SP Paper 491
3rd Report, 2014 (Session 4)
Proposed National Planning Framework 3
Remit and membership
Infrastructure and Capital Investment Committee consideration
GENERAL REMARKS ON THE PROPOSED NATIONAL PLANNING FRAMEWORK 3
Timescales for scrutiny
Coordination of national planning and investment documents
Population growth and demographic change
NPF3 and climate change
Remit and membership
To consider and report on infrastructure, capital investment, transport, housing, and other matters falling within the responsibility of the Cabinet Secretary for Investment and Cities apart from those covered by the remit of the Local Government and Regeneration Committee.
Adam Ingram (Deputy Convener)
Maureen Watt (Convener)
Committee Clerking Team:
Clerk to the Committee
Senior Assistant Clerk
Proposed National Planning Framework 3
The Committee reports to the Parliament as follows—
1. The Scottish Government laid its Ambition, Opportunity, Place: Scotland’s Third National Planning Framework – Proposed Framework (NPF3)1 document before the Parliament on 14 January 2014, as required by section 3B of the Planning etc. (Scotland) Act 2006. The Local Government and Regeneration (LGR) Committee was designated as lead Committee in the scrutiny of the NPF3 and Scottish Planning Policy (SPP) documents.
2. Given the significant range of issues covered in these documents, the Infrastructure and Capital Investment Committee (ICI), Energy, Economy and Tourism Committee (EET), and Rural Affairs, Climate Change and Environment (RACCE) Committee agreed to take oral evidence from stakeholders and report separately to the Parliament their findings on topics in the NPF3 document covered by their remits.
Infrastructure and Capital Investment Committee consideration
3. At its meeting on 18 December 20132, the ICI Committee agreed its approach to scrutiny of the draft NPF3 document in relation to the policy areas covered by the Committee’s remit: transport, housing, water and broadband infrastructure.
4. To assist the Committee in developing its views on the document, the Committee invited written submissions from a wide range of stakeholders. The call for views3 opened on 14 January 2014 and ran until 30 January 2014. The Committee received 38 responses, links to which can be found at Annexe C.
5. The ICI Committee took oral evidence on the draft NPF3 at its meeting on 29 January 2014 from the following witnesses—
- Professor Glen Bramley (Heriot Watt University)
- David Connolly (Systra)
- Professor Michael Fourman (University of Edinburgh)
- Professor Geoffrey Gooch (University of Dundee)
- Derek Halden (Derek Halden Consultancy)
- John Lauder (Sustrans)
- Phil Matthews (Transform Scotland)
6. The Committee also took evidence on 5 February 2014 from Keith Brown, Minister for Transport and Veterans and Derek Mackay, Minister for Local Government and Planning.
7. The Committee is grateful to all stakeholders and witnesses for the evidence submitted to the Committee.
GENERAL REMARKS ON THE PROPOSED NATIONAL PLANNING FRAMEWORK 3
8. In scrutinising the proposed NPF3, the Committee heard from a range of stakeholders on the topics pertaining to its remit. Stakeholders also had a number of more general comments on the development, context and presentation of the document, which the Committee feels would be usefully reflected upon in the finalisation of the NPF3. These are discussed below.
Timescales for scrutiny
9. The Committee notes from evidence that the publication of the draft NPF3 has been widely welcomed by stakeholders, and that they have expressed contentment with its broad aims and objectives.
10. However, some stakeholders expressed concern at what was considered to be the short timescale available to respond to committees’ calls for views on the document, especially those stakeholders responding to multiple committees. For example, Friends of the Earth Scotland commented in its written submission that—
“scrutiny of the framework [is] even more challenging for both stakeholders and MSPs in the context of the extremely limited 60 day scrutiny period. We continue to question whether this timeframe is sufficient to adequately scrutinise a framework of such critical national importance.”4
11. The Committee notes these comments and acknowledges the challenges presented to stakeholders by the time constraints applied to the consideration of the document by the legislative framework.
