NEMT Comments on Scottish Planning Policy Review

The consultation document can be found from http://www.scotland.gov.uk/Topics/Built-Environment/planning/NPF3-SPP-Review/SPP-Review

Consultation Question 1

We welcome the move to give improved spatial guidance for the siting of wind farms, using the SNH Map of Core Areas of Wild Land in Scotland to identify more clearly those areas which need to be protected. We consider these identified areas should be protected from any intrusive industrial development.

Para 68 - 71 - Rural Development

This section is generally good. However, more effort needs to be made to clarify phrases such "whilst protecting and enhancing environmental quality" and "responds to the specific circumstances of the area". These phrases will mean different things to different interest groups and should be clarified.

Para 85 - Development Planning

It should be made clear that the requirement to provide housing land does not apply within National Parks and also National Scenic Areas. Areas identified in the SNH map of Core Areas of Wild Land in Scotland should also be protected.

Para 90 - Consultation Question 9 - Development Planning

The Policy needs to recognize that, once designated, National Parks become desirable place to live in and generate their own housing demand for second homes and holiday lets, thereby destroying the very qualities that lead to them being designated as a National Park in the first place. The primary purpose of a National Park is to safeguard the environment and heritage of the area. Housing policy should be directed to supply of affordable housing for park residents.

Para 97 and Consultation Question 11 - Affordable Housing

25% is unacceptably low for a National Park. It should be noted that the Peak District National Park in Derbyshire achieves a near 100%. Why should this not be the target for Scottish National Parks?

Para 214 - 215 and Consultation Question 15 - Heat

We acknowledge that developing heat networks ahead of the availability of suitable sources of heat might help to drive transformational change. We suggest that it is more likely to discredit the development of heat networks. This area is in its infancy in much of Scotland. We suggest that the appropriate approach is to "walk before we run" and get more experience before we aim for transformational change. Thus, we believe that the correct approach is that heat networks should only be considered where there are suitable existing sources of heat supply.

This section should specifically address the easier contribution to reducing energy demand by improving house insulation, draught-proofing, etc.

Para 218 - 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 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. Tourists will not come to visit a wind factory.
• Clear guidance needs to be given on how close wind farms can be built to a protected area. It is unrealistic to expect a National Park to retain its character when surrounded by a dense concentration of wind turbines.
• 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 than spread evenly across the country. The guidance should encourage use of plantation areas such as some of the Borders and ex-industrial sites.

Para 219 - Onshore Wind

We support the removal of the 20MW threshold.

Para 230 and Consultation Question 19

We support the proposal.

Consultation Question 20

We strongly support this proposal and, indeed, have difficulty in seeing how the Strategic Flood Risk Assessment should not be used in this way.

Consultation Question 23

The tone of the document is too biased towards development and gives insufficient attention to preservation of our outstanding natural heritage. More attention should be paid to our environment and protection of endangered species.

Consultation Question 24

We believe that effective monitoring is essential if it is to become a respected document. We suggest a system of regular reviews and audits.

Submitted by Dave Windle

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