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Your guide to NPF4 consultation policies

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Policy 2: Climate Emergency

What the Planning Framework says:
a) When considering all development proposals significant weight should be given to the Global Climate Emergency.

b) All development should be designed to minimise emissions over its lifecycle in line with the decarbonisation pathways set out nationally.

c) Development proposals that will generate significant emissions, on their own or when combined with other proposals or when considered in combination with other proposals, allocations or consented development, should not be supported unless the applicant provides evidence that this level of emissions is the minimum that can be achieved for the development to be viable and it is also demonstrated that the proposed development is in the long-term public interest.

Development proposals for national, major or EIA development should be accompanied by a whole-life assessment of greenhouse gas emissions from the development. In decision making the scale of the contribution of development proposals to emissions in relation to emissions reduction targets should be taken into account. Where significant emissions are likely (even as minimised) in relation to national decarbonisation pathways but the planning authority is minded to grant consent, emissions off-setting measures may be considered including nature-based solutions. Such measures should take place on-site as an integral part of the overall development, or off-site where on-site provision is not possible or insufficient.

d) Development proposals for new, or alterations to, buildings, infrastructure and spaces should be designed to be adaptable to the future impacts of climate change. Proposals to sensitively incorporate climate adaptation and mitigation measures for existing buildings, infrastructure and spaces, should generally be supported.

What the John Muir Trust thinks: 

    • Proposing an accurate emissions assessment should be a clear requirement for all planning proposals.
    • We welcome a presumption against approving development proposals that will generate significant emissions but asking for more clarity on what counts as ‘significant’.
    • We're asking for this policy to make clear that developers should reduce emissions before they consider offsetting.
    • We state that the policy should make it very difficult for land use changes to proceed which would emit more carbon than they remove.
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Policy 3: Nature Crisis

What the Planning Framework says:

a) Development plans should facilitate biodiversity enhancement, nature recovery and nature restoration across the development plan area, including by: facilitating the creation of nature networks and strengthening connections between them to support improved ecological connectivity; through the creation of new or restoration of degraded habitats; and, through measures to increase populations of priority species. Nature networks, which connect biodiversity rich areas, may include international, national and locally protected sites, and Other Effective Area-Based Conservation measures (OECMs).

b) Development proposals should contribute to the enhancement of biodiversity, including restoring degraded habitats and building and strengthening nature networks and the connections between them.

c) Any potential adverse impacts of development proposals on biodiversity, nature networks and the natural environment should be minimised through careful planning and design. Design should take into account the need to reverse biodiversity loss, safeguard the services that the natural environment provides and build the resilience of nature by enhancing nature networks and maximising the potential for restoration.

d) Development proposals for national, major and of EIA development or development for which an Appropriate Assessment is required should only be supported where it can be demonstrated that the proposal will conserve and enhance biodiversity, including nature networks within and adjacent to the site, so that they are in a demonstrably better state than without intervention, including through future management. Applications for farmed fish or shellfish development are excluded from this requirement. To inform this, proposals should:

  • be based on an understanding of the existing characteristics of the site and its local, regional and national ecological context prior to development, including the presence of any irreplaceable habitats;
  • wherever feasible, integrate and make best use of nature-based solutions, demonstrating how this has been achieved;
  • be supported by an assessment of potential negative effects which should be fully mitigated in line with the mitigation hierarchy prior to identifying enhancements;
  • provide significant biodiversity enhancements, in addition to any proposed mitigation. Biodiversity enhancements should include supporting nature networks, linking to and strengthening habitat connectivity within and beyond the development. Biodiversity enhancements should be secured within a reasonable timescale and with reasonable certainty. They should include management arrangements for their long term retention and monitoring, wherever appropriate.

e) Proposals for local development should only be supported if they include appropriate measures to enhance biodiversity, in proportion to the nature and scale of development. Applications for individual householder development, farmed fish or shellfish development, or which fall within scope of the policy above, are excluded from this requirement. Development proposals which integrate nature-based solutions and deliver positive effects for biodiversity should be supported.