Coordination of national planning and investment documents
12. The Scottish Government has opted to closely coordinate the scrutiny of the NPF3 and the Scottish Planning Policy (SPP) refresh, a move which was welcomed in evidence to the Committee. Stakeholders believed that this approach gave a clearer picture of the Government’s vision for where and how development will be delivered.5
13. However, several stakeholders believed that this approach should be taken further, and that even greater coordination of related strategic planning and investment documents was to be encouraged. COSLA suggests in its written evidence that this coordination might include the National Transport Strategy, Second Report on Proposals and Policies (RPP2) , and the Zero Waste Plan, amongst others.6 The Scottish Council for Development and Industry makes a similar suggestion in its written statement to the Committee.
14. Transform Scotland went further by suggesting that the Infrastructure Investment Plan (IIP) should also be included in coordinated scrutiny because—
“…those transport infrastructure projects which feature in the Infrastructure Investment Plan (IIP)…are effectively exempt from detailed consideration under the NPF3 process. These include most of the Scottish Government’s own major transport infrastructure projects (road and rail). We consider that this makes the NPF3 process a limited, partial, and, ultimately, unsatisfactory process.”7
15. However, in oral evidence, the Minister for Local Government and Planning, Derek Mackay, told the Committee that although the purposes of these documents were quite separate, they complemented one another, saying that—
“I stress that the proposed NPF3 supports rather than replaces the infrastructure investment plan and the strategic transport projects review.”8
16. The Minister then went on to highlight the specific value of the NPF3 document—
“NPF3 is not a spending document, but a planning document. For some people, it is an interpretation of what matters as a material consideration in the planning system; for others, it is an investment document for Scotland. I think that it very helpfully outlines where planning can add value to the system and to individual projects, where necessary.”9
17. The Committee appreciates that the various documents which make up the framework for planning and investment in Scotland have different purposes, and exist within a hierarchy. However, the Committee sees the value to stakeholders, and to an effective scrutiny process, of ensuring that the various documents which form this hierarchy contain clear and unambiguous explanations of any relevant relationships which exist between them.
18. The Committee also recommends that the Scottish Government look at how the role that each of these documents plays in the planning and investment process, and information on where they sit in the hierarchy, can be clarified in a consistent and coordinated manner for the benefit of stakeholders, and to help improve transparency. It calls on the Scottish Government to provide an appropriate narrative to this effect in the final NPF3 document.
Population growth and demographic change
19. Several written submissions asserted that population and demographic change was highly likely to impact upon current and future transport, housing and other infrastructure provision. Some stakeholders expressed their concern that the Scottish Government may not be giving these issues full consideration during the development of the NPF3 and SPP documents and that this might impact on the effectiveness of the long term planning strategies across the range of subject areas covered by them. Nestrans stated in its submission—
“National Planning Framework 3 has an important role in setting the context for development plans in Scotland and …to “inform future policies and investment decisions in areas such as transport, energy, health and wellbeing, climate change and land use” (Proposed Framework page iii). However, very little consideration is given in the Proposed Framework to the implications of the projected growth, particularly as it applies to infrastructure requirements to facilitate that growth.”10
20. Aberdeen City and Shire Strategic Development Planning Authority, Aberdeenshire Council, and Aberdeen City Council concur with this view in their written submissions.
21. This concern was raised in particular by local authorities, especially those in areas of current and anticipated population growth, for example, Aberdeen, Perth and Edinburgh.
22. In written evidence several stakeholders questioned why certain major developments were given national development status and others were not. Examples of developments cited by stakeholders included the proposed dualling of the A9, housing development in the west of Edinburgh, Edinburgh to Glasgow Improvement Project (EGIP) and rail freight infrastructure.
