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Publication - Consultation Responses

Planning review position statement: analysis of responses

Published: 6 Oct 2017
Part of:
Building, planning and design, Research
ISBN:
9781788512695

Analysis of responses to the Scottish Government's Position Statement following the consultation on Places, People and Planning.

97 page PDF

1.8MB

97 page PDF

1.8MB

Contents
Planning review position statement: analysis of responses
Appendix 1: Summary Tables

97 page PDF

1.8MB

Appendix 1: Summary Tables

Theme 1 Making plans for the future

1. Aligning community and spatial planning

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Supportive of statutory link between development planning and community planning

Supportive of statutory link between development planning and community planning and the two-way process

Support need for Chief Executives to sign-off

Welcome statutory link and sign-off.

Welcome statutory link and sign-off.

Concerns

That there is not a need for a statutory link, as policy or guidance may be enough, or existing links such as to community councils are sufficient.

Resourcing the changes

Centralisation and loss of strategic expertise

Concern that statutory link is not really required to achieve better alignment between the two plans, it risks of overcomplicating the process and delaying the preparation of one or both plans.

The proposal is asymmetric and does not appear to meet the objective of a two-way relationship

Concern on how the reform of the planning system will align with the final Climate Change Plan, Onshore Wind Policy Statement and Energy Strategy

The LDP should remain spatial and if they are aligned with community planning, it must not be delayed.

Concern that the link with community planning can "dilute" the position of the LDP since the community will focus on creating "their plan" instead of maintaining their involvement in the statutory development plan

More information

If there is conflict, is spatial or community planning given greater weight?

How might alignment be effected – are there specific areas in which the two must account for each other?

What these connections are and, at a practical level, how closer working could yield greater benefits than the status quo.

The types of requirement it would impose on community councils

How will the system ensure that Chief Executives and their senior management teams will be involved throughout plan preparation, ensuring that it informs and is informed by other corporate strategies?

More information on how this would be achieved

General request for detail

More details about the link and on the weight/primacy of Community Planning in the LDP process.

What is meant by or would be achieved by having local authority chief executives "sign off" local development plans

How it will work in practice and how Community Plans would sit alongside the proposed Local Place Plans

Ideas

Creates more opportunity for community involvement in shaping places

Consider the consequent need for the planning service to take on a more active role in the community planning process will have resource and training implications

Change to the LDP should be made organically, according to the vision of the local community it is targeting in order for it to succeed rather than having all the decision imposed on the local community. If done this way, it will result in more distinctive places rather than poor places.

Introduction of a chief planning official to each local authority to make sure that the impacts of investment on place is being considered.

In some local authorities they might be more than 2 LDP to be signed-off by Chief Executive

Spatial planning should include land-use, transport and labour market amongst other policy areas

If there will be an increased status for community planning, deliverability must be a key consideration, as should robust criteria for departures from community plans

More work is required to meaningfully link the processes and outcomes of spatial and community planning to reduce double working, maximise resources within authorities, and support the delivery of the development plan.

The ultimate decision of the content of LDP is taken by local authorities and they should "sign off" the LDP

It should be reciprocal between both parties. It should add value and not slow down the system

2. Regional partnership working

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support removal of SDPs from two responses

Support for more flexible approach to strategic planning at a regional level

Support for stronger partnership working at regional level.

If SDPs are replaced – a robust regional partnership system needs to replace them.

Some support the removal of SDPs

Support for removal of SDPs and regional partnership working.

Support removal of SDPs for a procedure that supports the delivery of housing and infrastructure

Concerns

Concern that this is centralisation, removes opportunity for community input and the NPF would become overloaded and less effective

Concern for removal of SDP since they reflect a partnership that is formed between Local Authorities and regions throughout Scotland.

Removal of SDPs will leave a gap and loss of skills – lack of justification for such a move.

Concern that if the partnership arrangement is voluntary it will not deliver.

Concern that a voluntary partnership arrangement without any clear output plan is precarious and will depend on the individual relationships between LPAs and possibly even the local political affiliations

Effectiveness of new regional partnerships against current SDPs.

Removal of SDPs will result in unclear, unaccountable and variable regional structures as well it might slow down the system.

Concern that in the absence of clear government framework, the regional partnerships will not be able to make a significant contribution to the delivery of important strategic infrastructure

More information

If differences of view arise between participants, how will they be resolved so that the whole plan-making process is not brought to a halt?

How will the interests of local communities be represented in the work of regional partnerships?

"A stronger model of shared responsibility and co-production with regional partnerships" may be desirable but raises issues around partnerships composition and management – what in more detail is proposed? What about test case studies?

Detail on geographical coverage of regional partnerships

How will regional plans feed into NPF? As part of evidence base? What influence will they have? How potential tension would be solved?

More details on the financial support of regional partnerships

More information on how regional partnership working envisaged by the position statement will happen in practice

On operation and arrangements of regional partnerships.

How housing supply targets will be set and through what mechanism.

How duties and powers of regional partnerships will be established.

Who will have lead responsibility and adjudicate disputes between partners.

Where the responsibility for coordination of this new regional partnership working will lie; how the effectiveness of the partnerships will be monitored; how they will be resourced

Ideas

Need for clearly defined duties

Define the clear scale for regional partnership working

Need to specify the new vehicle for regional planning by preparing a model of the document

Adequate resources and expertise are needed to address effectively the issues that might rise at a regional level

Should SDPs be replaced they need to be replaced by something equally strong and effective – particularly in terms of partnership working.

Clearly define duties, powers and outputs for regional partnerships around their purpose, roles and responsibilities, governance, accountability, and funding

Introduce a mechanism that retains a 'regional' vision for growth

Any framework set out at a national level must be flexible to allow partnerships to react to local circumstances and priorities, no one-size fits all approach

Duties to encourage partnership working and formal structures.

Discretionary powers should be secondary to obligations.

Define clearly robust duties, powers and outputs for regional partnership working, fully considering the overall need for a more streamlined and efficient system.

Regional targets and regional spatial development strategies must be reflected in the new regional partnership system to ensure that delivery is not held up by individual local authority objectives

Clearly set out details of the responsibilities and the processes for monitoring outcomes

Clearly set out duties and powers for regional partnership working

Any replacement for the current SDP process must be robust and allow for tangible outcomes to be achieved

3. Improving national spatial planning and policy

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support for aspects across responses, but no single area of agreement.

