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

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CHAPTER EIGHT: KEY CONCLUSIONS

8.1 The NPF2 Consultation Document attracted a healthy level of written responses [283], given the scale of the documentation and other consultation exercises which had taken place. These responses were also well distributed across the various stakeholder interest groups, so that it is fair to conclude that a good cross section of concerned opinion was obtained.

8.2 The production of NPF2 was welcomed by most respondents but many sought to have aspects strengthened, clarified or new major projects included. There was considerable support for restructuring the document to make it shorter, more focused and with clearer links between the strategy and key projects and strategic designations.

8.3 There was a high level of support for the strategic aims and main strategy elements in the Framework but a number of respondents suggested stronger links with other national strategies. Some felt that the regeneration needs of rural areas and small towns had been rather underplayed. Tension between the objectives of sustainable growth and reducing Scotland's carbon footprint and too great an emphasis on economic considerations at the expense of social and environmental objectives were also cited as weaknesses by a number of respondents. Green networks were particularly strongly supported and numerous suggestions for their extension and development were made.

8.4 The Infrastructure Section, which identified the key National Developments, attracted the highest number of comments. While there was considerable support for the 9 listed projects some also attracted strong opposition. A common theme which emerged from responses to this section raised the question of the relationship between the Draft Framework transport proposals and other parallel transport-related studies. Views on air links were very polarized, but rail projects widely supported. Many Trunk Road projects were considered important but some criticism that more sustainable modes were not given more prominence.

8.5 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. In particular, there were serious concerns about overhead transmission lines and Ofgem approval processes.

8.6 There were a number of views suggesting that the list of National Developments was rather restricted and short-term, while many submissions wanted additional projects to be designated, some in fields other than infrastructure provision.

8.7 The sub-national dimension in the Draft 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, of the relationships 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 also stressed together with a call for a clearer understanding of the resource commitments underpinning the Framework

8.8 A number of local authorities considered that the needs and potential of their areas had been insufficiently recognised in the Draft Framework, in particular, the Ayrshire authorities, Argyll and Bute and Dumfries and Galloway. There were some concerns that there was too much of a Central Belt or Eastern Scotland bias in the strategy and proposals.

8.9 A concern with delivery was a constant theme running through the comments on the Draft Framework 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 the appropriate relationship between strategic plan and individual project environmental assessments. Disagreements with Strategic Environmental Assessment ( SEA) findings were generally related to a fairly wide range of specific points, but some individuals felt that the adverse impacts of the strategy as a whole had been underplayed.

8.10 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. Others considered that there was either too much of a Central Belt or Eastern Scotland bias. 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.

Page updated: Thursday, December 04, 2008