23. The Minister for Local Government and Planning responded to these questions in oral evidence to the Committee. He highlighted the fact that the process for the identification of candidates for national development status was an outcome from the second National Planning Framework. He added that—
“For the first time, we issued a call for national developments at the outset of the process, and more than 240 proposals were formally submitted…. Every proposal has been considered carefully, first against our published criteria and then in relation to the wider spatial strategy…. As a result, we have made choices and we have prioritised the projects that best reflect our spatial vision and which are considered to be in the national interest.”11
24. Both the Minister for Local Government and Planning and the Minister for Transport and Veterans were keen to emphasise in evidence to the Committee that national development status was conferred where it was believed that the added status would benefit the project12. The Minister for Local Government and Planning said—
“As well as that, we considered what benefit there would be from national development status—benefit could take the form of streamlining consent or of attracting wider interest, partnership or investment.”13
25. The Minister for Transport and Veterans explained, with regard to the dualling of the A9, that national development status was not required because the project was included in the IIP. He added—
“the substantive decisions have been taken on it and we will proceed with it and complete it by 2025.”14
26. The Committee also heard during this evidence session that, although the document focusses on 14 national developments, several of these are overarching developments covering a number of the smaller nominated developments. The Minister from Planning and Regeneration said—
“I emphasise that although we focus on 14 national developments, many of those bring together several individual proposals. Many other proposals are also recognised and supported within the wider strategy.”15
Current and future national developments
27. A recurring theme in stakeholder evidence to the Committee was a concern that the draft NPF3 focusses too heavily upon national developments which are already progressing, or are nearing completion.
28. City of Edinburgh Council suggested in its submission that the NPF3 document should be forward focussed—
“Whilst identifying areas for further growth, NPF3 does not contain any new infrastructure proposals. The Council submits that the NPF, in setting out its spatial vision for Scotland, should be leading the provision of infrastructure, not following it.”16
29. This was a sentiment echoed in the submission from the Royal Town Planning Institute, which stated—
“We do not want to comment on specific proposed national developments, but suggest that the long term nature of NPF3 means that it should be looking to identify those which are at the next stage to ensure that the planning system can enable them to be delivered.”17
30. However, other stakeholders suggested to the Committee that the NPF3 document should focus more on the enabling mechanisms which would allow development to take place. Derek Halden stated in evidence to the Committee—
“The major theme that is missing throughout the document is how the Government will enable the good things to happen; there is more about what the Government thinks that the good things are. It is the enabling mechanisms…that will make the difference in making connectivity happen in towns, cities, villages and islands. A lot more detail on those enabling mechanisms would help.”18
31. In oral evidence to the Committee, the Minister for Local Government and Planning responded to these concerns by noting that the NPF3 document takes account of national developments at various stages of progress—
“NPF3 expresses specifically in terms of infrastructure investment and transport what is required by the nation and where the planning system can add value and give certainty. For that reason, the iterative staged process of considering current infrastructure investments would further inform any future NPF—indeed, planning policy itself would be taken into account.”19
32. The Committee recognises that, for national development status to be effective in promoting progress around nationally important developments, the status can only be allocated to a small number of projects, although these projects can themselves encompass a large number of smaller schemes in an umbrella project. The Committee understands the Scottish Government’s rationale that the status of national development should be conferred on projects where it is judged that it would lend additional weight to the project and assist in driving development forward.
33. The Committee also recognises that stakeholders will have an interest in promoting a particular development, or in questioning the inclusion of other developments. The Committee acknowledges that more detailed information about whether the proposed projects for national development status met the necessary criteria is provided on the Scottish Government website. However, it would be in the interest of stakeholders for this additional information to be more clearly sign-posted in the proposed NPF3.20 The Committee considers that this would enhance the transparency of the NPF development process by increasing accessibility of information.
34. The Committee heard from stakeholders a concern that, although the NPF3 document sets out the wider vision for planning in Scotland, it does little to suggest how the success of the visions outlined ought to be measured, and how it would be known if a particular objective could be said to be complete.
35. Derek Halden suggested that—
“One of the greatest weaknesses in the planning framework is that it is too vague in the area of performance. When I looked at what is said about connectivity to Elgin with the A96, I thought, “How will I know whether this has been achieved?” It is so vague. What is it about? Is it about reducing travel times to the central belt or reducing travel times to Inverness and Aberdeen? Can we be a bit more specific? If we are, we will be able to go back and say, “Did it work?”21
36. Although the Committee recognises the high-level nature of the proposed NPF3 document, it supports the notion that outcome measurement is important in the establishment of the progress and success of the various national developments in helping to meet the Scottish Government’s wider objectives.