What the John Muir Trust thinks: 

  • We recommend the policy wording is explicit that restoration across the development plan area requires the identification, creation and protection of nature networks in such a way that enables natural connectivity between habitats and reverses habitat fragmentation.
  • We recommend that the list as written in Policy 3a includes the nationally important landscape type, Wild Land Areas, which whilst not protected by statute, remain valued landscapes and important places for wild nature (therefore matching the definition for Nature Networks in the draft NPF4).
  • We welcome Policy 3d. It has the potential of turning large-scale development into a means to reverse the decline of biodiversity. The land footprint of major EIA and national development can be vast (for example we estimated that the proposed Glenshero wind farm site is equivalent to the size of the city of Perth) therefore the biodiversity enhancement potential of these sites is enormous
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Policies 5 (community wealth building) and 6 (design, quality and place) 

What the Planning Framework says:

Policy 5: Community wealth building
a) Development plans should address community wealth building priorities by reflecting a people-centred approach to local economic development. Spatial strategies should support community wealth building; address economic disadvantage and inequality; and provide added social value.

b) Proposals for development within the categories of national developments and major developments should contribute to community wealth building objectives.

Q27: Do you agree that planning policy should support community wealth building, and does this policy deliver this? Have your say.

Policy 6: Design, quality and place
a) Development proposals should be designed to a high quality so that the scale and nature of the development contributes positively to the character and sense of place of the area in which they are to be located.

b) Development proposals should incorporate the key principles of Designing Streets, Creating Places, New Design in Historic Settings and any design guidance adopted by planning authorities and statutory consultees. Where relevant and appropriate, development proposals should also demonstrate through design tools, such as a Design Framework, Place Standard Tools, Development Brief, Masterplan, Design Guide, Design Code, Design Statement or Design and Access Statement, that an inclusive and design-led approach has been taken to development.

c) Development proposals should be able to demonstrate how the six qualities of successful places have been incorporated into the design of the development so that it contributes positively to the character and quality of the area and the way it functions.

d) Development proposals that are poorly designed, including those that are not consistent with the six qualities of successful places, should not be supported.

e) Proposals that are detrimental to the character or appearance of the surrounding area taking into account effects on daylight, sunlight, noise, air quality and privacy should not be supported, in order to protect amenity.

What the John Muir Trust thinks: 

  • Asking that all developments under Policy 5, including National Developments, support community wealth building. Changes in land use of any kind should be informed by community wealth building and place-making principles.
  • Asking for Policy 5b to be strengthened by stating a proposed development must show how it meets the community wealth building priorities.
  • Asking for Policy 6 to recognise that the needs of people living in a place should inform the design of any development. By making community needs a consideration at design stages it means developers and planners must take the time to explore what communities need. This could help developers consider how design aids or undermines human wellbeing.
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Policy 12: Blue and green infrastructure, play and sport

What the Planning Framework says:

a) Local development plans should identify and protect blue and green infrastructure, safeguarding existing assets. Plans should also identify opportunities to enhance and expand provision and access to blue and green infrastructure (at strategic and local scales). Development allocations should be chosen taking account of the areas that can best contribute to enhancing and delivering key green networks and priorities.

b) Local development plans should identify new, enhanced provision or improved access to play opportunities for children as part of enhancing and expanding blue and green infrastructure. Blue and green infrastructure should provide opportunities for play and recognise the need for, and provide publicly accessible, outdoor opportunities for formal, informal and incidental play. These facilities should be good quality, accessible and suitable for different ages and abilities, to satisfy current and likely future needs and demand in the community.

c) Development proposals that result in fragmentation or net loss of existing blue and green infrastructure should not be supported unless it can be demonstrated that the overall integrity of the network of blue and green infrastructure will be maintained.

d) Development proposals in regional and country parks should only be supported where they are compatible with the uses, natural habitats and character of the park.

e) Development proposals should not be supported where they result in the loss of outdoor sports facilities, unless the proposal:

