Fourth National Planning Framework - position statement: consultation analysis

Integrated Impact Assessment Update Report

The Update Report detailed progress since the Screening/Scoping Report that was produced in 2020 to inform the early engagement and Call for Ideas stages of the NPF4 preparation process. The Habitats Regulations Appraisal of NPF4 – Baseline Information Report was also made available as an Appendix.

Question 6: Do you have any comments on the Integrated Impact Assessment Update Report, published alongside this position statement?

There were relatively few comments on the Update Report, albeit a number of respondents expressed broad support. This including welcoming engagement with Public Health Scotland to inform the assessments.

Other comments and queries included that:

• More detail about the impact assessment process would be welcome, including whether assessments will be based on national or regional data. It was suggested that national-level data could miss or conceal local issues and that regional and locally granular data be used as far as possible.
• Flexibility will be needed, as technologies and needs will change quickly; a 'change mechanism' would be appropriate.
• Health effects must be examined. Public health considerations should be embedded into the plan making process and emerging data on the COVID-19 pandemic should be taken into account.
• It would be useful to confirm whether: assessment of developments that have a relevance to the historic environment will occur under Strategic Environmental Assessment; and how impacts from the policy requirement for preparation of Heritage Impact Assessments have been considered.
• The thinking being developed on how the supply of new homes affects the achievement of inclusive growth was queried and, in particular, how supply of deliverable housing land and new homes impacts on housing affordability.
• A National Development's lifecycle greenhouse gas emissions and reductions targets should be considered alongside the impact to the natural environment and other aspirations set out within the Position Statement.