National Planning Framework 4: integrated impact assessment post adoption statement

6. Reasons for selecting National Planning Framework 4 as adopted

6.1.1 The 2005 Act requires that the Scottish Government identifies, describes and evaluates the likely significant effects on the environment of any reasonable alternatives to the draft NPF4, taking into account its objectives and geographical scope. The extent to which alternatives could be considered reasonable was influenced by the relevant legislative requirements and takes into account existing policies and actions, the content of which has been set out elsewhere in other plans, programmes and strategies.

6.1.2 Preparation of NPF4 was part of a wider and ongoing programme of planning reform informed by an independent review of the planning system. It sits within the legislative framework set by the Town and Country Planning (Scotland) Act 1997, as revised and updated by the Planning (Scotland) Act 2019, which introduced new statutory provisions on the content and outcomes for the NPF. At the same time, there was a need to update NPF3 and Scottish Planning Policy to give fuller regional coverage and improve alignment with wider programmes and strategies, including on infrastructure and economic investment and responding to the twin global emergencies on climate and nature. 'Do nothing' was therefore not considered to be a reasonable option.

6.1.3 Throughout the environmental assessment of the three main components of the draft NPF4 consideration was given to potential alternative options and approaches:

• Spatial strategy: In advance of the new duty to produce Regional Spatial Strategies (RSS), the draft NPF4 spatial strategy was developed in collaboration with a range of partners and wider stakeholder interests, to develop thinking across regional and national spatial scales. No reasonable alternatives were identified.
• National developments: 35 alternative national developments were assessed for their potential environmental effects. This was an iterative process, with the assessment findings feeding into the final decision of what was to be a proposed National Development.
• Planning Policy: NPF4 should be taken as a whole, and all relevant policies should be applied to individual planning applications. Nevertheless, as part of the iterative drafting process, consideration was given as to whether any reasonable alternatives to policies might arise.

6.1.4 Ultimately the selection of the final suite of national developments was informed by the detailed analysis of proposals against published criteria, including environmental considerations such as climate change and impacts on natural and cultural heritage. In addition, the selected national developments were considered to be the best available means of implementing the wider aims of the spatial strategy. The SEA and HRA, and the associated consultation, provided a means of testing these proposals, to ensure that none of the national developments would result in significant adverse effects that could not be mitigated to an acceptable level.

6.1.5 As previously mentioned, the HRA brought about late modifications to two of the National Developments. This was in relation to:

• The development of a deep water port in Scapa Flow, initially proposed under Energy Innovation Development on the Islands; and
• any project brought forward under Dundee Waterfront which involved land reclamation.

6.1.6 For these two classes of development under Energy Innovation Development on the Islands (Originally Islands Hub for Net Zero) and Dundee Waterfront, on the basis of information available, it was not possible for the appropriate assessment to conclude that relevant projects could be progressed without adversely affecting several European sites situated around Orkney and in the Firth of Tay, respectively. These classes of development were therefore removed from their associated National Developments in the Revised Draft NPF4.

6.1.7 The society and equality assessments also supported the development of NPF4 as adopted. The Scottish Government has considered and embedded the three elements of the Public Sector Equality Duty: to 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. The EQIA in particular has helped highlight potential issues which may impact disproportionately on those with particular protected characteristics. The EQIA makes reference to how NPF4 supports proposals for newhomes that improve affordability and choice, including 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). Further local living and 20 minute neighbourhood guidance will also reflect the 7 'calls to action' as outlined in the 'Exploring Scotland's 20-minute neighbourhoods' event report^[37].

6.1.8 In the final BRIA, the Scottish Government's preferred option was compared to an alternative non-regulatory approach. It was found that any alternative strategy used to deliver national policies would not have the same status and influence as NPF4 and would likely need to be brought forward in a piecemeal way as the Scottish Government seeks to ensure that the planning system is changed to deliver wider policy priorities. This could result in a confusing and weakened landscape for planning decisions which would affect the whole sector.