Infrastructure investment plan 2021-2022 to 2025-2026 - draft: consultation analysis

Independent analysis of consultation responses to the Scottish Government's Draft Infrastructure Investment Plan 2021-22 to 2025-26. The consultation ran from 24 September 2020 to 19 November 2020.

3. The Inclusion of Natural Infrastructure


3.1 The Scottish Government proposes to revise its infrastructure definition to include references to natural infrastructure to reflect the role it plays in: a) the infrastructure system and the benefit it generates to the economy and society; and b) tackling climate change and other challenges e.g. biodiversity loss. This would help ensure investment in natural infrastructure can be considered and prioritised equally and on a consistent basis, alongside other areas. The Scottish Government proposes the following changes (highlighted as bold):

"The physical and technical facilities, natural and other fundamental systems necessary for the economy to function and to enable, sustain or enhance societal living conditions. These include the networks, connections and storage relating to the enabling infrastructure of transport, energy, water, telecoms, digital and internet, to permit the ready movement of people, goods and services. They include the built environment of housing; public infrastructure such as education, health, justice and cultural facilities; safety enhancement such as waste management or flood prevention; natural assets and networks; and public services such as emergency services and resilience."

Question 1a

3.2 There is almost unanimous support for the inclusion of natural infrastructure in the proposed definition of infrastructure. The vast majority of consultation respondents, both individuals and organisations, expressed support (76, 95%), Table 5.

Table 5: Do you support the inclusion of natural infrastructure in our definition of infrastructure?
Yes No Unsure
Number % Number % Number %
Individual 12 15% 0 0% 2 3%
Organisation 64 80% 0 0% 2 3%
Construction and Built Environment 12 92% 0 0% 1 8%
Natural Environment and Climate Change 12 100% 0 0% 0 0%
Travel and Transport 10 100% 0 0% 0 0%
Local Government 12 92% 0 0% 1 8%
Energy, Telecoms, Water and Waste 5 100% 0 0% 0 0%
Business and Enterprise 5 100% 0 0% 0 0%
Health, Education and Public Services 3 100% 0 0% 0 0%
Other 5 100% 0 0% 0 0%
Total 76 95% 0 0% 4 5%

N=80. Percentages do not add up to 100 due to rounding.

3.3 Question 1c of the Consultation Document asked the question:

"If you do not agree (with Question 1a and/or Question 1b) please provide your suggested changes and additional material to support your answers".

3.4 While a majority of consultation respondents expressed agreement with the closed questions, many went onto provide qualitative feedback. Where this is the case, for ease of reporting, we have categorised and reported responses in terms of whether they specifically relate to:

  • Question 1a (support for inclusion of natural infrastructure in the definition of infrastructure); and/or
  • Question 1b (wording proposed for revised definition), see Section 3.12.

3.5 As noted at Table 5, the vast majority of respondents are supportive of the proposed inclusion of natural infrastructure in the definition of infrastructure for the Draft IIP.

3.6 A common theme from the qualitative feedback relating to Question 1a is acknowledgement that the proposed change to the definition is "welcomed" or "helpful". Related points are that it "aligns" to the consultation response submitted to the initial Call for Evidence to inform the Infrastructure Commission for Scotland's work, or that the shift in the definition towards an "integrated" or "holistic approach" to consideration of natural and economic infrastructure investment could help unlock and "maximise benefits" and impacts.

3.7 There is broad agreement that the proposed definition helps to reinforce the important role and contribution that natural infrastructure plays. Common points raised are reflected below:

  • There is a firm belief that natural infrastructure is an "integral part" of the social, economic and environmental fabric of society, and that it touches on all aspects of our day-to-day lives (e.g. feelings of health and well-being, societal living conditions, transportation and accessibility, climate change, air quality).
  • Natural infrastructure is considered to play an "invaluable role" in society e.g. enabling healthy ecosystem services which support resilience (flood management schemes) and deliver goods (food and timber).
  • There are also considered to be "important synergies" which natural infrastructure can help to realise alongside other infrastructure sectors (e.g. active travel).
  • There is further recognition of the important role that the natural environment and investment in nature-based solutions can play in supporting community and economic resilience and recovery as we come out the other side of the current pandemic - "green recovery post COVID-19" – as well as its important contribution to tackling the challenges of climate change and biodiversity loss.
  • There is some feedback that the change in definition could help to encourage, support and embed changes in "behaviour and attitudes" that the Scottish Government seeks to bring about through ensuring investment in natural infrastructure is considered and prioritised equally and on a consistent basis, alongside other areas.

