CVs replace Core Principles. The CVs are more concise and focused.

Although there is no indication that the CVs are listed in order of priority, it is interesting that the CVs start by mentioning focus on outcomes (but what does that actually mean?!!!). The CPs had focus on quality of outcomes (as the last bullet point), but quality is not mentioned in the CVs, although the Introduction says “Planning should take a positive approach to enabling quality development …”. A lot of the changes from the SPP are like this – moving between sections, making it difficult to decide if there is any actual difference in the meaning and application.

New themes in the CVs include facilitating economic recovery and sustainable economic growth, and providing a supportive business environment.

The plan-led system was top of the list of the CPs, but is now the third on the list of CVs, which seems right, since the plan is only a means to an end. The reference to local and national park authorities having primary responsibility for operation of the planning system is now part of the principal policy on Engagement, and not mentioned in the CVs – that also seems right, as it’s not a “value”.

The planning service is also to be inclusive, which seems optimistic given the adversarial positions often adopted by parties. As the SPP says (but the draft doesn’t):

“It is essential to recognise that planning issues, by their very nature, will often bring differing interests into opposition and disagreement and the resolution of those issues will inevitably disappoint some parties. The planning system cannot satisfy all interests all of the time.”

It is reasonable for Core Values to be aspirational, but reality can’t be ignored.

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The consultation draft for the new SPP has been published, with responses due by 23 July, the same day consultation closes on the draft National Planning Framework 3.  Unlike the draft NPF3, which is a main issues report, and therefore more discursive, the draft SPP is in a final form.

So – first impressions:

• similar size – 264 paragraphs, the SPP has 257 – but it seems shorter, because it’s punchier
• it’s had a “corporate makeover” – there’s less planning-speak, especially at the beginning, and it’s less wordy
• more structure, with a distinction between Principal Policies and Subject Policies, and each section divided into: policy principles, key documents, and delivery (and for Subject Policy sections, there is also NPF context, and delivery is divided into development planning and development management)
• new category – “Principal Policies” – which gives a better focus than the SPP. This includes Placemaking, which has been given increased prominence by the Scottish Government since the SPP was published. Location of New Development is also a Principal Policy, including Town Centres and Rural Development moved from the Subject Policies in the existing SPP.
• Subject Policies – now sub-divided into: Buildings (homes, business and employment, historic environment), Natural Resources (natural environment, green infrastructure, extraction, aquaculture), Movement (travel), and Utilities (heat and electricity, digital communication, flood risk and drainage, waste) 

 I’m liking it so far. More reaction to follow.

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There’ more information in “Assessment of Proposed National Developments Report“, which unfortunately isn’t mentioned on the NPF webpage.  It includes an interesting commentary on the developments rejected as unsuitable for designation as national development.

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Once again, the impact is muted, because there’s no intention for NPF3 to revisit the transport infrastructure priorities identified in the Strategic Transport Projects Review and the Infrastructure Investment Plan.

The proposed national developments all relate to international connections: Aberdeen Harbour expansion (new); Grangemouth Investment Zone; additional container freight capacity on the Forth; improvements to Aberdeen, Edinburgh, Glasgow, Inverness (new) and Prestwick Airports; and High Speed Rail between Glasgow and Edinburgh, and south toward London.

Q14 poses searching questions:

• is our emerging spatial strategy consistent with the aim of decarbonising transport?
• are there any specific, nationally significant digital infrastructure objectives that should be included in NPF3?
• should NPF3 go further in promoting cycling and walking networks for everyday use, and if so, what form could this take at a national scale?

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The third is: a successful, sustainable place. This focuses on promoting high quality development and sustainable economic growth.

The feasibility of sustainable economic growth is a favourite discussion piece, but as the Report acknowledges, the role of NPF3 is to deliver Scottish Government policy, not change it.

The Report states that NPF3 can play a significant part in delivering the Strategic Priorities set out in the Scottish Government’s Economic Strategy, including supporting investment in Enterprise Areas; focussing on the renewable energy and grid infrastructure needed to help the transition to a low carbon economy; and prioritising projects like Ravenscraig and Central Scotland Green Network – both of which are suggested as national developments (CSGN is already a national development in NPF2).

Dundee Waterfront project is proposed as a national development because of “the scale of environmental, social and economic benefits”. More explanation of that justification is required.

Q11 includes “How can the strategy as a whole help to unlock the potential of our remote and fragile rural areas?”.

The housebuilding industry will be disappointed by the rejection of the proposal for NPF3 to set regional targets for housing development. However, the opportunity is taken to indicate the Scottish Government’s wish to see greater and more concentrated effort to deliver a generous supply of housing land, especially in South East Scotland.

No large scale developments are proposed to be designated as national developments on the basis of their contribution to meeting housing need. The Report says that because of the scale of the housing requirement it is not appropriate to single out for priority any particular developments. What does that mean? Is it the often debated too many eggs in too few baskets point – ie. designating national developments would tie up too much of the housing requirement in too few sites which could be slow to deliver? But if the Ravenscraig and Dundee projects are considered important enough to be given a leg-up, why not some large housebuilding projects? The lack of any housing-led national developments suggests the Scottish Government does not consider the significant need for housebuilding, acknowledged in the Report, to be as much as a priority as other forms of development.

