Integrated Impact Assessment
The IIA Screening/Scoping Report accompanying the Call for Ideas noted that a range of statutory and non-statutory assessments will inform the preparation of NPF4. The intention is to reach clear findings for each of the assessments, with a summary narrative that sets out key findings under the impact assessment themes of: Environment; Society and Equalities; and Economy.
- Environment Theme: this will include an SEA (including consideration of the likely health effects of National Developments), Habitats Regulations Appraisal, and a consideration of the life-cycle greenhouse gas emissions of National Developments.
- Society and Equalities Theme: this will include an Equality Impact Assessment, Child Rights and Wellbeing Impact Assessment, Island Communities Impact Assessment, and will have due regard to issues arising pertaining to Human Rights matters and through the Fairer Scotland Duty within the NPF4 preparation process. There will also be consideration of any data protection issues arising.
- Economy Theme: this will include a Business and Regulatory Impact Assessment to assess the likely costs, benefits and risks of any proposed policy changes that may have an impact on the public, private or third sector.
Although only a small number of respondents made IIA-related comments, these comments were sometimes very detailed. The analysis presented here gives a summary overview of key issues raised.
General comments included those offering support for the proposal to integrate reporting on the various assessments required for NPF4, including by providing a summary narrative which will draw together cross-cutting issues from the various assessments.
Strategic Environmental Assessment
There was support for the proposed approach of setting out the SEA in a narrative style with tables/matrices and mapping. Related suggestions included that the presentation of findings should identify opportunities as well as constraints and that this could be done in narrative and/or map form. It was suggested that looking for opportunities rather than just constraints will also help with identifying the interrelationships between environmental topic areas more fully.
On a similar theme, there was a view that the wording of previous impact assessment questions often seems to lead the reader to look for negative impacts or features and to overlook positive impacts and features. It was suggested that the scoring system (as set out at 3.1.12 of the Screening/Scoping Report) and some of the language used in the accompanying table (Table 2 of the Screening/Scoping Report) has an inherent negative bias. It was noted that some developments can enhance habitats and species and that any unintentional bias in the assessment methods and scoring systems should be removed.
Another proposal was that a score for unknown impacts should be included. This was seen as important to ensure that uncertainty around effects is recorded, and the level of overall uncertainty gauged. It was suggested that this will help inform discussion around reasonable alternatives, for example considering whether a slightly different course of action could result in a positive outcome or a more clearly defined environmental outcome.
Mitigation and enhancement opportunities
It was suggested that if 'no impact' is recorded, the potential to turn this into a positive outcome by considering a different course of action should be investigated. This was seen as particularly relevant to consideration of opportunities to deliver against existing environmental objectives which are designed to address historic environmental pollution or degradation (as identified in paragraph 3.1.7 of the Screening/Scoping Report).
In terms of possible additions or changes to the SEA:
- There was support for the assessment of the likely health effects for National or major developments. It was suggested that this requirement could also be extended to include an assessment of the impact of developments on wellbeing.
- It was suggested that there are many more inter-related aspects which could be picked up, such as the historic environment and geodiversity and the historic environment and material assets. An example given was that the Example Objective given under the Materials Assets topic (presented at Table 2 of the Screening/Scoping Report) could be expanded to read 'Reduce use and promote sustainable management of natural resources and heritage assets.'
- The relevant environmental objectives (in section 3.1.7 of the Screening/Scoping Report) could make mention of specific Soil and Geodiversity objectives.
- Adaptive flood risk management could be considered as part of the objective proposed for flood risk.
Habitats Regulations Appraisal
Comments about the Habitats Regulations Appraisal included that when considering the effects of any policy change that relates to solar PV, the Scottish Government should make reference to the very latest scientific evidence, for instance as catalogued by Lancaster University, on the ecosystem effects of solar PV.
Environment Baseline Information
Although there was a view that a lot of good information is presented in the Environment Baseline Information, it was felt that it is not always clear how this will inform the assessment of the effects from the policies and proposals in NPF4. In particular, it was suggested that it would be helpful to include references to the sources of information used to draw conclusions.
Other comments or queries regarding the information set out in Appendix A: Environment Baseline Information included that:
- Biodiversity, Flora and Fauna (section 1.2) refers to 2009 data which has now been superseded. The State of Nature Scotland Report 2019 provides a more up-to-date assessment for habitats and species, including those outwith protected sites.
- Climate Factors (section 1.4) could helpfully reference the Scottish Government Scottish Climate Change Adaptation Programme.
- Soils (section 1.7) should recognise and protect soil as a natural capital asset in its own right. One of the key pressures on soils is change in land use and land management practice which is likely to be a key component of NPF4 - however Table 2 does not mention this in its summary of key pressures. The Soils section should include Soil risk maps, the Soil map of Scotland and National soil map of Scotland - all data sources are available on the Scotland Soil Website.
