbers, are taken into account.

4.3. Business and Regulatory Impact Assessment

Assessment Findings

4.3.1 The proposals set out in the draft NPF4 were considered necessary to ensure that the planning system more effectively contributes to key societal challenges, including the climate emergency and nature crisis. These priorities represent an update from previous policies and, in places, are a significant shift from previous practice. It was identified that NPF4 was likely to impact on all business sectors across Scotland, particularly those who engage with the planning system through the submission of planning applications. The initial high-level assessment suggested the following effects on business were likely:

• The national spatial strategy sets out a high level vision of how Scotland should develop to 2045. The impact of the strategy on individual businesses is likely to arise through the identification of national developments and development management policies that are being put in place to support the spatial strategy;
• national development status will give greater certainty to developers because it establishes the need for the development, although additional costs may be associated with progressing proposals through the planning system;
• 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;
• some changes to development management policies will impact on businesses (both positively and negatively).

4.3.2 It was considered that national planning policies which will apply across Scotland should also free up resources for local authorities to bring forward local development plans that primarily focus on the spatial issues that are specific to their areas. However, some respondents to the partial BRIA expressed doubt that cost savings will outweigh need in local authorities for resource and skills to deal with new work areas

Assessment Recommendations

4.3.3 It was noted that work being taken forward by the High Level Group on Planning Performance^[26] will be central to informing a cross sectoral approach to skills and resourcing following the adoption of NPF4. The delivery programme published alongside the NPF4 as adopted aims to secure a cross-government approach to the delivery of NPF4. Along with other key stakeholders including Partners in Planning^[27] we will develop a skills strategy which will identify the specialist skills required to address the requirements of National Planning Framework 4, and the wider skills required to ensure we have planners with the expertise to deliver on our ambitions for Scotland.

4.3.4 The final BRIA considered that overall, costs are outweighed by the strong justification for proceeding with the intended approach, in particular the contributions to national outcomes.