Support for enhancement of role for NPF and SPP

Support national policies that do not have to be restated in LDPs

Support enhanced role of NPF and SPP

Supportive of enhanced status of NPF and SPP.

Concerns

Concern that this move leads to centralisation.

Concern that Regional Partnerships could well lead to in-fighting concerning the distribution of resources, new infrastructure

Concerns that without transitional arrangements, areas will have out of date Development Plans therefore undermining a plan-led system.

Creation of a top-down approach through NPF and SPP.

Timescale for preparation seems overly ambitious.

Concern that the planning system will become an even more constraint-led regime which severely restricts low carbon generation deployment

Concerns about alignment between planning reform and other policy changes

No major concerns were raised.

More information

How can communities be involved in the production of an enhanced NPF?

How views of regional partnerships will be taken into account and in turn how NPF will influence regional planning.

More details about how a revised NPF which sets housing numbers will work and what influence the regions will have in the setting of these numbers

Detail on change on statutory role of NPF and SPP.

More information on the circumstances in which the departures from national policy could be appropriate and the evidence, which the planning authority would require to provide as sufficient justification for departure.

What are the implications for delivery of homes?

Ideas

If greater use is to be made of the NPF, then there should be commensurately greater consultation and greater scrutiny by the Scottish Parliament

If the planning system is to deliver truly sustainable high quality places it will also be important that the NPF is strongly aligned with other key national policy documents

A process for subsidiarity of policy and consideration of local circumstances needs to be allowed for.

The NPF need to be aligned with other key national policy documents

Alignment from NPF to LDPs will be key to providing a coherent and consistent policy platform from which all can work.

The policies which are to apply nationally must provide greater detail and be expressed more clearly than the broad statements in the current versions of NPF and SPP in order to streamline the process

Transitional arrangements must also be set out in order to avoid a moratorium on development in the interim

4. Stronger local development plans

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support gatecheck and resolution of issues at an early stage – including departures from national policy.

Support for change to 10-year plan with provision for updates and review.

Support role of NPF and SPP in role of balancing local and national interest.

Support for removal of the MIR

Support for the introduction of gatecheck and early resolution of issues.

Concerns

Removal of Supplementary Guidance – particularly the protections this offered for natural and heritage assets.

Removal of Main Issues Report Stage – a key point for communities to engage with options.

Preparation timescales seem overly ambitious.

Removal of Supplementary Guidance – where will this detail be located instead?

How will conflict at the gatecheck stage be resolved?

10-year plans may become very out-dated quickly, particularly when it comes to rapidly evolving areas of development such as low carbon and renewable technologies.

How will a 10-year plan deal with the SPP requirement for LAs to maintain a 5-year effective housing supply?

Concern gatechecks could be subject to legal challenges (through unresolved issues) and result in delays.

More information

What would trigger an update/review of the LDP?

Detail on what should be considered and by whom at gatecheck. Needs an agreed list of matters, participants and how process is managed.

What will trigger a review/update of the LDP?

Further detail on the gatecheck process – who will lead the process and what level of certainty will the process lead to?

Triggers for updating/reviewing the plan – what will these be?

Ideas

SG retained as a complimentary to Draft Plans – providing detail on local context and delivery. SG also an important element in drawing together community views, business and development industry views

SG could be held at national level as part of SPP – and adapted by LAs for local needs.

Involve communities in gatecheck through citizen panels.

Align Gatecheck with SEA process by making it multi-stage/iterative.

Gatecheck matters:

  • Whether there is an adequate evidence base ( e.g. infrastructure capacity, environmental assets and constraints, housing land assessments and audits);
  • Outcomes to be sought from the plan (housing requirements, targets for other development types, reuse of vacant and derelict land);
  • Proposed departures from national policy on the basis of local circumstances;
  • Methods for the plan preparation including the approach to engaging delivery bodies and the public, alignment with community planning and the scope of the accompanying environmental assessment.

Gatecheck needs to be inclusive and comprehensive including resolution of issues – otherwise benefit is lost.

Housing Land Audit should be carried regularly and form the basis of a trigger.

5. Making plans that deliver

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support enhanced engagement for unallocated sites.

Support enhanced engagement for unallocated sites

Support replacement of action programmes with delivery programmes.

Support of enhanced consultation for unallocated sites. For allocated sites support for the reduction to 6 weeks but for unallocated sites more consultation is required and thus the period should still be 12 weeks

Support "proportionate" engagement for allocated sites.

Support the principle of engagement for unallocated sites

Concerns

Reduction in engagement for allocated sites – still matters of detail that communities want to be involved in.

Concern that having a two-tier system for pre-application consultation – dependent upon whether a site was or was not allocated in the development plan may be difficult to justify to local communities and consultees.

Concern that different communities would have a different capacity to contribute

Concern that without the buy-in of the development industry the ability of the Council to set out a realistic approach to delivery will be limited.

No significant concerns noted.

Enhanced engagement for non-allocated sites is a cause of concern. Also concerned that enhanced consultation might raise community expectations as to the level of influence they could have.

Engagement for non-allocated sites should only apply to major applications in order not to limit the development of small windfall sites for housing and other uses. For small sites, the developers should judge on what level of consultation should be undertaken

More information

Where would the local council be involved in strengthening of the local plan delivery programme?

Further information on how local development plan delivery can be strengthened – through secondary legislation – is required.

More detail in relation to the role of stakeholders is required

More details about the mechanism regarding the de-allocation of sites and if this would be some form of formal de-allocation process or if it would be a matter to be addressed in a review of an adopted local development plan.

More information on the potential de-allocation of sites.

Ideas

Strong plan led system is critical for the success of the planning system in Scotland. The system has to be incentivised to ensure that windfall sites are an exception

There should be a duty for all community planning partners, external delivery partners, and corporate stakeholders within local authorities to play a full part and be committed to delivery.

LDP would need to set clear timescales for delivery in order to encourage sites to be progressed, with sites that don't deliver within that timescale being removed and alternative sites being identified to compensate.

