1 introduction
1.1 The Scottish Planning Policy ( SPP) and National Planning Policy Guidance ( NPPG) series is being consolidated into a single, shorter SPP as part of the commitment to more proportionate and practical planning policies. The first part of the consolidated SPP was published in October 2008 1, and replaced SPP1 The Planning System. The final part of the SPP2 was published for consultation on 1 April 2009 and the 12 week consultation period ended on 24 June 2009. The consultation paper included 29 questions (see Appendix A).
1.2 The new SPP consolidates and rationalises existing policy from the current series of seventeen SPPs and NPPGs. The reduction in length has been achieved by removing repetition, background information, advice and explanation of other Government policies. Policy has been reworded and restructured to fit the new approach to communicating national planning policy and to remove inconsistencies and improve clarity.
1.3 The final part of the consolidated SPP includes sections on community engagement, sustainable development, outcomes and various subject policies (economic development, town centres and retailing, housing, rural development, coastal planning, fish farming, the historic environment, natural heritage, open space and physical activity, green belts, transport, renewable energy, flooding, waste management, minerals, opencast coal and telecommunications).
Outline of responses
1.4 A total of 196 responses were received. Table 1.1 shows a breakdown of respondents by type. The largest response category was 'planning authority'. Responses were received from all but one of the 32 local authorities and the two national park authorities. In addition, 5 responses were received from individual departments within planning authorities who had also submitted a more general response. The next largest category of respondent was 'environmental interest group/organisation'. A total of 24 responses were received which fell into this category, equivalent to 12% of all responses. Other categories of respondent were fairly evenly spread, with most of the remaining categories each representing 5-7% of the total.
Table 1.1: Analysis of respondents by type
Respondent type | Number of responses | % of total |
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Planning authority | 38 | 19 |
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Environmental interest group/organisation | 24 | 12 |
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Representative body - profession | 14 | 7 |
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Heritage interest group/organisation | 13 | 7 |
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Community council or group | 13 | 7 |
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Transport interest group/organisation | 12 | 6 |
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Mineral operator/organisation | 12 | 6 |
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Individual (including academic) | 12 | 6 |
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Recreation, sport, outdoor activity and play | 12 | 6 |
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Consultancy | 11 | 6 |
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Retailer /retail organisation | 10 | 5 |
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Developer (including representative bodies) | 8 | 4 |
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Other | 8 | 4 |
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Energy operator /organisation | 6 | 3 |
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Other public sector | 3 | 2 |
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Total responses | 196 | 100 |
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Note: percentages may not sum to 100 due to rounding
The concept of a consolidated SPP
1.5 Responses to individual questions are analysed in Section 2. The consultation paper did not ask people to comment specifically on whether they supported the general principle of a consolidated SPP, but many respondents offered comment on the overall concept. Positive comment included:
"The slimmed down document is welcomed as is the separation of policy from advice which will make the Scottish Government position easier to understand." [Perth and Kinross Council]
"Despite some initial reservations, the exercise has been refreshing and dynamic and has for the most part succeeded in distilling all of the key policy issues into a much more concise and user-friendly format. The draft SPP is a much more streamlined and focused policy statement....and is to be welcomed." [West Lothian Council]
"the SPP will be beneficial to the general public as it will be easier to grasp, as opposed to having numerous SPPs on a variety of themes" [Planning Aid for Scotland]
"De-clutters effectively" [Scottish Property Federation]
1.6 On the other hand, some respondents showed less support for the general concept, including:
"While appreciating the simplicity of a unified SPP and the removal of Scottish Government policy statements described elsewhere in other documents, Archaeology Scotland does not believe that this simplified SPP is sufficient on its own to support a fair and consistent modern planning system" [Archaeology Scotland]
"This consolidation and the removal of guidance from the policy… results in a less clear, less integrated policy. In addition the changes have altered the context in which the policies are understood." [Woodland Trust Scotland]
"General statements within the SPP are likely to produce confusion and uncertainty and could be open to challenge" [East Lothian Council]
1.7 Very few respondents gave unqualified support for the draft - the vast majority made a number of comments about the content of the draft and these are discussed in detail in relation to the specific question to which they refer.