Fourth National Planning Framework - position statement: consultation analysis

Other comments

Question 7: Do you have any other comments on the content of the Position Statement?

Around 130 respondents provided a comment at Question 7, with many summarising their position overall or highlighting topics or concerns that have been covered elsewhere in this report. The analysis presented below only presents issues not covered elsewhere within the report.

Actions requested as a result of delays to NPF4

It was argued that the urgency of the climate emergency, the delay to NPF4 and the required increase in renewable energy generation capacity would justify interim policy guidance on renewable energy developments. It was proposed that:

• There should be immediate guidance on the planning balance being tilted in favour of the climate emergency, which should be a material consideration in all planning decisions or should be given significant weighting or "special regard".
• There should be an urgent review of the current consenting process to address constraints.

It was also suggested that:

• Further guidance and understanding of the emerging NPF4 would be welcome. A local authority respondent noted their own second LDP (LDP2) would now be due for publication only weeks after the delayed draft NPF4.
• Clarity is needed as to how the any disparities between the second round of LDPs and the draft NPF4 will be dealt with by the Reporter.
• Until SPP comes into force, some flexibility will be required around change of use and assistance in reaching decisions based on priorities.

A further request for urgent action was that SPP should be updated to give absolute protection to ancient woodlands and hedges, and for there to be a requirement that ecological reports are carried out at a time of year when species are most readily identifiable.

National Developments

Proposals for National Developments were invited at the Call for Ideas stage of engagement on NPF4. Information on the proposals received can be found on the Transforming Planning mapping platform. The Position Statement notes that the Scottish Government will consider whether proposed national developments can help to deliver on the vision of each of the key outcomes, but there is no further discussion of the selection process (other than in relation to timetable issues noted in the Update Report).

Nevertheless, some respondents referenced national developments in their response including by:

• Seeking national development status for a project.
• Providing updates on projects they had already proposed.
• Commenting on individual projects presented on the Transform Planning website.

There were also requests for further information on the process to be followed in selection and adoption of National Developments in NPF4. Comments included that:

• The assessment criteria should be transparent and robust.
• The assessment process should consider adverse impacts on biodiversity, and on local communities - for example in relation to noise.
• Comments from affected communities should be included in the assessment process.
• Early publication of candidate National Developments should be followed by consultation.

In addition, it was suggested that NPF4 should be clear that National Development status does not circumvent the need for planning permission or obligation to comply with the Habitats Regulations, or other legal requirements.

There were also concerns over possible lack of flexibility to respond to new priorities or technologies going forward.

Other issues

Other issued raised and not covered elsewhere in the report included:

• Defining sustainability: It was noted that the Position Statement refers to travel, tourism, rural living and locations as 'sustainable' but does not define what this means. Adding a definition of sustainable development and its agreed principles to NPF4 was proposed.
• Explaining the hierarchy of legislation: An organogram was suggested in order to provide a visual guide to the hierarchy of policies and actions that a community council might need to understand.
• Protecting dark skies: The importance of protecting dark sky areas was highlighted and it was suggested a national policy would help to protect existing un-polluted areas and reduce the existing light pollution elsewhere, thereby reducing energy consumption and delivering on the wider net-zero agenda. It was suggested to be important to extend the principle of protecting dark sky areas beyond the "dark skies parks" mentioned in NPF3.
• Aviation safety: It was argued to be important that aviation safety is given due consideration in relation to wind farm re-powering applications, with continued engagement between aviation and renewables stakeholders and consenting authorities. It was also suggested that night-time aviation lighting should not be a reason to object to wind farm development, unless in a designated dark sky area.
• Green ports: Plans for green ports were noted, with several respondents highlighting potential candidates. It was suggested green ports are an important and complementary initiative relevant to NPF4.
• World Heritage Site application for the Flow Country: It was suggested that proposals for onshore wind development might have an impact on the application for World Heritage status for the Flow Country, and that those responsible for NPF4 and for the Flow Country proposal should meet to resolve priorities going forward.