EXECUTIVE SUMMARY
CONTEXT
The National Planning Framework 2: Discussion Draft was published on 8 January 2008 by the Scottish Government and responses were invited from a wide range of organisations and individuals by the 15 April 2008. This deadline was subsequently extended to 25 April 2008. A total of 283 separate submissions were received by the extended deadline for comments, these included 8 duplicate and 12 multiple responses from 242 respondent organisations or individuals.
PROJECT OBJECTIVES AND METHODS
The main purpose of the project was to provide an analysis of the comments received to the Discussion Draft so as to highlight for Scottish Ministers the key issues raised by respondents during the consultation with a view to identifying potential modifications to the Draft. Responses were inserted into a linked consultation database containing text and numerical fields relating to the 6 main respondent categories which had been identified, (local authorities; public bodies; business and trade organisations; professional and academic organisations; community councils and voluntary sector (including voluntary environmental organisations); and the public and politicians/political groups). There was a reasonably good distribution of responses across all of these respondent groups.
COMMENTS MADE ON THE DISCUSSION DRAFT NPF2
General Observations
Over half of all respondents [57%] commented on the general approach set out in the Discussion Draft. Just over half of these were broadly supportive, other comments tended to suggest changes to the structure of the document; the emphasis on various elements or the consultation process; few rejected the whole thrust of the Framework. Voluntary organisations and the public were least satisfied with the document.
A number of comments expressed concern at the length of the document and wanted a more concise and focused approach with the strategy and its links with National Developments more clearly articulated. There were some views that there was too much concentration on the Central Belt and insufficient geographic balance across Scotland. A prominent theme was the emphasis respondents felt was given to different objectives and, in particular, the extent to which the strategy was truly 'sustainable' given the difficulty in reconciling climate change and economic growth aspirations.
Voluntary organisations and the public were most concerned about the consultation processes associated with the preparation of the Framework. Most of this was focused on the extent to which designated National Developments would be subject to further public scrutiny and comment. Local authorities and businesses had concerns about delivery, in particular issues around; co-ordination with other policies, securing stakeholder commitment and identifying funding.
Scotland 2030
Nearly half of all respondents specifically commented on the strategy and there was a high level of support for the strategic aims and main strategy elements, however, a significant proportion of respondents [42%] wanted aspects to be strengthened and clarified, while 14% suggested that major new elements should be introduced or amended.
There was a cluster of responses which felt that the spatial vision/strategy was not as clearly articulated as it could be, some of which suggested a longer planning timescale was necessary. The need for stronger links with other national strategies was highlighted. Tension between the objectives of sustainable growth and reducing Scotland's carbon footprint and too great a bias towards economic considerations at the expense of social and environmental objectives were also mentioned. Greater recognition of both the potential and regeneration needs of rural areas and small towns was another general theme together with the desirability of greater emphasis on the promotion of good and sustainable design.
There was a general welcome for the role of cities and their regions set out in the Discussion Draft, but some views that the role of those other than Glasgow and Edinburgh had been underplayed. While comments were generally supportive, some concerns were expressed about the meaning of 'sustainable growth' and suggestions that land supply for business and industry was not as adequate as indicated. There was much support for renewable energy but criticism of some elements - especially wind farms, and to some extent, biofuels and carbon capture.
Most respondents supported the approach to housing in the Framework, but with many views that this was 'challenging', would require new approaches to delivery and tight monitoring. There were pleas for better design, quality landscape settings and general 'liveability'. There was also support for the Sustainable Communities initiative and many possible locations were suggested, while concerns raised related to planning procedures and community consultation. Few commented on the 'adapting the built environment' section, however the main observation was to strengthen references to flood risk and extreme weather events.
In relation to the environmental strands of the strategy, there was a call for better information on vacant and derelict land and pleas for it to be 'greened' as well as developed. Green networks were strongly supported and various suggested extensions to these were proposed, a greater role for the planning system in controlling deforestation was also advocated. Some respondents wanted 'wildness' recognized and protected, as a distinctive characteristic of the Scottish landscape. A more formal system of marine spatial planning was called for to better protect the marine and coastal environment from competing uses.
Infrastructure
Comments on transport were more numerous than for any other infrastructure category or subsection of the report. There was almost universal support for the key aims and outcomes of transport policy but support for specific projects tended to be concentrated amongst local authority and business responses. Those with reservations about the approach suggested the need for a shift away from road schemes towards public transport, rail freight facilities and other more sustainable forms of transport such as walking and cycling. It was noted that there were no National Developments directed at sustainable transport improvements and a number of possible projects were suggested in this context. A consistent theme throughout these responses was a request for clarification of the relationship between the transport proposals of the NPF and that of other parallel transport related studies with a view to properly determining national priorities.
Comments on air links were particularly polarized - some of those supporting expansion sought further prominence for Prestwick and Aberdeen but there were many observations suggesting that the Framework should not be supporting this mode of transport. There was a consensus that cross border high speed rail links should be encouraged but port proposals were more contentious. The viability of proposals for Rosyth and Scapa Flow was challenged and there were concerns about the failure to designate Hunterston and the Loch Ryan Ports as National Developments.
Responses to the section on 'internal connectivity' continued the debate concerning the extent to which sustainable modes were being encouraged by the Discussion Draft. Rail projects were again widely supported with the electrification of the whole Scottish inter-city network [not just Edinburgh-Glasgow] the most frequently mentioned improvement. Many trunk road projects were considered to be important and there were calls for the A75, A77, A9, A82 and A96 to be designated as National Developments. There were few comments on the role of buses and trams but disappointment was expressed that more was not made of walking and cycling in the Discussion Draft.