  • is ancillary to the principal use of the site as an outdoor sports facility; or
  • involves only a minor part of the facility and would not affect its use; or
  • meets a requirement to replace the facility which would be lost, either by a new facility or by upgrading an existing facility to provide a better quality facility. The location should be convenient for users and the overall playing capacity of the area should be maintained; or
  • can demonstrate, in consultation with sportscotland where appropriate, that there is a clear excess of provision to meet current and anticipated demand in the area, and that the site would be developed without detriment to the overall quality of provision.

f) Development proposals that result in the quantitative and/or qualitative loss of children's outdoor play provision should not be supported, unless it can be demonstrated that there is no ongoing or future demand or it is replaced by a newly created, better-quality or more appropriate provision within the development proposal.

g) Development proposals for temporary or permanent open space, green space or play space on unused or under-used land should be supported.

h) Development proposals should incorporate and enhance blue and green infrastructure wherever possible. They should be designed to be multifunctional and consistent with the six qualities of successful places. This means paying particular attention to, for example: ensuring that the needs of all potential users are met; connections with wider green networks for people and wildlife; responding to local character and distinctiveness; building in resilience; and maximising use throughout the year. Designs should take account of existing provision and identified requirements, to ensure the proposed blue green infrastructure is of an appropriate type(s), quantity, quality and accessibility.

i) Major development proposals for new homes, and other major development likely to be used by children and young people should incorporate well-designed,good-quality provision for play, recreation and relaxation.

j) Development proposals that include new streets and public realm should incorporate the principles of Designing Streets and inclusive design to enable children and young people to play and move around safely and independently; maximising the opportunities for informal and incidental play in the neighbourhood.

k) New, replacement or improved play provision should, as far as possible and as appropriate:

  • provide stimulating environments;
  • be inclusive;
  • be suitable for different ages of children and young people;
  • be easily and safely accessible by children and young people independently; including those with a disability;
  • incorporate trees and/or other forms of greenery;
  • form an integral part of the surrounding neighbourhood;
  • be well overlooked for passive surveillance;
  • be linked directly to other open spaces and play areas.

l) The long-term stewardship of blue and green infrastructure should be addressed to maintain its quality and integrity. Development proposals should provide effective management and maintenance plans wherever this is necessary. Developers must provide details of the functions of the blue and green infrastructure, the maintenance requirements, together with the party responsible for these, and demonstrate funding arrangements for their long-term delivery to the satisfaction of the local authority before construction starts.

What the John Muir Trust thinks: 

  • We're asking NPF4 to more explicitly recognise the role of wild places, in addition to green spaces. Empirical research consistently indicates that contact with the natural world provides multiple benefits for human health and wellbeing, including improvements to physical health (through increased physical activity) and improvements to psychological and social wellbeing (such as reduced stress and anxiety, increased happiness, self-esteem and resilience).
  • We recommend Policy 12b asks Local Development Plans to identify and protect wild places ‘as part of enhancing and expanding blue and green infrastructure’
  • We recommend Policy 12f, makes clear that ‘loss of children’s outdoor play provision’ includes loss of wild places in urban as well as rural areas.
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Policy 14: Health & wellbeing 

What the Planning Framework says:

a) Local development plans should aim to create vibrant, healthier and safe places and should seek to tackle health inequalities particularly in places which are experiencing the most disadvantage. The provision of health and social care facilities and infrastructure to meet the needs of the community should be a key consideration.

b) Development proposals should not be supported where significant adverse health effects are likely to occur. A health impact assessment will be required for all proposed development that is considered likely to generate significant health effects or is within the categories of national developments, or major developments or is EIA development.

c) Development proposals that would have a significant adverse effect on air quality should not be supported.

d) Development proposals that would result in unacceptable levels of noise will not be supported. A noise impact assessment will be required where significant exposure to noise is likely to arise from the proposed development.

e) Development proposals for, or including, space or facilities for local community food growing and allotments should be supported.