Requirement to explore what training opportunities could be made available for planners, with a focus on development finance and viability

Ensure the gatecheck aligns with other government policy areas.

For allocated sites the 12 weeks PAN period should be waived or reduced, however for non-allocated sites a 12 weeks PAN period is sufficient for public engagement.

Once a site is allocated in the LDP, this presumes buy-in from all the principle of development and its delivery, the planning application process for allocated sites should not undermine this buy-in, and the level of community consultation should recognise this

Any requirement for enhanced engagement should be left to the discretion of planning authorities

Theme 2. People make the system work

6. Giving people an opportunity to plan their own place.

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Supportive of Local Place Plans – with calls for ensuring there is support in place.

Supportive of LPPs informed by LDPs.

Supportive of stated purpose of LPPs to promote appropriate development.

Supportive of stated purpose of LPPs to promote appropriate development.

Supportive of LPPs being informed by the LDP.

Concerns

Concerned that LPP will not have any influential status.

That communities are not resourced nor have the skills to participate – including concerns for communities in disadvantaged areas.

Resourcing and delay are the primary concerns.

How will LPP production be resourced? Concern that funding will go to well resourced communities creating a greater deficit for disadvantaged.

Risk that community groups could still attempt to use LPP to block development.

Concerns that LPP is contrary to streamlining and efficiency in the planning system.

LPPs will delay LDP production

Risk that community groups could still attempt to use LPP to block development.

Concerns that LPP is contrary to streamlining and efficiency in the planning system.

More information

General request for information on how LPPs will be prepared.

Guidance on who can be involved in preparation.

How will LPP work for CPP partners subject to participation requests from community groups?

Community council involvement in Development Plan Scheme – how does this differ from current arrangements? How does this impact assessment at examination?

Ideas

Definition of community is important – draw from land reform or community empowerment.

Preparation of LPP will require significant resources – including professional advice. Must come from Government.

Communities will need to understand the role LPPs play in the broader framework of plans. Without clarity it risks undermining trust in the system e.g. if DM decision is contra to LPP.

Risk that LPPs become tool only used by the already informed, articulate and affluent.

Communities need to understand strategy of long-term development plans and accept need for change and development.

Clear guidance required keeping LPPs positive.

Independent scrutiny at the point of integrating the LPP with the LDP would be welcome.

7. Getting more people involved in planning

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support involving young people in planning – and wider engagement.

Supportive of the proposals – aware of need to reach "hard to reach" groups.

Supportive of early engagement in plan preparation.

Support engagement with young people and getting more people involved in planning.

Concerns

Token approaches to engagement will prevail.

Concern that some engagement with young people produces unrealistic outputs.

Additional resources and training required carrying out further engagement – diverting from other necessary tasks.

Community Council involvement in Development Plan Schemes may not be the right focus, which should be on early engagement.

-

Concerned if engagement with particular groups becomes a statutory requirement.

More detail on what the requirements will be is needed ahead of drafting the Bill.

More information

-

More details on how to get more people involved in planning and how this will be achieved.

More details on how to broaden engagement

Will moves towards meaningful engagement be in primary legislation, or secondary legislation and guidance?

More details on the development Plan Scheme and Participation Statements and how will they be achieved

Ideas

Implement findings of the Barriers to Engagement in Planning research.

Enhance transparency by responding to public comments on PAC and applications.

LAs should have a duty to upskill community councils, individuals and other groups so they can engage meaningfully with the planning system.

Consider how to promote planning through the education system through a strong link into the school curriculum

Balance community engagement and empowerment with wider societal interests (more homes, jobs, etc)

More guidance on getting people – both young and old - involved in planning should be introduced

8. Improving public trust

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support removal of repeat application at no cost.

Support strengthening enforcement powers.

Support PAC enhancement

-

Concerns

Rejection of equal rights of appeal.

-

Removal of second application at no cost. Many refusals are technical; this would discourage dealing with through amendments, but lead to more appeals.

Removal of second application at no cost. There are multiple reasons for re-submitting. If introduced – should be at reduced fee.

More information

-

-

-

Further detail on PAC changes required. Home building industry needs to be consulted on these changes.

Ideas

Introduce a right of appeal for applications that do not conform with the LDP

Improve trust by responding to comments on planning applications.

Participation in planning just one part of community empowerment – define whether public role in planning is driven by empowerment or more influence through participation and engagement.

-

-

9. Keeping decisions local - rights of appeal

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Agree that a review of local review bodies would be beneficial.

Welcome of mandatory training for elected members

Agree that ministers should not take planning appeal decisions more frequently

Welcomes the proposal for stronger early engagement rather than the introduction of equal or third party rights of appeal

Mandatory training for elected officials is welcomed.

Support for mandatory training for Local Review Bodies and welcome the reviewing of the effectiveness of local review bodies to explore lessons learned, share issues / solutions and identify scope for future improvement

Welcomes the rejection of third party rights of Appeal

Welcome the limit the range of application that can be considered by local review bodies, support mandatory training and not introduce third party rights of appeal

Welcome the decision not to introduce fees for lodging review or appeals, avoiding adding a new barrier to delivery

Concerns

Disappointment for not introducing the equal rights of appeal and fees for either lodging reviews or appeals

Concern that the whole proposal would not improve public trust

Disappointment that fees will not be introduced for appeals

-

Concerns about how local review bodies operate

More information

How reporters will reflect community views in their decisions

More details on how training would be delivered, or who would be responsible for the training and its content or how the quality of training would be assessed and made consistent over the country and through time.

-

Clarification about how the training will work across all the local and planning authorities in Scotland and who is to receive it

More detail is required for the scope of examination and powers of the reporter

Ideas

Ask the Gov. to review their position regarding equal right of appeal, as it is a mechanism that allows communities to express themselves.

Proportionate fee: the introduction of fees should be estimated which reflects the resources and capacity of the parties that must pay the fee. Or impose fees for unsuccessful appeal on developers to discourage them from burdening the system

Subsidiarity in decision-making is a sound principle but there comes a point at which applicants need the opportunity to test their case through an appeal process heard by a Reporter.

