National Planning Framework 2: Discussion Draft - Analysis of Consultation Responses

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CHAPTER ONE: INTRODUCTION

BACKGROUND

1.1 On 8 January 2008 the Scottish Government issued for public consultation a suite of documents related to NPF2, which is intended to guide Scotland's spatial development to 2030. These were:

  • National Planning Framework 2: Discussion Draft;
  • National Planning Framework 2: SEA: Environmental Report
  • National Planning Framework 2: SEA Annex to the Environmental Report: Assessment of Strategic Alternatives; and
  • National Planning Framework 2: SEA: Environmental Report: Non Technical Summary

1.2 The Planning etc. (Scotland) Act 2006 puts the National Planning Framework on a statutory footing. The Act also makes provision for the designation of National Developments, which will be subject to a different process than other planning applications. In particular, designation in NPF2 will be the mechanism for establishing the need for such developments, so that any Inquiry focuses on issues such as design and the mitigation of environmental impacts, not on matters of principle. A statement on the criteria for identifying national developments in Scotland's second National Planning Framework was made in Parliament on 13 September 2007.

1.3 Written responses to the above consultation documents were invited from a wide range of organisations and individuals by 15 April 2008, although this was subsequently extended to 25 April 2008. A total of 283 submissions were received by the deadline for comments (including 8 duplicate and 12 multiple responses).

1.4 In contrast to some earlier Scottish Government planning consultation exercises, there was not a set of specific questions to which consultees were being asked to respond (although the Environmental Report did in fact set out 5 very broad questions). The focus in this instance was primarily to identify the extent to which the national spatial strategy set out in the Draft NPF2, together with the 9 national development proposals were supported and the extent to which respondents were seeking modifications to these elements.

PROJECT OBJECTIVES

1.5 In common with other consultation exercises, the essence of the research project was to provide Scottish Ministers with a sound analysis and concise, but thorough report of the main issues arising from written responses to the consultation. This enabled the expressed aim of the contract, 'provision of recommendations for modifications to NPF2 resulting from the comments received during the consultation period' to be delivered.

1.6 The three specific objectives of the project, set out in the research specification had the following four components:

  • Analysis of responses, drawing out salient issues and indicating to which parts of the document(s) these relate;
  • Preparation of a report of responses citing: number of responses; key issues and commonly recurring issues;
  • Submission of recommendations identifying potential modifications to the draft NPF2; and
  • Preparation of a bulleted list of issues pertinent to the Environmental Report, including annexes and non-technical summary, arising from the responses.

RESEARCH METHODS

1.7 In order to facilitate the analysis, a linked suite of programs within Microsoft Office (in particular, Word and Excel) were used to handle the response data in the most efficient way. A database was constructed in Excel with outputs in Word format as specified in the contract. This enabled statistical tables for each question to be created and also provided text for transfer to the Digest of Responses. As data was entered into the tables they formed the basis of periodic progress reports to the Scottish Government.

1.8 The respondent group component of the Consultation Response Database was constructed in a hierarchical way (with fields to reflect client requirements as finally determined). Fourteen respondent fields were defined and these were capable of being grouped into six main categories (see Table 1.1).

Table 1.1: Respondent Group Categories

Aggregated Level

Refined Level

Local Authorities

Individual Authorities

Other Local Authority organisations

Public Bodies

Government Departments and Agencies

Other Public Bodies

Businesses

Development Industry

Other Businesses/Business Organisations

Professional and Academic Bodies

Professional Organisations

Consultants and Lawyers

Academic/Research Units

Voluntary Sector

Community Councils etc

Voluntary Organisations: General

Voluntary Organisations: Environmental

Public and Politicians

Private Individuals

Politicians and Political Parties

1.9 The documents which formed the basis of the consultation are very large in comparison with many previous exercises [365 pages] and the opportunities for comment were clearly considerable. There were also overlapping themes throughout the documents which added to the analysis difficulties. In order to manage this complexity we devised a structure for the Draft NPF2 which had 55 fields [see Table 1.2]. In practice, this proved to be rather too detailed and the more substantive comments focused on the strategy, infrastructure proposals and spatial perspectives, although it was clearly not possible to have been certain of this in advance.

