Scotland 2045: fourth National Planning Framework - draft: integrated impact assessment - environmental report

2.0 Assessment Approach

2.1 What is Integrated Impact Assessment?

2.1.1 A range of statutory and non-statutory assessments have informed the preparation of the draft NPF4 and we have integrated these assessment requirements, wherever possible, into the NPF4 preparation process. We have also co-ordinated the preparation of the evidence base across the individual assessments to minimise duplication, sharing information and links between the different assessment topics and making connections. In light of the statutory and non-statutory reporting requirements for individual impact assessments, clear findings are reported for each of the assessments individually. We are also publishing a IIA Non-Technical Summary which draws together and further considers these findings in a holistic way.

2.1.2 This report sets out the findings of the Strategic Environmental Assessment (SEA) of the draft NPF4, and is one of the statutory environmental 'themed' assessments which Scottish Ministers are required to undertake. Additionally, this report also sets out the findings of consideration given to the likely health effects of the proposed national developments.

Assessing the Likely Health Effects of Proposed National Developments

2.1.3 The Planning (Scotland) Act 2019 requires Scottish Ministers to bring forward new provisions on the assessment of the likely health effects of national or major developments. To help inform this work, the likely health effects of proposed national developments have been considered as part of the SEA process. This work has been informed in part by Public Health Scotland's NPF4: Briefing on Health and Proposed National Developments^[5]. In addition to considering the national development proposals specifically, we have also sought to draw out the likely health impacts of the NPF4 as a whole, where possible, through the SEA topic of 'population and human health', and taking into account emerging findings from relevant aspects of the Equalities Impact Assessment, which also accompanies the consultation draft NPF4.

Habitats Regulations Appraisal

2.1.4 The Scottish Government commissioned independent consultants AECOM to undertake a Habitats Regulations Appraisal (HRA) of NPF4, and the findings of the initial HRA screening report^[6] have helped to guide and inform the SEA where relevant. An Appropriate Assessment will be completed before the NPF4 is finalised.

Life-Cycle Greenhouse Gas Emissions of National Developments

2.1.5 The Planning (Scotland) Act 2019 requires the Scottish Government to undertake an assessment of the likely impact of each proposed national development's lifecycle greenhouse gas emissions on achieving national greenhouse gas emissions reduction targets. We have commissioned independent consultants LUC to undertake this assessment and the findings^[7] have also been taken into account in the SEA of the proposed national developments where relevant.

2.2 What is Strategic Environmental Assessment?

2.2.1 SEA is a systematic method for considering the likely environmental effects of certain Plans, Programmes or Strategies. SEA aims to better protect the environment, ensure any development is sustainable and increase opportunities for public participation in decision making.

2.2.2 The Environmental Assessment (Scotland) Act 2005 ('the 2005 Act') requires all qualifying policies, plans, programmes and strategies (referred to generally as 'plans') to undergo SEA. The 2005 Act ensures that the environmental effects of public plans that fall within its scope are properly assessed and the findings set out in an Environmental Report. The Environmental Report and the plan to which it relates must then be open for public consultation.

2.2.3 NPF4 is considered to be a qualifying plan under Section 5(3) of the 2005 Act and this Environmental Report has been prepared in accordance with the Act. The NPF4 SEA process includes the following distinct stages:

• Scoping – establishing significant environmental topics, setting the environmental baseline, developing the proposed method(s) and intended approach to the assessment and setting out the intended consultation period;
• Environmental Assessment – assessing the likely significant environmental effects of the proposed plan and any reasonable alternatives, and consulting on both the draft plan and Environmental Report;
• Post Adoption Statement – sets out how the assessment and the consultation results have been taken into account in the finalised plan: and
• Monitoring – monitoring the significant environmental effects of the implementation of the plan and identifying any unforeseen adverse effects at an early stage in order to undertake appropriate remedial action.

2.3 Structure of the Environmental Report

2.3.1 This Environmental Report includes the following information:

• Section 1 introduces NPF4 and sets out its relationship to other plans, programmes and strategies
• Section 2 details the approach to the assessment
• Section 3 describes the current baseline environmental conditions and environmental protection objectives
• Section 4 presents the assessment findings of the spatial strategy and proposed national developments
• Section 5 presents the assessment findings of the draft national planning policy
• Section 6 describes the overall cumulative effects of the draft NPF4
• Section 7 outlines the mitigation identified and proposals for monitoring
• Section 8 sets out the next stages in the preparation of the NPF4 and the environmental assessment process, and on the consultation process.

2.4 SEA Activities to Date

2.4.1 Our Integrated Impact Assessment (IIA) Scoping Report^[8] set out our early thinking on the assessment method(s) and on the baseline information to inform the assessment, and invited comments as part of the early 'call for ideas' on NPF4 in January to April 2020. To further support the policy process we published our NPF4: Update on Integrated Impact Assessment^[9] alongside the NPF4 Position Statement^[10] in November 2020. Comments received from the SEA consultation authorities^[11] (SEPA, NatureScot and HES), from Public Health Scotland, and from the early engagement process more generally have helped to inform the overall approach to the IIA as well as the SEA specifically.