What the John Muir Trust thinks: 

  • We recommend this includes a presumption to refuse any type of development that restricts people’s access to green space and wild places.
  • We're asking for the policy to require that any proposal for development close to existing green spaces (in an urban setting) or wild places (in a more rural setting) should show through its design how it will enhance the natural environment and community access to green spaces and nature.
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  • Have your say

Policy 19: Green energy

What the Planning Framework says:

a) Local development plans should seek to ensure that an area's full potential for electricity and heat from renewable sources is achieved. Opportunities for new development, extensions and repowering of existing renewable energy developments should be supported.

b) Development proposals for all forms of renewable energy and low-carbon fuels, together with enabling works such as transmission and distribution infrastructure, and energy storage such as battery storage, should be supported in principle.

c) Development proposals for wind farms in National Parks and National Scenic Areas should not be supported.

d) Outwith National Parks and National Scenic Areas, and recognising the sensitivity of any other national or international designations, development proposals for new wind farms should be supported unless the impacts identified (including cumulative effects), are unacceptable. To inform this, site specific assessments including where applicable Environmental Impact Assessments (EIA) and Landscape and Visual Impact Assessments (LVIA) are required.

e) Development proposals to repower, extend and expand existing wind farmsand for the extension of life to existing windfarms should be supported unless the impacts identified (including cumulative effects) are unacceptable.

f) Development proposals for small scale renewable energy generation technology should be supported.

g) Areas identified for wind farms should be suitable for use in perpetuity. Consents may be time-limited but wind farms should nevertheless be sited and designed to ensure impacts are minimised and to protect an acceptable level of amenity for adjacent communities.

h) Major applications for energy generation from low carbon sources, for manufacturing or industrial developments should be accompanied by adecarbonisation strategy to demonstrate how greenhouse gas emissions from the process are appropriately abated. That strategy may include carbon capture and storage.

i) Proposals for negative emissions technologies and carbon capture should be supported in principle.

j) Development proposals for solar arrays should be supported where the planning authority is satisfied that the arrays would not adversely affect (including the effect of glint and glare) residential amenity, road safety, historic environment assets, or aviation interests. Ground mounted arrays should be installed using pile driven or screw foundations rather than trench foundations to facilitate restoration of the site.

k) Specific considerations will vary relative to the scale of the proposal and area characteristics but development proposals for renewable energy developments must take into account:

  • net economic impact, including local and community socio-economic benefits such as employment, associated business and supply chain opportunities;
  • the scale of contribution to renewable energy generation targets;
  • effect on greenhouse gas emissions reduction targets;
  • cumulative impacts – taking into account the cumulative impact of existing and consented energy development;
  • impacts on communities and individual dwellings, including visual impact, residential amenity, noise and shadow flicker;
  • landscape and visual impacts, including effects on wild land;
  • effects on the natural heritage, including birds;
  • impacts on carbon rich soils;
  • public access, including impact on long-distance walking and cycling routes and scenic routes;
  • impacts on historic environment assets, including scheduled monuments, listed buildings and their settings;
  • impacts on tourism and recreation;
  • impacts on aviation and defence interests including seismological recording;
  • impacts on telecommunications and broadcasting installations, particularly ensuring that transmission links are not compromised;
  • impacts on road traffic and on adjacent trunk roads;
  • effects on hydrology, the water environment and flood risk;
  • the need for conditions relating to the decommissioning of developments, including ancillary infrastructure, and site restoration, opportunities for energy storage; and
  • the need for a robust planning obligation to ensure that operators achieve site restoration.
  • Do you agree that this policy will ensure our places support continued expansion of low-carbon and net zero energy technologies as a key contributor to net zero emissions by 2045? Have your say

What the John Muir Trust thinks: 

  • We're asking for Local Development Plans to identify the areas in their Local Authority where the renewable energy potential can be realised whilst at the same time identifying areas for safeguarding for nature’s recovery.
  • We recommend that a spatial approach for onshore wind is clearly stated and retained in NPF4.
  • We're asking for continued recognition and protection for Scotland’s Wild Land Areas as part of a spatial approach for onshore wind development.
  • We suggest a preferential planning hierarchy which prioritises development in already developed landscapes.
  • We recommend it refers to Wild Land Area impact assessments as an assessment consideration within the Landscape and Visual Impact Assessment.
  • We're requesting support for community renewable energy development.
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Policy 32: Natural places

