National Planning Framework 3:
NEMT Comments on NPF3 Main Issues Report
The Report can be found from http://www.scotland.gov.uk/Topics/Built-Environment/planning/NPF3-SPP-Review/NPF3
- 2. Better Spatial Guidance for Onshore Wind
- We fully support the proposed use of the SNH map of Core Areas of Wild Land
in Scotland to identify more clearly those areas which need to be protected.
It is important that an impartial body provides this guidance as planning
authorities would be caught in conflicts of interest. However, we believe
that this welcome move needs to be strengthened as follows:-
- Provisions need to be made for updating the map at regular intervals.
For example, it is surprising that so little of the Borders and Dumfries
& Galloway appears on the map. This is not a problem at this stage
where we establish the principle. Detailed local consultation might well
result in an increase to mapped core wild land in this area.
- All areas of wild land identified by SNH should be part of Group
1 (ref. Scottish Planning Policy, Para 218) to give improved protection.
Wild land is a major part of our heritage and responsible for significant
tourism income, particularly important for the economically vulnerable
rural communities found in these areas.
- Para 2.21 needs to be strengthened. As currently written, this is too
weak and inviting of challenge. We understand the reluctance to designate
under statute. However, use of the SNH mapping to "inform future
planning" will not give local authorities sufficient reassurance
to resist legal challenges from large power companies.
- More guidance needs to be given on how cumulative impact is calculated
as this is of concern to local communities increasingly surrounded by
wind farms. This will be particularly important in the cases where proposals
are made to extend existing wind farms and also where proposals are made
to build new wind turbines in the vicinity of an existing wind farm.
- The guidance needs to encourage further large scale wind energy development
to be focused in a few key locations rather spread evenly across the country.
The guidance should encourage use of plantation areas in non-sensitive
landscapes and ex-industrial sites.
- 2. Electricity Transmission
- Para 2.45 needs to state a clear commitment to either not put new or upgraded
power lines through areas of wild land designated by SNH, or to use buried
cables through these sensitive areas.
- 7. Sustainable Use of Our Environmental Assets
- This section is too development focused. We doubt that examples of the land
uses given, i.e. woodland expansion, peatland or habitat restoration would
do much to meet climate change targets. Afforestation designed to maximise
rates of carbon sequestration would be ugly and unfriendly for both wildlife
and human access. Much greater contributions to targets would be made by improving
transport modes (from private to public and from motorised to walking or cycling)
and space heating regimes.
- 9. Sustainable Tourism - Long Distance Routes
- We agree that a good network of long distance walking trails is a valuable
resource for both encouraging tourism and also for improving local community
health. However, we see no advantage in designation as a national development.
This sort of development will proceed best with local ownership. National
designation is more likely to stifle local and regional initiative and impose
- We consider that a sufficient number of long distance routes has been established
in recent years and that these should be allowed to "settle down"
so that an assessment of usage can take place.
- When considering new cycle routes, care should be taken to site them away
from main roads. Some existing routes are too near busy roads, e.g. A9 and
Submitted by Dave Windle
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