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.

Natural environment

Proposed key objective of NPF4: To protect, enhance and promote access to our natural environment; whilst supporting their sustainable use and securing positive effects for biodiversity when considering new development. This includes identifying and affording protection to international, national and locally designated areas and sites in development plans and development management, including having regard to the desirability of preserving peatland

Suggestions with respect to the wording of the key objective included:

  • Protection and enhancement of biodiversity needs to be clearly set forward in the key objective rather than implied as part of a broad natural environment statement.
  • Amending the objective to read: 'To protect, enhance and restore nature, securing positive effects for biodiversity when considering new development. This includes identifying and affording protection to international, national and locally designated areas and sites and their species in development plans and development management to prevent damaging proposals being brought forward in these locations. To promote sustainable access to our natural environment.'

It was suggested to be important that NPF4 and the Land Use Strategy are closely aligned or are integrated effectively to prioritise the land use changes needed to achieve positive action on both climate and biodiversity. It was also argued that planning authorities need to have more focused input into the next Land Use Strategy in order to ensure a targeted approach to climate change and biodiversity that considers local conditions and circumstances.

The inter-relationship between the climate change emergency and the natural environment were highlighted and it was argued policies designed to contribute to meeting net-zero carbon targets must also take account of opportunities to enhance biodiversity and aid nature recovery. In a similar way to climate change, biodiversity should be integrated though out NPF4.

It was also suggested NPF4 must retain the recognition in current SPP that the environment is a 'valued national asset', and that planning has a role in protecting the environment, enhancing it, and promoting access. Requiring every development to be compatible with the National Outcome for the environment - 'We value, enjoy, protect and enhance our environment' - was proposed and that any development contrary to any aspect of this outcome should not proceed.

Recognising the importance of community environmental stewardship and traditional practices in maintaining and supporting a range of unique habitats, biodiversity and iconic landscapes in rural and island areas was also proposed.

There were calls for creation of a Scottish Nature Network or Ecological Network. The Scottish Nature Network - proposed as a National Development - was described as 'a spatial network of natural assets that would guide and inform long-term investment in Scotland's green infrastructure. Helping to align and co-ordinate the achievement of shared objectives across planning and land use sectors particularly in terms of taking action on the climate and nature crises at local, regional and national scales.'

Identifying international, national and locally designated areas

SPP guidance on development within national and international designations was suggested to be clear and the current hierarchy of policy for international, national and locally designated areas to be robust and to work well. Reviewing and updating the approach to the identification and protection of areas of the highest scenic and landscape significance including National Parks and National Scenic Areas was also suggested.

It was argued that as well as statutory and non-statutory designated sites, connecting habitat should be protected, as the value of ecological networks will be increasingly important with the effects of changing climate on species ranges.

Locally designated sites were argued important to both the sense of place of local communities and in attracting tourism, with UNESCO Biospheres given as examples of the type of sites that might be appropriate for local designation. It was suggested many of the landscapes most valued by local people in rural Scotland are designated as Local Landscape Areas or Special Landscape Areas, and that these should be given strong protection from damaging development in NPF4. Preparation of Management Strategies for Scotland's 33 National Scenic Areas was proposed as a National Development.

With respect to the process of designation of sites it was suggested that it would be useful for more guidance on local designation to be available or for existing guidance to be reviewed and integrated into SPP. Lack of a standard methodology, and staff resources and expertise were identified as limiting inclusion of local sites in LDPs.

A rather different position was that the existing national parks and statutory environmental designations provide sufficient protection to areas of special character, and that an increasing number of areas subject to local designations are placing too many restrictions on wind farms.

Specific sites

Stronger protection for the most important wildlife sites was proposed to make it clear and unambiguous that protected areas are not appropriate places for large scale development, unrelated to the conservation management of the site.

Specific suggestions included better protection for ancient woodlands and for Ramsar sites.[28] With respect to the latter it was argued Ramsar sites and all their listed habitats and species should be given equivalent protection to Natura 2000 sites.