Table 1.2: Response Fields

Level 1

Level 2

Paragraph Numbers

General Comments

General Comments

1-301

Introduction

Background and Purpose

1-12

SCOTLAND TODAY / DRIVERS OF CHANGE

General Comments

13-140

The Place/ Importance of Place

13-22/79-80

The People/ People and Households

23-25/90-100

The Economy/ Economic Strategy

26-51/77-78

Housing

52-55

Transport/ Transport and Land Use

56-67/115-122

Energy/ Energy Production, etc.

68-72/123-136

Waste/ Waste Management

73-75/137-138

Broadband/ New Technologies

76/139-140

Sustainable Development

81-89

Regeneration

101-105

Scotland in the World

106-114

SCOTLAND - 2030 THE DEVELOPMENT STRATEGY

General Comments

141-187

Key Aims

141-149

Cities and their Regions

151-154

Sustainable Growth

155-168

Housing

169-172

Sustainable Communities

173

Adapting the Built Environment

174-177

Vacant and Derelict Land

178-180

Greening the Environment

181-184

Scotland's Landscapes

185-186

Marine and Coastal Environment

187

INFRASTRUCTURE

General Comments

188-190

Transport

191-225

Energy

226-232

Waste Management

233-237

Water and Drainage

238-241

Flooding & Water Resource Management

242-244

Communications Technology

245-246

SPATIAL PERSPECTIVES

General Comments

247-295

City Collaboration

250

Edinburgh Waterfront

251

West Edinburgh

252

East Central Scotland

253-254

Clyde Waterfront

255-258

Clyde Gateway

259

Making the Connections

260-262

Green Network

263

East Coast

264-269

Highlands and Islands

270-281

Ayrshire and the South-West

282-289

South of Scotland

290-295

STRATEGY MAPS

Maps

296

MAKING IT HAPPEN

General Comments

297-301

ANNEX:NATIONAL DEVELOPMENTS - STATEMENTS OF NEED

Replacement Forth Crossing

Edinburgh Airport Enhancement

Glasgow Airport Enhancement

Grangemouth Freight Hub

Rosyth International Container Facility

Scapa Flow Transhipment Facility

Electricity Grid Reinforcements

Glasgow Strategic Drainage Scheme

2014 Commonwealth Games Facilities

1.10 In addition, the responses to the SEA documents also had to be analysed. It was even more difficult to anticipate how responses to these documents would be framed but we focused on the 5 key questions in the Environment Report and the different scenarios set out in the Strategic Alternatives assessment. This approach produced 10 potential fields [see Table 1.3]. Once again this proved to be a little too detailed with very little comment on the Assessment of Strategic Alternatives

Table 1.3: Environmental Reports and Annex - Response Levels and Fields

Level 1

Level 2

SEA: ENVIRONMENT REPORT/NON-TECHNICAL SUMMARY

General Comments

Disagreement with the SEA Findings?

Need for further evidence, information or policies to be taken into account?

Concerns about environmental effects on particular areas?

Opportunities for mitigation of adverse effects of NPF2 not already identified?

Opportunities for NPF2 to deliver greater environmental benefits than identified?

SEA ANNEX ASSESSMENT OF STRATEGIC ALTERNATIVES

General Comments on Alternatives

Comments on Specific Alternatives

Assessment/Selection of Alternatives

Other Comments on the approach

1.11 There were four main elements to the analysis. First, general comments on the draft NPF2 were captured and common themes identified. Second, responses to the specific chapters in the Discussion Draft were analysed by stakeholder groups, an assessment made as to whether comments were broadly positive or negative, and suggestions for additions or amendments to the Framework recorded. Third, matters concerned with factual accuracy or suggested changes to improve the clarity of the Framework text were separately recorded in the database. Finally, comments on the SEA Environmental Statement were captured and summarized.

Page updated: Thursday, December 04, 2008