What the Planning Framework says:

a) Local development plans should identify and protect locally, regionally, nationally and internationally valued natural assets, landscapes, species and habitats. These assets and areas should be safeguarded in the spatial strategy in a way which corresponds with the level of their statutory status. Spatial strategies should also be designed to better connect nature rich areas through establishing and growing nature networks to help protect and restore the biodiversity, ecosystems and natural processes in their area.

b) Development proposals that would have an unacceptable impact on the natural environment including biodiversity objectives should not be supported.

c) Development proposals likely to have a significant effect on an existing or proposed European site (designated as a Special Areas of Conservation (SACs) or Special Protection Areas (SPAs) which is not directly connected with or necessary to their conservation management must be subject to an 'appropriate assessment' of the implications for the conservation objectives. The relevant tests for such developments are set out in legislation.

d) Development proposals that will affect a National Park, National Scenic Area, Site of Special Scientific Interest or a National Nature Reserve should only be supported where the objectives of designation and the overall integrity of the area will not be compromised; or any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by social, environmental or economic benefits of national importance. Planning decisions for development within National Parks must be consistent with the National Parks (Scotland) Act 2000. All Ramsar sites are also European sites and/or Sites of Special Scientific Interest and are extended protection under the relevant statutory regimes.

e) Development proposals that would be likely to have an adverse effect on aprotected species should not be supported unless it meets the relevant statutory tests. If there is evidence to suggest that a protected species is present on site or may be affected by a proposed development, steps must be taken to establish their presence. The level of protection afforded by legislation must be factored into the planning and design of the development and any impacts must be fully considered prior to the determination of the application.

f) Where non-native species are present on a site, or where planting is planned as part of a development, developers should take into account legislation on non-native species.

g) Development proposals that affect a site designated as a Local Nature Conservation Site or a Local Landscape Area should be supported where development will not have significant adverse effects on the integrity of the area or the qualities for which it has been identified; or any such effects are clearly outweighed by social, environmental or economic benefits of local importance.

h) Planning authorities should apply the precautionary principle where the impacts of a proposed development on nationally or internationally significant landscape or natural heritage assets are uncertain but there is sound evidence indicating that damage could occur. If there is any likelihood of damage, modifications to the proposal to eliminate the risk of such damage should be considered and implemented. If there is uncertainty, research, surveys or assessments to remove or reduce uncertainty should be undertaken.

i) Development proposals for development in areas identified as wild land (per Nature Scot Wild Land Areas map 2014) should only be supported where:

  • the proposed development cannot be reasonably located outside of the wild land area; or,
  • it is for small scale development directly linked to a rural business, croft or required to support a fragile population in a rural area; and,
  • a site based assessment of any significant effects on the qualities of the areas is undertaken, and use of siting, design or other mitigation minimises adverse impacts.
  • Q50: Do you agree that this policy will protect and restore natural places? Have your say

What the John Muir Trust thinks: 

  • We support it overall and commend the Scottish Government for recognising and clearly emphasising the fact that Scotland’s natural environment underpins our economy, health and wellbeing, biodiversity and climate resilience.
  • We rRecommend that NPF4 clearly identifies what would constitute “an unacceptable impact on the natural environment” in Policy 32b, as it appears open to interpretation in its current form.
  • We're asking it to provide clear protection to nationally important peatlands.
  • We welcome the presumption against development in Scotland’s wild land stated in Policy 32i.
  • We're asking the policy to define or be more precise about what is meant by ‘nationally and internationally valued natural assets’ and to include Wild Land Areas as nationally important natural assets.
  • We're supporting small scale development ‘directly linked to a rural business, croft or required to support a fragile population in a rural area’, which should be accompanied by assessments of impact.
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Policy 33: Soils

What the Planning Framework says:

a) Local development plans should protect locally, regionally, nationally and internationally valued soils.