Wild Land

Clarity around the status of Wild Land was suggested and it was noted this is, in effect, a designation in every way other than its actual status.

There were calls for NPF4 to retain or strengthen the existing protection for Wild Land, including making clear that any proposed development that could lead to part of the land losing its Wild Land status would be refused.

Specific suggestions included:

  • The Wild Land Areas map should be retained as part of a spatial framework. and areas identified could be given equivalent status to National Scenic Areas or recognised as part of a national Nature Network.
  • The attributes of Wild Land Areas could be recognised in less remote places.
  • LDPs should specifically address any Wild Land in their areas, stating how these will be preserved or, if developed, how their special qualities will be maintained.
  • There should be engagement with local communities.

As noted under the Energy - electricity theme, concerns were also raised regarding the inclusion of Wild Land within Group 2, including because there is no formal designation for Wild Land, and that current SPP sets the bar for development too high for any wind energy scheme to satisfy. Any further protection for Wild Land was suggested to risk having a detrimental effect upon economic development and social sustainability in some areas.

Recognising the role of national parks

It was suggested that NPF4 should continue to recognise and protect the national importance and special characteristics of Scotland's National Parks and their potential to contribute to climate and nature emergencies. It was also noted that national policy criteria can establish the role of national parks in conjunction with, not in isolation from, other designated or protected areas.

There was a call for designation of a suite of new national parks, including in Galloway and in the Borders. This was suggested as a National Development. Consideration of a role for Coastal and Marine National Parks was also suggested.

With respect to planning in National Parks it was argued that:

  • The powers available to National Park Authorities should be reviewed with a view to strengthening their control of development.
  • Development plans and planning decisions for National Parks should be consistent with the first objective of National Parks - 'To conserve and enhance the natural and cultural heritage of the area'. A development category for ecological restoration within a National Park's development plans could help Parks to fulfil this objective.
  • New settlements in National Parks would be both unsustainable and inappropriate and should be ruled out.
  • No major developments should be permitted in National Parks, except in exceptional circumstances.

A relaunch for Scotland's existing Regional Parks was also proposed, along with consideration for new Regional Parks, for example in the Ochil or Kilpatrick Hills.

Positive effects for biodiversity

Many respondents commented on the importance of biodiversity, including that NPF4 should include policies to safeguard, protect and enhance biodiversity or that, like climate change, biodiversity should be integrated though out relevant topics. The importance of large areas and networks of habitat were highlighted.

Suggestions included that NPF4 should:

  • Define biodiversity.
  • Reflect regional variations in biodiversity.
  • Recognise the place of Local Biodiversity Action Plans and incorporate an action plan into all spatial planning decisions.
  • Set out the role of key agencies and other stakeholders in securing positive effects for biodiversity. Embed more landscape architects and ecologists into planning authorities.
  • Recognise the contribution the historic environment makes to landscapes and how it relates to biodiversity.
  • Address how biodiversity is to be incorporated into development plans and how local authorities will measure 'positive effects' when assessing a planning application. 'Positive effects' was suggested to be too vague.
  • Provide general policy that can be applied across different scales of development and in different locations.
  • Adopt a policy requiring development to deliver 'positive effects for biodiversity' through a mechanism that is yet to be specified.
  • Support the concept of biodiversity net gain.

Suggestions with respect to biodiversity net gain included that it should be:

  • Promoted in all new developments and redevelopment/ regeneration schemes; mandatory for all government and public sector actions; or applied to commercial development which does not primarily serve any community or public need.
  • Assessed against the potential of an environment not its current condition.
  • Underpinned by a set of principles to guide delivery.
  • Enforceable.

It was noted that the principle of net gain has already been introduced in English planning policy, so a methodology is already established.

The importance of development following the mitigation hierarchy was emphasised, so that, wherever possible, adverse impacts on biodiversity are avoided and alternative options pursued. Where adverse impacts are unavoidable, suitable mitigation measures should be secured or, where this is not possible, compensatory measures should be considered.

