National Planning Framework 3:
NEMT Comments on NPF3 Main Issues Report

The Report can be found from

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:-
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 unwanted standardisation.
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 A82.

Submitted by Dave Windle

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