3.8 Another common theme is that the proposal to revise the infrastructure definition to include references to natural infrastructure gives natural infrastructure the recognition it deserves "as an asset class in its own right". Here, it is noted that its inclusion within a revised infrastructure definition could help: address the issue of natural infrastructure often being "under-valued" in terms of its contribution towards inclusive economic growth and generating economic value (and the wider value and impact it brings); and "level the playing field in terms of access to investment for nature based solutions". It is further noted that in doing so, this could "make greater use of natural assets, reduce the need for more physical built environment, and help support the enhanced management of the natural environment".

3.9 A small proportion of consultation respondents are "unsure" regarding the proposal to include natural infrastructure in the definition of infrastructure (four, 5%), Table 5. This includes two individual respondents and two organisations (Construction and Built Environment and Local Government). There is limited qualitative feedback, except for a request that the Draft IIP includes a clearer definition of natural infrastructure and additional examples (i.e. what does it include, what does it not include).

3.10 A few consultation respondents who noted agreement with the proposal to revise the definition of infrastructure, go on to specify aspects which they feel could be clarified, improved and/or strengthened, as noted below:

  • The Draft IIP could benefit from including a more detailed explanation of the intended benefits or consequences of widening the definition to include natural infrastructure.
  • The Draft IIP could include additional examples and illustrations of natural infrastructure investment (e.g. examples of natural assets or networks), and the benefits and impacts it helps to derive). This relates to the point outlined above regarding a request for additional guidance to be provided on what is in and out of scope.
  • The Draft IIP could be more explicit in terms of recognising the wider role, value and impact of investment in natural infrastructure. Specific points mentioned include: health and well-being, blue and green infrastructure, cultural value, the historic environment.
  • While the holistic definition and approach is welcomed, a point raised is that it would be important not to "dilute the investment required for such a wide range of services and networks" and that it "does not detract from the overall impact and impetus to support an "infrastructure first" approach". Aligned to this, is acknowledgement of the inherent challenges of "balancing competing demands" when making decisions on infrastructure investment, and that decisions should not reduce the quality of natural assets.
  • A further point is that careful consideration would be required if natural infrastructure is to be included in the "definition of 'infrastructure' used in a wider context" to ensure that unintended consequences are not created, including the potential for overlaps between funding sources.
  • There is recognition that there is currently no comparative methods for measuring the economic or financial benefit or impact of natural infrastructure projects, and that there would be inherent challenges in comparing like-for-like when there are no standardised metrics and methods. This point is reflected in the respondent quote below.

"We recognise there is direct and indirect value attributable to services performed by 'natural infrastructure' in terms of environmental processes that cannot be performed by 'man-made' hard infrastructure. We welcome this inclusion albeit we would suggest that for public understanding the Scottish Government should develop advice and a framework for quantitative comparison that shows how environmental services can be monetised. This will help overcome a certain sigma that presumes only hard infrastructure is dependable in the long term".

The Wheatley Group

Question 1b

3.11 A majority of consultation respondents agree with the wording proposed for the revised definition of infrastructure within the Draft IIP (48, 62%), Table 6. Organisations are slightly more likely to answer "Yes" than individuals (56% and 46% respectively), albeit this varies at an organisation sub-group level. A relatively large proportion of consultation respondents either did not agree with the proposed wording or are unsure (29, 38%).

Table 6: Do you agree with the wording proposed for the revised definition?
Yes No Unsure
Number % Number % Number %
Individual 6 8% 3 4% 4 5%
Organisation 42 55% 13 17% 9 12%
Construction and Built Environment 7 54% 3 23% 3 23%
Natural Environment and Climate Change 8 73% 3 27% 0 0%
Travel and Transport 6 60% 3 30% 1 10%
Local Government 10 77% 1 8% 2 15%
Energy, Telecoms, Water and Waste 3 60% 1 20% 1 20%
Business and Enterprise 3 60% 0 0% 2 40%
Health, Education and Public Services 1 50% 1 50% 0 0%
Other 4 80% 1 20% 0 0%
Total 48 62% 16 21% 13 17%

N=77. Percentages do not add up to 100 due to rounding.