2.4.2 A follow up meeting with the SEA consultation authorities and with Public Health Scotland took place on 16^th December 2020, which helped to further shape the overall assessment approach and refine the environmental baseline.

Scoping the Environmental Topics

2.4.3 The IIA Screening/Scoping Report considered that all environmental topics should be scoped into the assessment due to the nature and scale of NPF4 and the potential for likely significant effects to occur across all topics. This Environmental Report therefore considers the following environmental topics, and their inter-relationships:

• Biodiversity, Flora and Fauna
• Population and Human Health
• Climatic Factors
• Air
• Water
• Soil
• Cultural Heritage and Historic Environment
• Landscape and Geodiversity
• Material Assets

2.5 Assessment Methodology

2.5.1 The draft NPF4 includes the following components, which form the focus of this assessment:

• Spatial Strategy; an overarching spatial strategy for Scotland in the future. This will guide the preparation of regional spatial strategies, local development plans, and local place plans and will also be relevant to wider policies and strategies relating to land use.
• National Developments; setting out proposed national developments to support the spatial strategy.
• National Planning Policy Handbook; setting out policies for the development and use of land which are to be applied in the preparation of local development plans; local place plans; masterplans and briefs; and for determining the range of planning consents.

2.5.2 The Planning (Scotland) Act 2019 also requires the National Planning Framework to include 'targets for the use of land in different areas of Scotland for housing'. Draft targets are included in Annex B of the draft NPF4 and these are considered alongside the assessment of the draft planning policies.

2.5.3 Finally, part 4 of the draft NPF4 sets out an intended high-level approach to delivering the finalised strategy, to be further developed into a standalone, live delivery programme once NPF4 has been finalised. This is not a focus of the assessment though the intended approach to delivery has been taken into account where relevant in the overall assessment.

2.5.4 This SEA has been undertaken by the Scottish Government's Environmental Assessment Team, working closely with officials in the NPF4 drafting team. As part of our wider Integrated Impact Assessment process, we have sought to integrate the SEA assessment requirements wherever possible, into the NPF4 preparation process, to inform and influence NPF4 development and maximise the effectiveness of the SEA within the NPF4 preparation process. In keeping with the broad and strategic nature of the draft NPF4, it is a strategic level assessment which draws on a range of methods to identify potentially significant environmental effects.

Stage 1 - Evidence Gathering and Setting Objectives

2.5.5 A series of SEA objectives (see Table 2.1) were developed to assist in predicting and evaluating the potential effects of the NPF4 on the environment, informed by the likely scope and content of the plan and its policy context; relevant environmental protection objectives; and the environmental baseline. The draft objectives were established during scoping and refined through the subsequent SEA process, including in consultation with the SEA consultation authorities. These objectives form the basis of the assessment of the national planning policies, which is presented in tables using a scoring system (see Table 2.2 below). The objectives have also helped to inform and guide the assessment of the spatial strategy and proposed national developments, which are presented in narrative form.

2.5.6 The assessment has also drawn on previously undertaken SEAs where relevant, including of NPF3 and Scottish Planning Policy; the Infrastructure Investment Plan 2021 – 2025-26; and the Review of the Scottish Planning System – Planning Bill.

Stage 2 – Iterative Assessment

2.5.7 Iterative assessment of the emerging draft spatial strategy, and draft national planning policies, took place in tandem.

2.5.8 At the same time, early consideration of suggested national developments, alongside the Habitats Regulations Appraisal screening process and consideration of equalities impacts, helped to inform and guide the selection of proposed national developments. Figure 2.1 illustrates the approach to selecting the proposed national developments.

Stage 3 – Cumulative Assessment

2.5.9 The third stage of assessment explored the potential for cumulative and in-combination effects of the draft NPF4, and draws together the findings from stage 2.

Table 2.1 SEA Objectives

Topic : SEA objectives

Biodiversity, Flora and Fauna

• Avoid adverse impacts to designated habitats and species
• Avoid adverse impacts to undesignated habitats and species
• Protect, maintain and enhance biodiversity

Climatic Factors

• Avoid new Greenhouse Gas (GHG) emissions
• Reduce GHG emissions in order to meet Scotland's emissions reduction target of net zero by 2045
• Promote and enable adaptation to climate change

Air

• Avoid adverse impacts to air quality
• Reduce emissions of key pollutants and improve air quality throughout Scotland
• Reduce levels of nuisance e.g. noise, vibration, dust, odour and light

Water

• Avoid adverse impacts on the ecological status of water bodies
• Ensure the sustainable use of water resources
• Reduce the number of people and properties at risk of flooding and promote adaptive flood risk management
• Protect, maintain and improve the ecological status and physical state of the water environment

Soil

• Safeguard and improve soil health, protect soil resource and soil functions of all soil types in Scotland
• Safeguard and improve high value agricultural land and carbon-rich soils
• Reduce the extent of contaminated and vacant and derelict land

Cultural Heritage and Historic Environment

• Avoid adverse impacts on the historic environment including its setting
• Protect and enhance valued landscapes, historic and archaeological sites and other culturally and historically important features, landscapes and their settings