37. The Committee recommends that the Scottish Government consider the ways in which national developments’ performance outcomes can be effectively measured to ensure they help meet the Scottish Government’s objectives in terms of making Scotland a successful, sustainable place, and so on.
38. The Committee also suggests that there may be value in producing, amongst the associated documents to the finalised NPF3, a record of outcomes or progress of the national developments which appeared in NPF2 but no longer appear in NPF3, and noting against them why they have been removed. This could also be carried forward to future iterations of the NPF. The Committee is of the view that this would promote transparency and assist outcome measurement.
NPF3 and climate change
39. The Committee noted a recurring theme throughout the process of evidence taking of the concern of some stakeholders about how the national priorities and developments laid out in the NPF3 document could be reconciled to the Scottish Governments commitments, under the Climate Change (Scotland) Act 2009, to the reduction of emissions.
40. Several stakeholders also submitted evidence to the Committee commenting upon renewable energy and associated infrastructure. However, this is not an area covered by the Committee’s remit, and it would expect these particular issues to be explored by other committees involved in the NPF3 scrutiny process.
41. In the ICI Committee’s evidence taking, stakeholders raised concerns regarding the potential carbon impact of the national developments listed in the NPF3 – particularly those pertaining to transport strategy and infrastructure. This issue will be covered in more detail under the transport section of this report.
42. The ICI Committee’s focus on the NPF3 document was primarily concerned with transport issues. The Scottish Government has laid out in its NPF3 document a series of transport developments under the ‘Connected Place’ section. The Scottish Government aims to ensure that Scotland’s transport infrastructure helps create a more connected country which better allows movement. This feeds into wider aims of economic growth, another issue which is woven throughout this document.
43. The evidence heard by the ICI Committee covered all major modes of transport; including those where national development status has been allocated, and those where it has not.
44. In the NPF3, the Scottish Government details its plans for enhancements to five airports in Scotland. The Scottish Government believes that development of the airports will help drive economic growth, encourage inward investment, and will help its aim of creating a more connected Scotland. Annexe A of the proposed NPF3 lays out details of the types of expansion which are proposed.
45. During evidence taking, the Committee heard contrasting evidence about the potential value of the proposed airport development. The Committee heard from some stakeholders a degree of concern regarding both the Scottish Government’s decision to enhance five airports, and how these developments might impact upon the Government’s ability to achieve its own emissions reduction targets under the Climate Change (Scotland) Act 2009. The Committee is also aware that growth in air travel in Scotland has been greater than projected, and that growth has not been evenly spread across Scotland’s airports.
46. Phil Matthews, of Transform Scotland, argued that there was a fundamental contradiction between the logic in expanding five airports, and the Scottish Government’s view that the growth of air travel (and the impacts thereof) will be contained. He said—
“…paragraph 5.34 of the main issues report seems to suggest that, over the long term, we can contain the growth of airports, while at the same time it argues for expansion of all five airports. I just question whether those numbers stack up. We know that, in the past decade or so, growth projections that have come out of some Scottish airports have been significantly out compared with the reality. I therefore question the underpinning of the paragraph.”22
47. In contrast, Professor Geoffrey Gooch argued in his evidence to the Committee that, in light of the growth of new industries in Scotland, it would in fact be in the interests of the Scottish economy to be well connected by air routes to growing markets. As such, he accepted the planned airport expansions might be necessary, in spite of a possible impact on emissions levels—
“It is quite clear that the national planning framework has a focus on the development of relatively new industries such as the renewables industry. That is not just a Scottish or UK industry; it definitely has a global reach. In that respect, the airports are obviously completely necessary because we are looking at not just transport between Scotland and London but the opportunity to bring in business people from all parts of the world to see what is happening in Scotland.”23
48. In written evidence to the Committee, the Scottish Council for Development and Investment also welcomed the planned airport enhancements, and emphasised that good air links were vital to Scotland’s ability to compete economically in an international market. It added that the developments should be widened: “SCDI supports retaining the growth of key airports as national developments, and expanding these to include Inverness.”24
49. It was suggested in evidence that airport expansion would improve interconnectivity with international markets, and might also have the effect of reducing the carbon impact of air travel to and from Scotland. It was argued that more international flights to regional airports might result in less need for domestic connecting flights.
