6. Impact Assessments
- Question 5 in the consultation paper focused on this.
- We did not consider that the changes would have significant impacts on the environment, business, equalities and children's rights and wellbeing, and therefore our view when preparing the consultation paper was that fuller impact assessments were not required.
- However, we invited views and evidence on this.
A majority of respondents (61% of all responses) agreed with our conclusion that full impact assessments are not required, given the procedural and technical changes, their lack of significance, their role in clarifying processes and their temporary lifespan ahead of NPF4 being published.
Others (39% of all responses) disagreed with our conclusion because:
- They considered the proposals to have significant effects, potentially impacting on national outcomes.
- The intent is to change the way that planning decisions are taken.
- They considered that further assessment is needed to ensure the consultation is valid.
In terms of the specific assessments, some respondents suggested that a strategic environmental assessment (SEA) was required to assess the impacts on net zero emissions, and to take into account the impact on providing renewable energy schemes, energy efficient homes, green infrastructure, and the reuse of vacant and derelict land.
Some responses suggested that equalities and human rights could be affected by the impact on affordability for those on low incomes, and that health could also be affected. Similarly, some respondents considered there may be wellbeing or health impacts arising from the economic impact on the housebuilding industry, construction sector and supply chain.
A BRIA was considered necessary by some, given their views on the potential impacts on businesses and the economy. Evidence was presented which has been considered in more detail in the following section.
Detailed comments received
Strategic Environmental Assessment
Housing developers and their representatives considered that the changes would result in lost opportunities for sustainable development, with effects on the housing supply, green networks, open space, vacant and derelict land and unproductive sites. Renewable energy providers also wanted to see an assessment of the impact on meeting net zero targets.
Equality Impact Assessment and Child Rights and Wellbeing Assessment
It was suggested that fuller assessments were necessary, given the potential impact of the changes on housing affordability. It was suggested that health could be affected, and that unemployment and hardship in the housebuilding sector would also lead to impacts.
Business and Regulatory Impact assessment
It was contended that, based on a series of assumptions about the income generated from each house, the removal of the presumption would mean that more than 10,000 jobs, £13.3 million of 'local spend' and £40 million to the local economy would be lost.
- Our initial assessments assumed the changes will not affect decisions directly – our view was that the proposed changes would maintain the original policy intention.
- We recognise that the Court's decision could change how the policy is applied, and that amendments may therefore lead to different decisions being made.
- However, the evidence shows that the role of the presumption is neither clear cut nor determinative. The impact, in terms of numbers of homes built or other developments affected cannot be accurately predicted. However the impact on number of homes delivered could reasonably be expected to be neutral given the continuing role of planning judgement in decision-making and taking into account the revised amendments we are now proposing. The effect of changes on other sectors is also expected to limited.
- We do not accept the evidence submitted by Homes for Scotland as referred to above, because this assumes that without the presumption, all exceptions sites would be refused planning permission, with 2,667 homes not being built as they would depend on the presumption in favour of development that contributes to sustainable development. Our review of the evidence suggests that this is an over-estimate. It is not reliable to conclude that all proposals that may have been approved would be refused permission. This is particularly the case when the amended policy changes set out in Section 7, and the application of planning judgement in each case, are taken into account.
- Nevertheless, we have given further consideration to the likely impacts of the changes, taking into account all of the views and evidence received and in light of the revised proposals. We have published new screening reports which conclude that fuller assessments are not required.