3.12 While responses to Question 1b are mixed (albeit a majority agree), it generated a largely consistent set of qualitative responses, regardless of how the consultation respondent answered the closed question.

3.13 Our analysis confirms that there is universal agreement with the definition in broad terms. However, consultation respondents in the main either provide suggestions for:

How the definition could be further clarified, improved or strengthened.

Wording or phrasing changes (to varying degrees of change).

3.14 The consultation analysis report has concentrated on identifying common themes relating to Point 1 above. The Infrastructure and Investment Division will review all of the suggested definition wording and phrasing changes separately as it looks to refine, revise and finalise the IIP.

3.15 There are many comments that seek additional guidance and greater clarification (or less ambiguity) around the proposed definition, and more specifically on terminology.

3.16 A common theme across the consultation responses is that the Draft IIP could define more clearly what is meant by the various terms used in its proposed definition of infrastructure. This includes terms such as "natural", "natural assets", "networks", "cultural facilities", "resilience", as well as setting out more clearly what is in and out of scope. A wider suggestion is that the provision of "sub-definitions for all of the infrastructure components" could be helpful for the reader.

3.17 Common feedback is that natural infrastructure could be better described, illustrated and understood (in the proposed definition of infrastructure as well as in the Draft IIP more generally), including the multiple benefits that arise from natural infrastructure and assets. For example, there is most reference to including more on green and blue infrastructure and natural assets, as well as to ecosystem services and health and wellbeing/human wellbeing benefits.

3.18 Among respondents who do not agree with the definition (or who are unsure), there is some acknowledgement and support for the "broad", "wide-ranging" or "comprehensive" definition of infrastructure presented in the Draft IIP. There is also feedback that it supports and is "consistent with the intentions of the next National Planning Framework (NPF4)". There are a handful of comments that raise points of note and/or concern with the proposed definition. These can be summarised as follows:

  • The Royal Town Planning Institute (RTPI) Scotland notes that the definition goes beyond most of the "normal" definitions of infrastructure which tend to be dominated by physical infrastructure provision (e.g. water, drainage and utility services). It notes that housing is not traditionally seen as "infrastructure" although a key component of social and local community infrastructure. Concern is raised that "housing may dictate investment strategies and investment plans to the detriment of other conventional infrastructure types", and asks for this issue to be addressed within the Draft IIP.
  • South of Scotland Enterprise note that it is important that the definition within the Draft IIP is consistent with that used elsewhere to better understand "potential opportunities around nature-based solutions". Specific reference is made to the work of the Scottish Forum on Natural Capital and work to develop the well-being economy monitor. It notes that a consistent definition would be valuable to better understand the potential opportunities around nature-based solutions.
  • NatureScot proposed wording changes (additions) to better illustrate natural assets alongside traditional infrastructure.

"These include the networks connections and storage relating to the enabling infrastructure of transport, energy, water, habitats, telecoms, digital and internet, to permit the ready movement of people, goods and services….They include the built environment of housing; public infrastructure such as education, health justice and cultural facilities; natural assets and networks that supply ecosystem services; safety enhancement such as waste management or flood prevention; and public services such as emergency and resilience".

  • Campaign Response 1 and 2 raise similar points. Firstly, that aspects of the International Institute for Sustainable Development (IISD) definition of national infrastructure have been omitted within the Draft IIP proposed definition, and suggest it be adopted in full. There is specific reference within Campaign Response 1 for the definition to include "and then intentionally managed to provide multiple benefits for the environment and human wellbeing". Both suggest (albeit in slightly different terms) that the Scottish Government should "adopt a stronger position in protecting the natural infrastructure and a commitment that infrastructure projects are assessed on the basis of do not harm to the environment, sense of place or human wellbeing". Campaign 1 notes that there is not a "sufficiently ecosystem services-based approach" and that natural capital and ecosystem services approaches are well-recognised models for sound, informed and proportionate decision making and important for sustainable development" – and should be "fully adopted by Scottish Government as the basis for the new common approach".



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