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
- 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
- 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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