An Energy Company highlighted their own commitment to biodiversity no net loss outcomes for new projects, and their aim to drive environmental stewardship best practice in the industry as part of wider sustainability ambitions.

It was also argued that some parts of Scotland's valued environments can accommodate certain types of development, where it can be demonstrated that there will be no adverse environmental impact or where it can be demonstrated that there will be net-gain in biodiversity, and that primacy must be given to EIAs when determining applications.

Alignment with existing environmental legislation

It was suggested that NPF4, the Land Use Strategy, the Regional Land Use Frameworks, and sector-specific policies such as the Forestry Strategy need to be integrated. Integrating relevant policies was also suggested to have potential to support the integration of data and mapping in decision making.

Specifically, it was suggested NPF4 should:

  • Be compatible with existing pieces of environmental legislation and provide guidance as to how they apply to planning.
  • Reference other strategies where relevant but be useable without reference to multiple external documents.
  • Endorse existing environmental legislation and the policies and guidance from the key agencies - SNH, SEPA and Historic Environment Scotland.
  • Provide guidance on how the Forestry and Woodland strategies can or should align with proposed LDP development strategies.
  • Be aligned with any future legislation on post Brexit environmental standards.

Protecting soils

It was suggested that the current approach of protecting the best quality agricultural land and the increasing emphasis on protecting peatland and carbon rich soils should be continued. The complexity of soils in ancient woodland was also highlighted and argued likely to be damaged by disturbance even if there is no loss of trees. Policies on avoiding soil compaction around trees and encouraging compliance with BS 5837:2012 were suggested.

Supporting creation of woodland

There were calls for creation of more woodland, particularly of native species, including in both upland areas and urban areas. The value of afforestation of upland areas in providing catchment-scale flood mitigation was highlighted.

It was suggested planning can support woodland creation through implementation of the Land Use Strategy, mapping of areas of opportunity that take account of sensitive habitats such as peatland and guiding the spatial strategy for 'the right tree in the right place'. Policies to ensure new woodland and forestry planting is not to the detriment of priority species that depend on open habitats were suggested.

It was also argued that a potential conflict between major forestry expansion and the need to protect peatland and carbon rich soils should be recognised, and pilot work by Scottish Forestry and Councils in southern Scotland was suggested to provide a possible route to identifying less sensitive areas for forestry expansion.

Woodland creation could also be supported through a requirement for LDPs to identify and safeguard opportunity areas, ensuring that opportunities are not lost to other forms of development.

It was also noted that, while the 2019 Act tasks planning authorities with developing Forestry and Woodland Strategies, the promotion and control of forestry planting does not come under the remit of the planning system.

Protecting existing woodlands

The importance of protecting existing woodland was also highlighted with proposals that:

  • There should be a presumption against development which would destroy areas of established woodland.
  • Scotland's temperate rain forest should be conserved and restored.
  • There should be stronger protection or statutory protection for ancient woodland and veteran trees. Compensation through securing other positive effects for biodiversity should not be considered with respect to removal of ancient woodlands.
  • The Ancient Woodland Inventory should be updated using mapping of ancient woodlands carried out during production of Forest and Woodland Strategies.

Balancing competing requirements

With respect to the requirements for renewable energy and preservation of peatlands it was suggested that:

  • NPF4 should provide a clear steer on planning policy in regard to new waves of renewable energy development, in particular in relation to areas that are identified as having significance in terms of their landscape, biodiversity and/or carbon sequestration values.
  • The planning system should not prevent onshore wind developments on peatland where the resultant development will have a short carbon payback period, other mitigation can be put in place, and where development can improve degraded peatland under existing good practice guidance.
  • NPF4 should recognise that renewable energy projects can provide wider environmental benefits, such as contributing to resilient ecological networks, restoring degraded peatlands and restoring grasslands. Solar PV was argued to be completely compatible with continued grazing by sheep or the establishment of biodiversity havens.
  • NPF4 should recognise every area has a carrying capacity for onshore wind, and some areas are getting close to this limit. A national overview was suggested to ensure that all areas with potential for renewable energy are making a proportionate contribution.



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