The broad thrust of the subsection on 'Energy' was widely supported, but concerns were expressed about a potential 'energy gap' if baseload electricity generation was not increased. While the need for some improvements to the electricity transmission network was generally accepted views diverged on the most acceptable form it should take. There were concerns about the environmental effects of overhead transmission lines [Beauly-Denny in particular] and of the role of the Ofgem approval process. The Framework proposals for the development of marine energy and sub sea networks prompted many positive comments and a call for the indicative area of potential to be extended. Similarly, most comments on 'decentralised production' were favourable with various suggestions for overcoming perceived difficulties and constraints on its progress.
There were relatively few responses to the remaining subsections of the Infrastructure chapter. With regard to waste management, there were calls for the identification of a national network of facilities sufficient to meet projected needs; and further clarification of the requirements for radioactive waste facilities in the South of Scotland. Some respondents felt that the Framework significantly underplayed the problems associated with the provision of water and drainage facilities and sought clearer investment targets. The approach on flooding was broadly welcomed with calls for more emphasis on 'holistic' river catchment management solutions and greater use of canals. The main points made in relation to communications technology were for greater data transfer speeds and recognition of the potential which the Digital Switchover Project had in facilitating new services.
Spatial Perspectives
The sub-national dimension in the Framework was generally welcomed by respondents, however, most of those commenting specifically on the matter felt it did not go far enough. Some felt that other broad spatial development options should have been considered, others that there was either too much of a Central Belt or Eastern Scotland bias, but the most frequent comment was on the need for more detail on the share of national growth and development to be allocated to each sub-national area. The Central Belt subsection attracted fewer comments than other areas, most observations wanted greater emphasis to projects or their designation as National Developments. Mentioned in this context were: Edinburgh Waterfront; a West Lothian Strategic Employment Zone and the Strathleven Corridor. There was very positive support for the Central Scotland Green Network proposal.
Concerns were expressed that there was insufficient emphasis on the energy sector around Aberdeen; pro and con views relating to the Aberdeen Western Peripheral Route and the suggestion that the north-east arc of development should be extended to Inverness. There were also views that the potential role of Peterhead's Deep Water Port and Dundee City had not been fully recognised. A cluster of representations objected to the perceived concentration of development around Inverness at the expense of the rest of the region and there were calls for greater emphasis on the Outer Hebrides National Energy Zone and for improvements to the A9 north of Dornoch. The local council felt that the role of Argyll and Bute had been underplayed in the Draft Framework.
The absence of a Central Ayrshire Economic Development Zone was raised by a number of respondents from the area and a suggestion that there should be greater emphasis on the Ardeer peninsula Energetics Cluster; Hunterston; Prestwick; Ayr Town Centre Renaissance Project and improved communications with the Central Belt were proposed as National Developments. There were concerns that the treatment of the South-West, split as it was between two sub-national areas, was confusing. More proposals for action in relation to small towns and rural areas in the South of Scotland were recommended and another group of projects put forward as prospective National Developments [Loch Ryan Ports; A75/77 upgrade; Dumfries Town Centre Regeneration; Gretna International Gateway; M74 Economic Corridor; Borders Rail Link and A1, A68 and A7 route improvements]
Making it Happen - Statements of Need
Delivery had been a theme running through the comments on earlier sections and, consequently, there was almost universal support for the section on implementation in general and the Action Programme in particular. One matter of particular concern, was the status of projects mentioned in the Discussion Draft which were not designated National Developments. Another recurring theme was the need for both a clearer understanding and transparent policy implementation consistency between NPF2 and the whole range of related national, regional and local policy documents and strategies. The need for continuing community, business and government agency involvement in the implementation process was stressed together with a call for a clearer understanding of the resource commitments underpinning the Framework.
While there were a substantial number of comments relating to National Developments, there were few about the Statements of Need themselves. There were some observations that they contained less detail than might have been expected and a recommendation that the identification of any national project should follow a series of steps each being subject to a form of environmental assessment. There was also a query as to whether the Statements of Need formed part of the Action Programme or not. Specific comments tended to seek clarification of the description of the project or further elaborate why it was needed.
COMMENTS ON THE ENVIRONMENTAL REPORT AND RELATED DOCUMENTS
There was a limited number, but, in general, a very detailed set of responses to the Environmental Report and most respondents felt that a thorough assessment had been carried out. There were several procedural points about how any revisions to the Framework will be assessed and the appropriate relationship between strategic plan and individual project environmental assessments. Disagreements with Strategic Environmental Assessment ( SEA) findings were generally related to fairly wide range of specific points, but some individuals felt that the adverse impacts of the strategy as a whole had been underplayed. Responses to the need for further evidence followed a similar pattern - areas of concern included: soils; landscape; natural heritage; water and air quality; connectivity and new communities. Particular areas where environmental impacts were of concern included: the Firth of Forth; West Edinburgh; Inverness A96 Corridor and Orkney. There were a range of suggestions on how to improve mitigation measures and these covered issues such as the water environment and flooding; air quality; renewable energy and impacts on Special Protection Areas / Special Areas of Conservation. It was considered that greater environmental benefits would be achieved if a national network of waste management facilities was developed and if more elements of the Sustainable Scenario had been incorporated in the Draft Framework adopted strategy.
Observations on the Assessment of Strategic Alternatives raised some concerns about the rationale underpinning the selection of elements from different alternatives for the Framework; lack of consideration of grid reinforcements and the ambiguous meaning of 'sustainable economic growth'. There was a view that few of the National Developments could really be considered 'sustainable' and regret that none had the environment at their core. A number of other specific points relating to the selection and assessment of transport projects generally and airports in particular were also mentioned in responses.