Fees should still be charged for reviews and appeals but the fee should be returned if the appeal is successful

If training is to be made mandatory then it needs to be done via statute

LRB's should apply only to householder appeals and that overhaul of the LRB process is necessary

The introduction of third party rights of appeal would have caused major delays and further demand on LPA resources to the detriment of housing and infrastructure delivery, and would serve to be a disincentive for investment in Scotland.

It is unclear at present why schemes of delegation vary markedly across Scotland and that in many Council areas these should afford greater weight to letters of objection than those for support, in terms of the level of decision making for applications

Theme 3. Building more homes and delivering infrastructure

10. Being clear about how much housing land is required

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

-

Welcome any move that gives greater certainty to setting housing numbers and reduces debate.

-

Support involvement in discussions including Homes for Scotland – should take place prior to Bill and legislation drafting.

Concerns

Concern re balance between economic growth and environment.

Concerned re suggestion to set targets nationally, as this does not avoid a repeat of arguments about numbers delivered at development plan process.

-

Concern at lack of detail at this stage in the process.

More information

-

Role of Regional Partnerships and regional spatial strategies in housing number determination.

Unclear at what level Housing Land decisions will be made.

Clarity as to what level housing targets will be set at.

Ideas

Communities of place and communities of interest and designers involved in housing should be added to 'housing professionals, planning authorities and developers'.

Community reps to be included in discussion around "a solution which minimises the level of debate" to ensure satisfaction with method.

Challenge remains in identifying housing need and demand in rural areas. Current HNDA not robust for rural areas with small/sparse population – therefore challenging to identify and plan for new housing.

Must be at a sub-national/regional level in order to understand impact of major developments on transport network. Allows a greater sustainable transport response.

Clear targets rather than aspirations need to be set to be effective.

Bill and primary legislation should set out provision for clear, robust evidence housing target (not aspiration). Set at NPF or nationally produced regional guidance.

Gatecheck assess LA compliance.

11. Closing the gap between planning consent and delivery of homes

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support recognition of environmental assets.

Support enabling authorities to use CPO powers.

Supportive of proposals overall – CPOs and requirements for viability of sites.

Welcome the delivery of high quality development in the right places

Welcome the proposal and particularly the use of compulsory purchase power to facilitate development

Supportive of the objectives of this proposal.

Welcome decision not to include changes to CPO or Development Land Tax at this point.

Concerns

-

Removal of strategic planning could diminish capacity to understand regional delivery issues.

Concern that the legislation as it is written would not help in the delivery of housing

-

Viability information should not be a statutory requirement and only required where viability issues have been identified as an impediment to delivery.

Viability can change over time.

Concerned that LAs do not have the skills to assess viability and its complexities.

More information

How will planning enable building more high quality homes?

Consultation on proposed revision to CPO guidance needed – CPO can bring benefits, but also additional risks for LAs.

More clarity is required as to how this might be carried out in practice

-

De-allocation – more consideration of how this would operate should be considered.

More details on how the Scottish Government plan to close the gap between planning consent and delivery of homes

Ideas

Types of homes developed should be part of the consideration.

High quality homes should mean adequate space, fit for lifetime occupancy.

A minimum density of 30dwellings per hectare (as used to exist in England) would both ensure effective and efficient use of available land, but also help improve design and use of the "Designing Streets" approach ( i.e. more houses and less tarmac).

Meeting housing needs and creating places of quality are public objectives and should be led by the public sector, as they are widely on the Continent.

Opportunities for LAs to capture land value uplift.

Need to factor into consideration that viability issue could change with times

Improved and consolidated planning system that enables the use by planning authorities of CPO. CPOs can be an effective way of unlocking difficult sites but it needs to be borne in mind that the local authorities take on a considerable amount of risk and additional costs in these circumstances

Help individuals and small groups to deliver houses by supporting local co-operatives and self-builders and making it easier for them to develop through LDP.

Consideration should be given to the appropriate points in the planning process of considering the viability of sites and development delivery – at what point from development planning to development management should this take place?

The cost and availability of land often has limits the ability of housing associations to deliver affordable housing. Explore the potential for land to be transferred at existing use value in order to allow increased delivery of affordable housing.

Explore how the uplift in value on land designated for housing can be used to fund infrastructure.

Unlocking sites would require involvement with key agencies

Site viability and deliverability should be proven at the allocation stage which would prevent sites which are not deliverable within the plan period being included within LDPs when there is little or no chance of them delivering within the required period. Viability submission must remain confidential and it should be submitted when the developer contribution threatens the viability of the scheme

12. Releasing more 'development ready' land for housing

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support reflection of concerns in position statement re environmental assessment requirements

Support SPZ and proposed CPO powers

Welcome research and Piloting of SPZ – consultation on outcomes required prior to legislative change.

Supportive of SPZ – learning from trials and research

Concerns

Rationale required for removing restrictions to SPZs in conservation areas etc. At odds with achieving high quality places

How will funding for upfront infrastructure work, plus other resourcing issues such as funding-gap when no planning application fees are collected.

Could be resource intensive process without speeding up the process.

-

Results of research into SPZ need to be subject of further consultation prior to being embedded in legislation. Currently unclear as to how SPZ leads to delivery of more homes.

Discretionary charging – no legislation should be taken forwards until consultation on this has taken place on both operation of SPZ and level of charging.

More information

-

How will any funding gap be addressed? How would local authority or resident concerns be addressed in event of SPZ by Ministerial direction?

-

Further thought on delivery, management and funding required.

Ideas

Rebrand as Strategic Development Zones

Exclusions – all areas around listed buildings or scheduled monuments, conservation areas, designated landscapes, SSSI, greenspace network, wildlife corridors, and related settings and surroundings.

SPZ only successful if high standards of design and non-interference of historic environment.

Need to ensure any large-scale designation is well served by transport infrastructure, services and marketing to ensure sustainable travel is embedded.

Rebrand SPZ to reflect purpose in PPP – tools for encouraging masterplanning and strong design codes.

Need to be able to secure land at existing values.

-

Opportunities for custom and self-build need to be specifically identified.

Experience of pilot schemes must be used to inform.

13. Embedding an infrastructure first approach

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support the approach – regional infrastructure audits, incorporate green infrastructure.