b) Development proposals should only be supported if they are designed in a way that minimises the amount of disturbance to soils on undeveloped land and protects them from damage including erosion or compaction.

c) Development on peatland, carbon rich soils and priority peatland habitatshould not be supported unless essential for:

  • essential infrastructure, where there is a locational need and no other site is suitable; or
  • the generation of energy from a renewable source, where the proposal supports a zero carbon electricity system and will maximise the function of the peatland during its operational life and in decommissioning; or
  • small scale development directly linked to a rural business, farm or croft; or
  • supporting a fragile population in a rural or island area; or
  • restoration of peatland.

A detailed site specific assessment will be required to identify depth, quality and stability of soil and the effects of the development on peatland, including the likely effects of development on CO2 emissions. This should inform careful project design and ensure that adverse impacts, including emissions release, can be avoided and minimised through siting, design and appropriate mitigation. Where an assessment identifies peat onsite, a peatland management plan will be required to demonstrate that any unnecessary disturbance, degradation or erosion has been avoided or minimised, including appropriate mitigation measures. Where peatland /peatland vegetation is displaced this must be reintegrated into a functional peatland system, in accordance with the mitigation hierarchy and relevant biodiversity policies.

d) Development proposals for new commercial peat extraction, including extensions to existing sites, should not be supported, unless:

What the John Muir Trust thinks: 

  • Asking for a clear policy expectation that developers design development to avoid peat.
  • Asking for deep peat to be safeguarded from new built development.
  • Requesting accurate carbon assessments of the carbon that could be released from a site.
  • Suggesting the carbon calculator tool is revisited and updated and referenced in planning policy.
  • Stating that in the absence of an accurate carbon assessment, there should be a policy presumption against development at a site.
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Policy 34: Trees, woodland and forestry 

What the Planning Framework says:

a) Local development plans should identify and protect existing woodland and potential for its enhancement or expansion to avoid habitat fragmentation and improve ecological connectivity, helping to support nature networks. The spatial strategy should identify and set out proposals for the development of forestry and woodlands in their area, in associated Forestry and Woodland Strategies, including their development, protection and enhancement, resilience to climate change, and the expansion of woodlands of a range of types to provide multiple benefits to the physical, cultural, economic, social and environmental characteristics of the area, in accordance with The Right Tree in the Right Place guidance.

b) Development proposals should not be supported where they would result in:

  • any loss of ancient woodlands, ancient and veteran trees, or adverse impact on their ecological condition;
  • adverse impacts on native woodlands, hedgerows and individual trees of high biodiversity value or identified for protection in the Forestry and Woodland Strategy;
  • fragmenting or severing woodland habitats, unless mitigation measures are identified and implemented;
  • conflict with Restocking Direction, Remedial Notice or Registered Notice to Comply issued by the Scottish Government Forestry Regulator, Scottish Forestry.

c) Development proposals involving woodland removal should only be permitted where it would achieve significant and clearly defined additional public benefits. Where woodland is removed in association with development, developers will generally be expected to provide compensatory planting.

d) Where a planning application is proposed which includes an area of existing woodland or land identified as being suitable for woodland creation (under the FWS), opportunities to enhance and expand woodland onsite and integrate it into design, or create new woodlands in accordance with the Forestry and Woodland Strategy in association with development, should be considered.

e) Sustainably managed woodland can bring a range of benefits and planning applications should be supported where they enhance, expand and improve woodland to deliver benefits such as carbon sequestration, improving air quality; enhancing energy efficiency and providing shelter and shade, providing opportunities for woodland play and recreation; improving biodiversity; helping prevent flooding; and other ecosystem services.

What the John Muir Trust thinks: 

  • Welcoming it overall. It places an importance on value of trees and woodlands and showing a commitment towards protecting and enhancing Scotland’s woodlands.
  • Recommending that Policy 34c and 34d, should stress the importance of safeguarding the remaining fragments of ancient woodland and Scotland’s rainforest, as well as protecting native woodlands against any adverse impacts
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