50. However, David Connolly expressed his concern to the Committee that an expansion of the identified airports raise the number of international destinations might not have the desired reduction in connecting flights, but might, in fact, generate more leisure flights from Scotland to these locations, thereby driving up emissions.25
51. The Committee heard about the difference in approach to air travel being adopted in some countries in Europe, where single international hubs have been identified for expansion, with surface transport hubs connecting to other major locations in the country. Professor Michael Fourman argued that having five international airports in one country may be a less favourable option—
“If the objective is to encourage international air travel, spreading one’s bets over five airports cannot be the best way to do so. Amsterdam is an international airport hub. Many people fly into Holland. Holland does not have lots of other airports that many people fly into; it has Amsterdam ... There are all sorts of economies of scale for the airlines in having a hub where they can exchange passengers and baggage between different flights.”26
52. However, the Minister for Transport and Veterans sought to clarify that airport expansion also referred to services, not just to an increase in the number of flights or runway capacity. He stated—
“It is also true to say that the expansion that is referred to … often includes things that are about customer service, better security arrangements and better customer comfort, so the expansion is of the quality of service that is offered, as well as of the air business through direct flights, which are less environmentally damaging.”27
53. The Committee acknowledges and welcomes the inclusion of the airport enhancement proposals contained in the draft NPF3, in simple economic development terms. However, it would also urge caution, given the potential for increased greenhouse gas emissions from airport expansion to undermine the Scottish Government’s efforts to meet its own ambitious emissions reduction targets.
54. The issue of surface access was a recurring theme in evidence, and the Committee heard a significant amount volume of evidence from stakeholders regarding surface access to Glasgow Airport.
55. Stakeholders, especially those in the west of the country, expressed disappointment that the importance of improvements to surface access systems had been, in their view, down-graded since NPF2. Renfrewshire Council noted that surface access around airports does not only impact upon the airport, but also upon the economic and social development of the surrounding areas. It stated in its written evidence to the Committee that—
“Surface access improvements have been consistently part of the NPF since its first iteration and Glasgow seems to be the sole Scottish airport where a solution to these issues has not been delivered. It is welcomed that the business and economic development potentials of land surrounding the airport are recognised by the proposed NPF. However, these opportunities are just as affected by access issues as the airport.”28
56. This was a point supported by the Scottish Council for Development and Industry—
“The focus on airports must not be restricted to the airport master-plans themselves, and should include their surrounding areas and transport connections with the airports, to encourage the delivery of their full potential in supporting economic growth.”29
57. In his evidence to the Committee David Connolly, of Systra, suggested that airport infrastructure and surface access issues were fundamentally interlinked, and should not be treated separately. He stated—
“On the point about connectivity and airports, I think that it is a mistake to separate surface access from airports. If someone comes in on business and arrives at the airport but does not know how to get to, or cannot find their way to, their meeting or the city centre, or if they go for a taxi and fall into a pothole somewhere at the gate of the airport because the link has not been made, that creates a bad perception.”30
58. The Minister for Transport and Veterans wished to reassure the Committee and stakeholders that surface access had not been downgraded, and that in the case of Glasgow Airport, work was being undertaken on a surface access strategy. He noted—
“We have enhanced the designation for Glasgow airport in NPF3, but we recognise that this is not always about what the Government does. We are a partner in the study that the airport is taking forward, and nothing in NPF3 precludes us from taking forward anything that comes from that study. However, NPF3 is much more about enabling the creation of an environment in which such things can be taken forward. There is no downgrading of the issues that we are looking at in relation to surface access.”31
59. Following this evidence from the Minister for Transport and Veterans, the Scottish Government announced that it was considering the viability of tram access to Glasgow Airport to improve surface access to the city centre.32
60. The Committee recognises the importance of good surface access systems in making best use of Scotland’s airports. By ensuring that different transport modes are more effectively interconnected the Scottish Government will be working toward its objective of creating a more connected country, and also reducing the need for domestic flights, which are believed to contribute to the burden of emissions which are to be reduced significantly under the Climate Change (Scotland) Act 2009.