Supportive of an infrastructure first approach – but requests for detail on how, including alignment from the national to local.

Support for an infrastructure first approach.

Welcome the commitment within the Position Statement that key delivery partners, will be consulted as to the role and purpose of this group

Support decision to not introduce an agency (not all).

Support infrastructure auditing.

Concerns

Concerned that infrastructure is under such pressure that a new approach will be unable to alleviate these pressures.

No mention of district heating.

Without a formal agency how will there be local and national accountability.

Disappointment in rejection of a national agency model. Local authorities need help in unlocking development – assistance if not provided by an agency could be provided in other ways as a priority.

Strategic and long-term view not adequately addressed through proposals.

Concerned that a delivery group will be less effective than an agency with duties.

Infrastructure in the position statement seems concerned with housing delivery but needs to include utilities, energy, telecommunications, waste, transport etc.

Concern at the potential for the imposition of a Scottish Infrastructure Levy on energy infrastructure project

Concerned the task-based approach will fail to deliver – without statutory requirement for providers and developers to work together long-term constraints will remain.

Would prefer commitment and certainty provided by a national infrastructure agency.

More information

More details on the ideas proposed

More details on the precise role of partnership working to help improve infrastructure governance and co-ordination

More information on the source of funds that any national body established would manage, and who would mediate and take the final decision if competing priorities were identified

More details if the infrastructure levy would apply to infrastructure projects

How regional partnerships will ensure alignment of infrastructure delivery will be important.

Ideas

Infrastructure planning and coordination as a responsibility for multi-agency Regional Partnership.

Finance infrastructure upfront and recoup cost from developer contributions.

Careful account should be taken of local community and environmental factors, rather than merely imposing proposals from a great height in the interests of early development.

More evidence on why sites have stalled may be beneficial in taking a task-based approach.

Include water and flooding 'infrastructure' in community and spatial planning systems.

Regional Transport Partnerships could provide continuity of knowledge regarding regional infrastructure needs.

Transport Scotland could play a role in pump-priming transport infrastructure through a revolving fund.

The issue of delivery of infrastructure should be given due priority, and local authorities should be given due support to unlock development. Look at case studies in the UK

Define the delivery mechanism from national – regional – local to optimise collaboration and be clear on the precise roles and responsibilities expected from the infrastructure providers

UK-wide alignment of infrastructure objectives needed for the energy sector.

Scottish Government action on funding education infrastructure is key to unlocking housing development.

Infrastructure audit should also identify where new infrastructure be delivered, its funding and method of delivery.

Infrastructure constraints are probably one of the most significant barriers to development.

Alignment of infrastructure provision within the proposed regional partnership working will be important, and proactive working and upfront delivery of infrastructure from Councils to enable delivery of development.

14. Creating a fairer and more transparent approach to funding infrastructure

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support on-going research and levy – provided levy can also fund green infrastructure and is in addition to site-specific obligations.

Welcome infrastructure levy being given further consideration.

Supportive of levy subject to resolution of – cumulative impact of new infrastructure levy and S75 obligations on developers and viability, fund to be able to deliver infrastructure upfront, managing fund to leverage its value – solution to long-term infrastructure challenge.

Welcome retention of S75 ability to modify/discharge.

Support retention of ability to apply for modification and discharge of S75

Concerns

Avoids consideration of funding through public buying at existing values or taxation to gain uplift in value when land use is changed.

Disappointed that removal of ability to modify/discharge S75 obligations not in Position Statement.

Avoids consideration of funding through public buying at existing values or taxation to gain uplift in value when land use is changed.

Disappointed that removal of ability to modify/discharge has been rejected. Notes changes may be required regarding future infrastructure levy.

Of the view that allowing modification prejudices medium-long term planning.

While levy could help fund infrastructure for housing development, it could impact development, which has little or no impact on infrastructure.

Concerns remain re CIL experience. S75A obligations must be considered alongside future decisions on the role of a levy.

Concerned re any levy/taxation that is not supported by delivery mechanism – rates and collection can be set through Supplementary Guidance but difficult to guarantee what funds are spent or programmed to be spent on.

Levy is not solution – waiting for fees to accumulate will delay development.

More information

Detail /justification on proposals – such as no removal of provisions for S75 modification.

Levy requires further consideration following Stage 3 research report – presents further options to test.

Clarity and full consultation on detail will be required on SFT research outcomes, unlikely this can be completed prior to Bill on current timetable.

Matters still to be considered – who has responsibility for delivering and coordinating infrastructure, how it fits with housing delivery, how levy will be scrutinised, and what financial burden should be anticipated.

Ideas

Focus is on new infrastructure provision – existing infrastructure is important in maintaining quality of place and should be considered.

Innovative infrastructure planning and levy must be tailored to local circumstances.

Local Authorities should have option as co-signatory to modify or discharge based on changing circumstances.

Scottish Futures Trust work should allow feed in from RTPs.
Scottish Government needs to consider how land value uplift can be captured when land is allocated or made viable through infrastructure provision.

Infrastructure required as result of increased pressures – renewable energy arguably does not put similar pressures. Recommend similar approach (development that is not a building) to exclusions as in CIL.

Consultation on scope of levy should take place prior to committing to it.

Any changes should be made in consultation with the development industry.

15. Innovative infrastructure planning

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support not removing Section 3F.

Welcome the proposal to consider extending permitted development status to small-scale low-carbon improvements such as micro renewables, electric vehicle charging points and cycling infrastructure in some circumstances.

Support removal of Section 72 of the Climate Change Act.

Support the principle of encouraging new developments to install and operate low and zero carbon-generating technologies.

-

Support removal of Section 3F of the Town & Country Planning (Scotland) Act 1997, as introduced by Section 72 of the Climate Change (Scotland) Act 2009

Concerns

More could be made in the Position Statement of role of planning in tackling climate change.

Disappointed that a potential burden in Section 3F has not been removed – better tackled through Building Standards/Control.

-

Concern that retaining Section 3F doubles up aspects already assessed by Building Control. Adds complexity to planning that is unnecessary.

More information

More details on what the Scottish Government proposed to do in planning for our future energy needs

More details on how planning can help tackle climate change

More information on existing controls with regard to Section 3F to ensure there is not duplication between Planning and Building Control.