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“A natural place to invest” is the second key priority: “Our aim is to respect, enhance and make responsible use of our natural and cultural assets”.

This is a fairly short chapter. The only specific new proposal is to designate as a national development a suite of priority projects for long-distance paths and trails.  

It does pose some questions which seem certain to set off some lobbying, for example:

Q7 “Should NPF3 propose any specific actions in relation to the role of land use in meeting climate change targets, for example woodland expansion, peatland or habitat restoration? Should the strategy be more aspirational in supporting the development of a National Ecological Network?”

Q8 “Would it be helpful for NPF3 to highlight the particular significance of habitat enhancement and compensatory environmental measures around the Firth of Forth?”.

The Report doesn’t always take a consistent approach, possibly because of poor editing. For instance, under “Tourism, recreation and the visitor economy”, there are no specific questions identified. However, there is a statement (question?) that NPF3 could highlight areas where tourism potential could be further developed, such as the Galloway and Southern Ayrshire Biosphere Reserve and Dark Skies Park. An implicit invitation for some lobbying?

On waste and resource management, the Report says there is a need to maintain a flexible, market-driven approach. However, Q10 suggests there is still room for debate: “Should NPF3 support a decentralised approach to provision for waste management or should NPF3 make provision for more strategic waste facilities?”.

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The Report says that the key questions are about the spatial implications of the existing energy policies and commitments, and what new development and infrastructure investment is needed to help deliver them. Much of the new development and investment has already been identified in the policies and commitments, so there’s no surprises. The interest is in which of the projects are prioritised as national developments:

• onshore wind – spatial guidance at a national level, including use of SNH mapping for wild land (this is also raised in the draft SPP);
• offshore renewables - key onshore infrastructure requirements to be national development;
• baseload electricity generation – national developments: Peterhead CCS project; carbon dioxide transportation hub at St Fergus; Captain project at Grangemouth (c700MWe Integrated Gasification Combined Cycle Power Station with carbon capture; Longannet and Cockenzie - new or refurbished electricity generating plant to be fitted with carbon capture technology and carbon storage facility;
• electricity transmission, distribution and storage – national development to include connections to Orkney, Shetland and the Western Isles; England; and Norway;
• gas pipeline network – enhancements recognised as a “nationally important aspiration”;
• National Renewables Infrastructure Plan (NRIP) - prioritising improvements in infrastructure it identifies, but not designating these as national developments, except the expansion of Aberdeen Harbour.

So the spatial strategy will designate national developments, but it will recognise and prioritise other developments too. It’s frustrating that there’s little explanation of the criteria used to draw this distinction, and also of what the distinction will actually mean in practice.

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In the Bova case, the main issue was whether there had been a failure to understand the potential significance of an aquifer, and the effect which the proposed development might have on groundwater flows and potential flooding to properties outwith the site.

The judges held there was no mistake of fact giving rise to unfairness. The expert advice available to the Council was there was no evidence of an aquifer and that, in any event, an aquifer would be at a depth that the development works would not affect. The design set out in the proposals was stated to be such that it would cope with groundwater from whatever source, and that it would result in an improvement in the pre-existing situation.

The other issue was whether there had been a change in planning policy between the date of the minded to grant decision and the issue of the permission.

The change was from “erring on the side of caution” to “precautionary approach”. The judges described the change as relatively minor – “fine tuning”. They held there was no real possibility that the Council would have reached a different conclusion if the reference to a “precautionary approach” had been drawn to their attention.

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New on the list:

• Onshore infrastructure for offshore renewable energy
• Grangemouth and Peterhead Carbon Capture and Storage
• National Cycling and Walking Network
• Dundee Waterfront
• Ravenscraig
• AberdeenHarbour

The MIR hints at some of the tensions in deciding which developments to add to the list. It’s disappointing that no clear criteria are mentioned. While the Dundee Waterfront and Ravenscraig projects are worthy, the reasons given for their inclusion are not particularly informative: “the scale of environmental, social and economic benefits which can be delivered” (Dundee Waterfront), and “Its scale, its links with the aspirations for the Central Scotland Green Network and the number of benefits it can provide in the heart of the Central Belt” (Ravenscraig). If scale is relevant, at what point does a project become national rather than regional?  

One of the key benefits of designation as a national development is the end of any debate about the need for the project. That may be an advantage for potentially controversial projects such as overhead power lines. For many of the other projects, which do not have widespread opposition, designation as national development appears to be more about the political advantages of getting the Government’s seal of approval.

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It’s like drinking a fine wine – you need to take time to savour the taste and identify all the flavours.

There’s a lot that sounds familiar, because it’s delivering existing sectoral policies and commitments in areas such as energy (eg. National Renewables Infastructure Plan) and transport (eg. Infrastructure Investment Plan). Also, it’s an evolution of the overall spatial strategy in NPF2, which it concludes remains essentially sound.

So it’s about updating to reflect new circumstances, challenges and opportunities, and giving even greater emphasis on ensuring that strategy is given effect through new development and infrastructure.

The 4 key priorities are expressed very differently from the 4 key aims in NPF2, but the content seems similar. The most obvious “evolution” is that low carbon is a priority in its own right, whereas previously it was part of promoting a greener Scotland.

I’m off to savour the taste of the spatial strategy for each of the 4 key priorities.

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