- Cultural Heritage and Historic Environment (section 1.8) presents figures on Scotland's Historic Environment in Numbers but their source is not clear. It was suggested that the most recent figures from Scotland's Historic Environment Audit should be used instead. The section should be also amended to note that Scotland's historic environment resonates internationally and nationally as well as being culturally important to local communities.
- Landscape and Geodiversity (section 1.9) could be adjusted to ensure that the importance of all landscapes are acknowledged as per the European Landscape Convention.
- Material Assets (section 1.10) makes no mention of infrastructure. The Scoping Report also appears to lack consideration of key pressures associated with existing infrastructure, for example in relation to energy generation and transmission, transport, or water treatment and supply.
One respondent noted the proposal to run a public consultation on the IIAs and draft NPF4 in parallel with the 120-day parliamentary consideration of the draft NPF4. They were content with this plan.
Also with reference to timescales, the impact of the COVID-19 was noted and there was a query as to whether the extension of the Call for Ideas period (to 30 April 2020), is expected to have any knock-on effects on timescales for the preparation of the plan and the accompanying IIA. A respondent who is a Consultation Authority under the Environmental Assessment (Scotland) Act 2005 noted that, for administrative purposes, they consider that the consultation period commences on receipt of the relevant documents by the SEA Gateway.
Also with reference to COVID-19, it was acknowledged that mitigation measures have disrupted the engagement programme and that, as a result, businesses and stakeholders will not have had the same opportunities to be involved. There was a call for the Scottish Government to make arrangements to hold discussions with interested stakeholders and to allow for more sharing and iterations of its drafts as they are prepared.
Society and Equalities
Including 'improving equality and eliminating discrimination' as a stand-alone outcome to NPF4 was welcomed, although the need at this early stage to apply an equality lens to each of the other NPF4 outcomes was also highlighted. The importance of producing a full equality impact assessment - which is both produced and published in an accessible way - prior to or when the draft NPF4 is laid before the Scottish Parliament was also raised.
A specific suggestion in terms of the accessibility of the process was that organisations such as BEMIS and the Coalition for Racial Equality and Rights need to be involved and should be listed as statutory consultees at a strategic level.
In terms of the focus of the work to be undertaken, comments included that:
- The Scottish Government must pay due regard to the PSED, including specific duties, and the 'Fairer Scotland' socio-economic duty.
- The Scottish Government and planning authorities should use evidence-based equality impact assessments and the Fairer Scotland duty to aid their strategic thinking, outcome and priority-setting, and action planning.
- Given the long-term nature of NPF4, its impact on equalities will evolve over time and equality considerations should be subject to regular review.
- Specific, evidence-based equality outcomes which address different protected characteristic groups in relation to planning should be developed by planning authorities.
- Monitoring, evaluation and compliance activities should ensure that clear equalities standards are upheld and that desired equalities outcomes are central to this process.
The need to consider the cross-cutting themes of age, disability, race, religion or belief, sex, sexual orientation, gender reassignment and socio-economic disadvantage was highlighted, and there was a call for links to be made to equality and poverty-related policies nationally, regionally and locally.
The importance of ensuring that gender equality is mainstreamed in NPF4 and all planning policy was also highlighted, as was need to identify and address the needs of children and young people, older people, and those living in areas of severe and multiple deprivation. It was also seen as important to identify those who have experienced challenges related to previous planning policy, such as Gypsy/Travellers and disabled people, and to take steps to ensure that NPF4 meets their needs.
With specific reference to Showpeople, it was reported that without any legal status as an ethnic community, this community has not been given any consideration in past NPFs and it was noted that the Screening/Scoping Report and the Society and Equalities baseline information only references Gypsy/Travellers, leaving the Scottish Showpeople community excluded from any conversation at an early stage. It was suggested that the Scottish Showmen's Guild and other members of the community could be involved in a workshop for Showpeople.
Other suggestions in terms of taking the equalities elements of the IIA and NPF4 overall forward included that:
- Proposals should be informed by those with lived experience, including old and young people, children, disabled people, women, minority ethnic groups, religious groups and people with experience of living in poverty.
- Using population segmentation to identify requirements for different protected characteristics and vulnerable populations could be helpful. Some of this is already captured in the IIA but it needs to feed through to NPF4, particularly as there will be greater issues around poverty and disadvantage stemming from the COVID-19 pandemic.
- The cultural sector can be a vehicle to improve understanding and raise awareness in communities of equalities issues.
Island Communities Impact Assessment
The importance of ensuring that NPF4 is properly island and remote rural proofed was noted.
The Scottish Government's recognition of the particular planning-related challenges and opportunities arising from the special circumstances of island communities was welcomed. The preparation of an Island Communities Impact Assessment to accompany the 2019 Act was seen as a very valuable exercise, including because it contained recommendations which will assist in the development of NPF4.
In the drafting of NPF4, there was a call for the Scottish Government to continue to take the unique character and setting of island authorities into consideration, including by 'islands proofing' NPF4.
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