Further clarity in the guidance and related legislation to avoid confusion and unnecessary duplication of existing controls and enforcement.

As Section 3F is said to be of limited value – will this be removed by another route?

More information on how the proposed reform to the Scottish Planning System, will support the objectives of the finalised Climate Change Plan, Energy Strategy and Onshore Wind Policy Statement, due to be published in the coming months.

Will work on education infrastructure planning have any bearing on the Bill and legislation? Currently one of the largest barriers to housing delivery.

Ideas

Climate change and environmental protections should be embedded in any legislation.

Consider how the planning system can have an effective role in supporting Scotland's climate change targets – Section 3F not progressing change.

RTPI Scotland proposed the introduction of a task force charged with carrying out a national infrastructure audit. This would not require the setting up of a new infrastructure agency, but could help to improve horizon scanning for needed national and strategic infrastructure projects.

Data sharing between utility providers and local authorities could be much improved and create efficiencies in the planning system.

Need for innovative behavioural mechanisms for the use of infrastructure.

Policy needs to support delivery of other policy objectives such as renewable energy and a low carbon future – it is not just about delivering housing.

-

Theme 4. Stronger leadership and smarter resourcing

16. Developing skills to deliver outcomes

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support proposals for sharing skills in environmental assessment

Support for proposals.

Support skills sharing provided this means support archaeology and heritage services (through improved training) – rather than depletion and stretching those services.

Welcome RTPI audit and look forward to outcomes where skills shortage is demonstrated.

Support sharing services particularly if it makes for a more efficient system, increased performance in determination of planning applications.

Concerns

Calls for Chief Planning Officer at Senior Level appear ignored.

Sharing services should not come at the expense of role archaeologist or other specialist can play when embedded in an LA.

-

-

More information

-

More opportunity for discussions needed.

-

-

Ideas

Scottish Government expert team could support planning authorities.

Areas that could do with additional support – coal mining and onshore wind.

Upskilling is good, but also awareness of opportunities from new technology and how to embrace these.

Thought needed on how skills shortfalls will be bridged while making provisions for reformed system.

-

Development of skills should be transparent engagement between public and private sector to develop mutual understanding.

Specialist skills could be improved through closer collaboration between neighbouring authorities or through regional planning partnerships. Development viability, archaeology, retail impact assessment, EIA, housing and employment land supply assessment, economic assessment.

17. Investing in a better service

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support increased fees – with aim of increasing quality decisions, not just speed.

Support full cost recovery from planning application fees.

Support the extension of permitted development rights

Support ability to charge for other/additional services – proportionate to said service.

Support increased fee and it should be ring fenced to improve service

Support increase in fees if it can demonstrate an improvement in service.

-

Concerns

Concern that paying a higher fee leads to a multi-tier system with larger fees capturing time and attention.

Clarity on final resource implications for planning departments is needed before decisions on fees can be made.

Concern and disappointment that there will be delay in increasing fees – planning departments have a long-standing funding gap in many instances that needs met before services can be improved or adapted to reforms.

Discretionary charging could create uneven playing field across Scotland – applicants being held to ransom or a race to the bottom.

Concern over the long-term implication of the increase of fees on the energy industry

Concerns regarding discretionary charging – current practice does not demonstrate improvement in quality of service.

Disappointed new fee schedule implemented ahead of planning review completion.

Increased fees need to be accompanied by additional performance indicators.

More information

More information on how additional fees could be used to implement improvement measures

More details on discretionary charging

How will a link between increased fees and improved performance be demonstrated?

How will Local Authority performance be measured to justify increased fees?

More information on what effect the increase in planning fee will have?

Ideas

Additional fees for enhanced monitoring of consents – EIA developments, energy developments and mineral extraction in particular.

Planning is a public good and therefore could be funded from general taxation.

Penalty fee for retrospective applications.

Guidance on fee levels should be provided to give an indication of expectations, while still allowing discretion of individual LA.

A final, comprehensive assessment of funding and resourcing requirements needs to wait until the final publication of the new planning measures so that a full position of new and additional duties and related costs can be predicted

New or increased costs should be proportionate to the type and quality of service, and not be excessively onerous to the applicant

Planning application fees need to be ring-fenced for planning departments.

Meaningful quality control needs to be in place to ensure improved service aligns with increased fees.

Online applications could attract a discounted fee

Any increase in the fees paid by the private sector needs to result directly in an injection of additional resources for planning services, delivering stronger leadership that supports appropriate development and encourages new investment in our built environment.

18. A new approach to improving performance

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Support monitoring of outcomes over procedures – pleased to see climate change and carbon emissions monitoring in statement.

Consistent Validation process. And performance monitoring of outcomes.

Support measuring of outcomes – Place Standard could be a reasonable method.

-

Support improving performance across whole planning system

Concerns

Disappointed how outcomes will be monitored is not defined: will it be decision-making speed, quality of development or both?

Penalties could place a strain on already struggling authorities.

Hope that lack of detail does not mean that focus on high performing system is reduced, whether or not planning fees are increased.

More information

-

More detail welcomed. Will a new performance framework be designed to fit reformed system with focus on quality outcomes?

-

Further detail on any new approaches to improving performance need to/should be provided ahead of legislation.

Ideas

Could also include impact of public engagement on planning decisions, quality of public engagement processes.

Independent, expert assessments of economic, environmental, and social outcomes as products of the planning system's operation.

Monitor health and well-being outcomes, climate change and carbon emissions.

Monitor link between community planning and spatial planning – core set of outcomes as different authorities may have different priorities.

Better addressed through imposing statutory improvements or peer intervention.

High-level group looking at performance should include private sector voice with experience of major applications.

Sanction for authorities that consistently fail to improve through either Regulatory Reform (Scotland) Act 2013, or under Part12A of 2006 Act.

Greater transparency of performance is required.

Audit Scotland should carry out necessary assessment. Poor productivity seems to be root issue and should be addressed before money is spent.

KPI for determining what is acceptable performance for assessing applications and registering applications needed.

19. Making better use of resources: efficient decision-making

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Permitted development rights for front garden bike stores, community-growing spaces etc.

Support provided it does not give developers free reign.

