NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.

Mineral extraction

Proposed key objectives of NPF4: To safeguard workable resources and ensure that an adequate and steady supply of aggregates is available to meet demand whilst ensuring that the impacts of extraction on local communities, the environment and the built and natural heritage are properly addressed. The policy will also reflect the Scottish Government's finalised policy position on unconventional oil and gas.

General comments on extraction of resources included that there is a case for addressing this issue at a national and/or regional level as it is not an area of specialism for many authorities.

It was also suggested policy on extraction of resources should:

  • Reference policy on the circular economy, reduction of waste and the waste hierarchy.
  • Address how development of mineral sites relates to climate change mitigation and the net-zero carbon agenda- for example by requiring a 'Sustainability Statement' as part of the planning process.

Fossil fuels

Several respondents referred to the Scottish Government's position of no support for unconventional oil and gas with comments including that this should be set out clearly in NPF4. There was support for the Scottish Government's decision, which was noted to align with the decarbonisation agenda and with climate change targets.

Some respondents argued the policy position of no support for unconventional oil and gas should be extended to cover all new fossil fuel extraction, including manufacture of fossil hydrogen and fossil fuel generation with Carbon Capture and Storage (CCS). It was argued that any further consents for fossil fuel extraction would be incompatible with the Scottish Government's climate change targets and legislation and there was a call for public incentives and investment in the fossil fuel industries to end by 2025.

With reference to the text of NPF4 it was suggested that:

  • Reference to fossil fuel in terms of improving energy security should be removed.
  • The requirement to safeguard areas of search for coal should be removed.
  • While coal is being extracted a policy on opencast coal extraction is still needed.

Whether development plans will no longer be required to safeguard fossil fuel deposits from sterilisation was also queried.

Extraction and restoration

The need for NPF4 to include a policy framework for the safeguarding of workable mineral resources while protecting local communities, the environment and the built and natural heritage was highlighted.

In terms of the impacts of extraction and restoration of mineral sites, it was suggested that:

  • It should be clearer that impacts should be avoided and minimised in accordance with the mitigation hierarchy. Consents for mineral extraction in sensitive wildlife areas should be avoided and there should be no consents that rely on complex restoration solutions as part of impact mitigation.
  • Criteria-based policies should ensure that development is always carried out in a sustainable manner, including avoiding sand and gravel extraction from coastal sites.
  • Small scale quarrying for sand would cause little environmental damage.
  • Applications for any new sites should be subject to full survey, assessment and mitigation.
  • Significant weight should be given to impacts on natural heritage and there should be a requirement for net biodiversity gain.

While the potential benefits of habitat creation on restored mineral sites were highlighted, it was also reported that the collapse of the open cast coal industry has left a number of sites unrestored/remediated. It was recommended that NPF4 should:

  • Require fees to be secured for monitoring surface coal mines in line with The Town and Country Planning (Fees for Monitoring Surface Coal Mining Sites) (Scotland) Regulations 2017. Put a system in place for monitoring and enforcement - for both activity on site and the value of the funds.
  • Include a requirement for adequate funds to fully restore sites and withhold consent for development which requires ongoing mitigation or restoration until the finance for mitigation/restoration is in place. It was also suggested both that subsequent permission to develop land forming part of a habitat management area should not be permitted and that restoration plans should be flexible.

Reserves and future demand

Views on Areas of Search included that:

  • These are unhelpful and should be removed.
  • A criteria-based approach would be more practical or would be appropriate in certain circumstances.
  • Favoured areas of search would provide more certainty to developers and stakeholders.
  • Sensitive environmental sites should be excluded from favoured areas of search.

A requirement for a minerals audit to verify that a ten-year (or at least adequate) supply exists was suggested to ensure that sufficient materials are available. One Local Authority respondent, who noted they had found it difficult to plan in the absence of enough information on future demands from industry, argued a criteria-based approach would be preferable. Another suggested that limited information on workable reserves for aggregates is available in some local authority areas and that the onus should be on operators to provide evidence to justify further workings or extensions to existing workings.

With reference to land banks, comments included that moving to a ten-year development plan will not have implications since councils are required to have a ten-year mineral land bank of reserves for construction aggregates. The maintenance of land banks was also suggested to be best addressed at a regional level.



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