Landscape and Geodiversity

• Avoid adverse effects on landscapes and geodiversity
• Safeguard and enhance the character and diversity of the Scottish landscape and areas of valuable landscape and geodiversity

Material Assets

• Avoid adversely impacting on material assets (e.g. water, heat, energy and flood protection infrastructure etc)
• Promote the principles of circular economy
• Reduce use and promote sustainable management of natural and built environment resources
• Promote the sustainable design, use and management of new and existing assets/infrastructure to support the development of high-quality places

Population and human health

• Reduce the health gap and inequalities and improve healthy life expectancy
• Promote and enhance/improve access to open space, greenspace and the wider countryside
• To protect and improve human health and wellbeing through improving the quality of the living environment of people and communities
• Increase sustainable access to essential services, employment and the natural and historic environment

2.6 Assessing Significance

2.6.1 The 2005 Act requires the Environmental Report to set out the likely significant environmental effects expected from the proposed plan.

2.6.2 As may be the case with many strategic level assessments, significance can be difficult to define, requiring the application of professional judgement and experience. To achieve a consistent approach, the following criteria have been used as a broad guide to evaluate the significance of both positive and negative effects:

• Effects on nationally or internationally protected environmental features.
• Effects of greater than regional scale (though consideration has been given to the potential for localised and regional effects where relevant and applicable).
• Effects that could impact on delivery of national policies, targets or commitments.
• Effects that exacerbate or address existing, national and international environmental problems or issues, as identified in the baseline analysis.

2.6.3 Additionally, the Environmental Report notes more minor effects arising where these are identified, but aims to focus particularly on effects that are considered to be significant when considered in relation to the above criteria.

2.6.4 The scoring system in Table 2.2 is used in the detailed policy assessment tables. Where findings are presented in narrative form, the same terminology has also been used.

Table 2.2 Assessment Key

✓ - Positive Effect

X - Negative Effect

0 - Negligible Effect

X✓ - Mixed Effect

✓✓ - Positive Effect (Significant)

XX - Negative Effect (Significant)

? - Uncertain

2.7 Consideration of Reasonable Alternatives

2.7.1 The 2005 Act requires the Environmental Report to identify and assess any reasonable alternatives to the plan or programme, taking into account its objectives and geographical scope.

2.7.2 The NPF is a spatial plan for Scotland setting out Scottish Ministers' policies and proposals for the development and use of land. As such, the draft NPF4 sets out a vision for how Scotland's places will change in the future and reflects priorities across Scottish Government portfolios, bringing together a wide range of plans, programmes and policies. The draft NPF4 has been prepared in accordance with the Town and Country Planning (Scotland) Act 1997, as amended, which specifies certain matters to be addressed and sets out the statutory outcomes for the NPF. Its preparation has been informed by an iterative process of extensive stakeholder engagement as part of the NPF review process.

2.7.3 Do nothing: Preparation of NPF4 is part of a wider and ongoing programme of planning reform^[12] 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 is a need to update the current 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' is therefore not considered to be an option.

2.7.4 Alternative focus: As discussed in section 1 above, the draft NPF4 sets out the Scottish Government's vision for how planning and development will deliver a net zero, sustainable Scotland by 2045. It sets out how each part of Scotland can be planned and developed to create: sustainable places; liveable places; productive places; and distinctive places. Annex A of the draft NPF4 sets out how development will contribute to each of the statutory outcomes identified in The Planning (Scotland) Act 2019. In light of this statutory and wider policy framework, we do not consider that a fundamental change in focus can be viewed as a 'reasonable alternative'.

2.7.5 In assessing the draft spatial strategy, proposed national developments, and National Planning Policy Handbook components of the draft NPF4 we have however given consideration to any alternative options or approaches. Views are also invited on this aspect of the SEA through the consultation process:

• 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 have been identified.
• National developments: Appendix E sets out the assessment of alternative national developments.
• Policy handbook: This part 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, we have given consideration as to whether any reasonable alternatives to policies may arise and where these have been identified they are discussed further in Appendix C of this report.

2.8 Difficulties and Limitations Encountered

2.8.1 The 2005 Act requires those undertaking SEA to identify any difficulties encountered during the assessment process. Whilst no issues have hindered the assessment of draft NPF4, it is important to recognise that this is a strategic level assessment of a national level framework and so the findings are necessarily broad-brush.

2.8.2 It is acknowledged that many of the specific environmental effects arising from NPF4 will depend on the context within which policy is applied. Local Development Plans prepared by individual planning authorities will themselves be subject to SEA, and where individual development proposals are likely to have significant environmental effects, these will be subject to relevant Environmental Impact Assessment (EIA) legislation. This is a natural feature of a strategic level assessment, and does not undermine the benefits of undertaking SEA at this level. Any uncertainties or likely dependencies have been identified and taken into account throughout the assessment process.

2.8.3 As 2020 was atypical in terms of many environmental trends due to the Covid-19 pandemic, this year may be considered an anomaly. This has been discussed, where relevant within the environmental baseline.