Support expansion of PDR with appropriate protections for rural, environmental and conservation designations.

Support proposals as a move to ultimately deliver more robust consents, reduce legal challenge.

Support expansion of PDR – freeing time for planning officers to work on major applications.

Concerns

Concerns with some forms of permitted development rights – particularly concerned about conservation areas and other designated sites.

Efficiency should not undermine quality decision-making.

Concern that it may not free up resources as people still seek guidance on whether or not development is permitted.

Concern that there could be a loss of application fee income.

Concern that the Scottish planning system is not geared up to create economic benefits from the green energy industry

Disappointed measures to improve development management procedures have not been outlined.

More information

Consideration of impact of current PDR should be made before extension.

Complex proposals, therefore further work required.

-

Further consultation on development management procedures should be sought.

Ideas

-

Apply same PDR rules to contractors carrying out same works as statutory under-takers – e.g. laying cabling in roadside verges.

PDR provision for small-scale renewable energy projects – 2-3kw and under scale.

Improved knowledge of on-shore wind sector needed – repowering and modern turbines especially.

Electricity Generation Licenses for proposals under 50 MW – in order to grant the same rights and level the playing field.

Suggested areas for development management review:

  • Introducing application procedures to change planning permissions by a non-material variation (under section 64) or a minor material amendment – and allow the opportunity to appeal;
    Definition of planning applications – such as a requirement for Design (and Access) Statements for applications for planning permission in principle;
  • Timescales for certain procedures – registration, request for further information, neighbour notification, consultation responses, issuing planning decisions.
  • Refreshed government circular on the use of conditions.

20. Innovation, designing for the future and the digital transformation of the planning service

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Pleased that concerns re digital exclusion have been considered.
Yes – ensure community councils have facilities to work online and print paper copies.

Broad support

Supportive of E-Planning system proposals – resources and skills needed to implement.
Supports DTF establishing – technology can help people interact with the planning system.

Support establishing a DTF

Concerns

Concern that adoption of digital could lead to 'bigger and better mistakes' – emphasis should be on improving public disenchantment and poor quality outcomes.

-

Concern that review is not utilising opportunity to strengthen commitment to low carbon development and economic investment.

-

More information

Getting ePlanning Code of Good Professional Practice should be a priority to stop abuse of the system.

The Digital Task Force will be key to focus and focal point.

-

-

Ideas

Consideration needs to be given to rural communities and ability to skip content that takes a long time to load over slower connections.

Technology reforms should run in parallel to other reforms or risk wasting resources. E.g. new LDP process should be put in place with supporting technology. DTF should consider digital exclusion, how can LAs communicate using relevant methods.
National Standards for submission of applications needed, currently each LA adapts. Scotland's Greenspace Map shows what can be achieved.

Opportunities in using social media.

Digital technology could introduce 'real time' tracking of applications.
Technology will never replace the need in planning to have dialogue among stakeholders as to the right location for development – technology can help facilitate with right information.

SEA Review Questions

Question 2: What are your views on the accuracy and scope of the information used to describe the SEA environmental baseline set out in the Environmental Report?

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Broadly support the 4 key areas of change identified in the Consultation

The scope appeared to be comprehensive and separating the SEA into two stages, strategic and indirect environmental effects, was sensible

Given the high-level nature of the plan, the level of detail in the environmental baseline seems appropriate

The scope of the information used to describe the SEA environmental baseline to be accurate and capture the key environmental issues across Scotland

-

No comments

More information

/clarifications

Need for clarity on the Wild Land Areas, it must be explicitly identified alongside National Parks and National Scenic Areas.

Clearly specify in the planning bill that SEA will have at least as important a role in SPZs as in other planning matters

More information on what the environmental implications of removing supplementary planning guidance will be

More information on what it meant by "High-quality homes"

Concern

Non-Technical Summary is not simple and clear enough to fully understand the consequences of the specific proposals

Idea

Incentives need to be offered to developers to build on brownfield sites.

The SEA/ HRA provide important checks to ensure that environmental policies in the NPF/ SPP are not weakened by the drive to improve development delivery

More reference to "landscape character", land use, archaeology and biodiversity.

A clear majority (>97%) of the known archaeological resource is undesignated, these should be identified and The Historic Environment Records ( HERs) should be the key source of information and advice on Scotland's historic environment assets and how to address the issues they raise in the planning system

"The predicted environmental effects set out in the Environmental Report have potential for both positive and negative effects. Any changes must be carefully designed to achieve a more efficient system that delivers better outcomes. Welcome the reference to improving opportunities for developing low carbon infrastructure in table 3.1 within the Environmental Report."

It does not recognise the value that natural resources and material assets present to co-location of renewable energy projects.

Quotes

"Additional relevant sources we would recommend for inclusion in Section 2 Biodiversity, Flora and Fauna in Appendix A are: The UN Sustainable Development Goals, two of which relate directly to biodiversity conservation: Goal 14 Conserve and sustainably use the oceans, seas and marine resources for sustainable development,
Goal 15 Protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and reverse land degradation and halt biodiversity loss." 061-A3

We welcome the inclusion of the Historic Environment (3.2.3) within the scope of the document and the recognition of its importance to Scotland's landscapes and wider environment, together with the statement that "Many further archaeological resources remain undiscovered". 083-B1

"The environmental baseline information and accompanying protection objectives for cultural heritage provide a helpful basis for the assessment and we have no comments to offer on these." 070-B3

"The predicted environmental effects set out in the Environmental Report have potential for both positive and negative effects. Any changes must be carefully designed to achieve a more efficient system that delivers better outcomes. Welcome the reference to improving opportunities for developing low carbon infrastructure in table 3.1 within the Environmental Report." 093-C4

No comments

Question 3: What are your views on the predicted environmental effects as set out in the Environmental Report?

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Agree that the future Planning Bill is unlikely to have significant direct environmental effects due to the fact it is expected to make largely procedural changes

Agree that the Planning Review is unlikely to cause direct Environmental impact, per section 3 of the Paper.

Agreement with the predicted environmental effects set out in the Environmental Report including the approach to alternatives

Welcome the section of Population and Human Health

-

-

Concern

Do not agree with the removal of restrictions in S.54 of the Planning Act and S.37 of the EIA regulations

The removal of SPG will remove a mechanism for environmental scrutiny that is currently available which is a concern for landscape matters

Disappointment that implications for statutory environmental assessment are not embedded fully into the plan making process

Concern that the proposed move to 10-year plan period would have a negative effect on the environment due to a lack of opportunities to address environmental change over the 10-year.

Disagree that no significant environmental impacts are likely to arise from potential changes to 'Simplified Planning Zones'

-

-

More Information

Guidance on how the scarce knowledge of early engagement pre-Gatecheck process might be overcome would be helpful.

Who is responsible for carrying out SEA of the Local Place Plans and where Local Place Plans sit in the lifecycle of the LDP

More information on the reasoning behind why some of the recommendations that formed part of the Places, People and Planning consultation exercise were not taken forward, and to what extent this was based upon their environmental effect or other factors

-

-

Idea

To combine and integrate Health Impact Assessments ( HIA) within the proposed changes will benefit both environmental and population health.

Permitted Development Right, the rebranding of SPZ and removal of certain planning and EIA restrictions will have an environmental impact and thus, mitigation and monitoring should be employed to address the issues raised as well from those arising from moving to a 10-years plan cycle.

Localised indirect impact may occur due to the method development and infrastructure will be delivered, these should be assessed by local authorities during the plan-making process

Communities active participation in planning and placemaking can lead to the creation of better green spaces and environmental improvement

-

Quotes

"The first stage does not recognise the impact that a lack of strategic planning has on the environment. Current practice has seen disorganised, piece-meal development with a loss to the environment. The proposals seem to ignore their own inherent contradictions which need addressing at national, not local, level (for instance the drive to low carbon economy has seen the growth of windfarms and the destruction of our landscape)." 013-A3

"We agree that the Planning Review is unlikely to cause direct Environmental impact, per section 3 of the Paper. Indirect impacts may arise as a result of the procedures in which development and infrastructure is delivered, however these more localised impacts are better assessed by the local authority during the plan-making process, therefore we agree that the predicted effects provided in the Paper are appropriate for this context."

"To achieve our ambitions regulation must match these ambitions and it must not unnecessarily frustrate same by creating financial obstacles or uncertainty in intent. This industry has massive economic potential as well as its potential to impact positively on reducing reliance on fossil fuels and carbon emissions."

No comments

Question 4: What are your views on the findings of the SEA and the proposals for mitigation and monitoring of the environmental effects set out in the Environmental Report?

A. Civil Society

B. Planning and Policy

C. Business

D. Development Industry

Agreement

Agreement with the overall conclusions of the SEA that the proposed changes are largely procedural and operational and are unlikely to have any significant, direct environmental effects

Agreement that the introduction of a gatecheck might have the potential to help strengthen environmental consideration

Agreement with the findings of the SEA and the proposals for mitigation and monitoring, in particular the recommendations for specific guidance and alignment of SEA and HRA procedures

Welcome the recognition that community buy-in and trust are essential to achieving successful places and environmental improvements

Welcome the reference to improving opportunities for developing low carbon infrastructure

Concern

Scotland's natural landscape is very important and concern that with the pressure on delivery, the individual developments with a requirement of an EIA will still go through the planning process and thus, damaging the landscape

Concern that the removal of supplementary guidance applies increased pressure at the 'gatecheck' stage of the planning process

More information

More guidance on how in areas where environmental effects such as air quality are already an existing priority will be addressed and improved by changes to the planning system and planning process.

More clarifications to how consideration of indirect effects within these new PDR's will be taken forward

More information on how SPZ and permitted development rights protect and enhance the Historic Environment

Idea

Monitoring the performance of the amended planning system will be particularly important, as will be the enforcement of SEA/ HRA findings. This must also assess whether or not there is any weakening of environmental policies due to the drive for enhanced delivery of development.
Further research on the potential impact upon people, wildlife and natural environment (flora and fauna) that could come with future changes and developments, and how this could be robustly measured and monitored.

Potential negative environmental impacts of the proposed changes might arise as the structure of the new system becomes clear through the drafting of primary and secondary legislation, regulations, circulars and NPF/ SPP themselves, it is important to be able to mitigate these impacts.

Localised impacts are better assessed by the local authority during the plan-making process

A focus on outcomes rather than procedures and statistics would be beneficial

Need to consider alignment between environmental assessment legislation ( HRA and SEA) and the new plan preparation process, as well as the need for alignment with new provisions around Local Place Plans.

Positive or negative effects might arise from the changes in permitted development rights and Simplified Use of Planning Zones. These should be added to the schedule of mitigation, as a way of highlighting that further assessment may be required, given that this will remain uncertain until specific measures are brought forward.

Environmental effects might rise from the potential changes to SPZs; therefore, further scrutiny of the proposals for SPZs must be taken once the options are more detailed.

The predicted environmental effects set out in the Environmental Report have potential for both positive and negative effects. Any changes must be carefully designed to achieve a more efficient system that delivers better outcomes

No comments

Quotes

"In the second stage there is recognition of impacts to the landscape. However it is mentioned once and glossed over because the emphasis is on the benefits of development (the emphasis on delivery). Whilst we are not against development, and recognise its importance, the natural landscape has much to offer, Indeed the document in its early stages mentions that "Scotland has high quality landscapes, with many iconic views and scenic areas". Our concern is that whilst individual developments with a requirement of an EIA will still go through the planning process that process will have undue pressure on it to deliver." 013-A3

"Monitoring the performance of the amended planning system will be particularly important as will be the enforcement of SEA/ HRA findings. This must also assess whether or not there is any weakening of environmental policies due to the drive for enhanced delivery of development." 068-A3

"Mitigation – it will be important that the potentially negative impacts of the proposed changes are taken into account as the structure of the new system becomes clear through the drafting of primary and secondary legislation, regulations, circulars and NPF/ SPP themselves. It is likely to be at these stages that the environmental impacts of the proposals will be identified with more certainty and can be mitigated." 040-B2

" HOPS agrees with the overall conclusions of the SEA that the proposed changes are largely procedural and operational and are unlikely to have any significant, direct environmental effects." 076-B1

No comments

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