61. The Committee awaits the outcome of the Glasgow airport study with interest, and would welcome an update from the Minister for Transport and Veterans following its publication.
62. During the evidence taking process, the Committee heard several concerns from stakeholders regarding rail developments in the draft NPF3. These related to the Edinburgh to Glasgow Improvement Project (EGIP), the proposed high--speed link between Edinburgh and Glasgow, and wider rail improvement projects in Scotland.
63. In section 5 of the proposed NPF3, the Scottish Government lays out its vision for the role rail travel will play in a more connected Scotland, with a High Speed Rail route being considered between Glasgow and Edinburgh as part of a longer term development of a route to London. The proposed framework also highlights the wider rail improvement plans for the rail network in Scotland, as covered in the Infrastructure Investment Plan (IIP).33
64. In written evidence to the Committee, stakeholders raised concerns that the business case for the Edinburgh to Glasgow high speed project had not yet been established. The Scottish Council for Development and Industry stated—
“the strength of the business case for a standalone Edinburgh-Glasgow high speed link is yet to be established, and this link should not be prioritised above other improvements to the rail network in Scotland, including the electrification of the network and improvements in journey time from the central belt to Aberdeen and Inverness.”34
65. This was a view echoed in the coordinated submission from Aberdeen City Council, Aberdeenshire Council, Aberdeen City and Shire Strategic Development PA and Nestrans—
“Although there is currently no published justification or business case for this project, prioritising it ahead of relatively modest improvements to the very slow journey times from Aberdeen to Inverness and Aberdeen to the central belt does not appear justified.”35
66. The Minister for Transport and Veterans, in evidence to the Committee, sought to reassure that the business case for the Edinburgh to Glasgow high-speed rail line was in development, and that the EGIP project was being taken into account—
“That should come to ministers in the next few weeks and will give us more certainty about how we intend to take it forward. In considering the Edinburgh to Glasgow rail improvement project, for example, we have taken into account that the high-speed link may happen. However, we should not get involved in a lot of expenditure or plans in respect of high-speed rail that would supersede the Edinburgh to Glasgow improvement project.”36
67. The Committee notes the concern of stakeholders that the business case for a high speed line between Edinburgh and Glasgow, in advance of the wider UK high speed rail project, has not yet been published.
68. However, it welcomes the indication from the Minister for Transport and Veterans that the business case will come before Ministers shortly. The Committee recommends that the Scottish Government, in considering the business case, take account of the concerns raised in relation to the impact the Edinburgh to Glasgow high speed rail plan might have upon the EGIP project, and the Scottish Government’s commitment to wider rail improvements across Scotland.
69. The Committee requests that it be kept informed of decisions following discussion of the Edinburgh to Glasgow high speed rail business case.
Sea port developments
70. The proposed NPF3 document details three sea port national developments at section 5.20 and 5.21: Grangemouth Investment Zone, Freight Capacity on the Forth, and Aberdeen Harbour. The Scottish Government sees these ports as gateways to Scotland, and as a vital part of Scotland’s economic future
71. Stakeholders were generally welcoming of all three sea port developments. The Scottish Council for Development and Industry noted in its written statement to the Committee that consideration will need to be given in the future to how freight is distributed once it reaches port, and raised short-sea shipping as a viable option. The SCDI states in its submission—
“Despite the prominence of ports in the Proposed NPF3, no mention is made of short-sea shipping. This is a mode that has considerable potential given the number and distribution of ports around Scotland and the UK, both for distributing goods throughout the UK, but also to Europe.”37
72. With regard to Grangemouth, Councillor Joan Paterson raised concern about the additional freight handling capacity anticipated. Councillor Paterson welcomed the acknowledgement in section 3.40 of the impact upon the community and the expectation that consideration would be given to the environment and quality of life of residents. She expressed the view that this should be strengthened by the addition of appropriate caveats at Annexe A of the proposed NPF3.
73. The Committee welcomes the inclusion of three sea port developments in the draft NPF3. However, it also notes concerns about the potential impact on the environment and local residents of such developments. It therefore recommends that the Scottish Government consider whether section 3.40 of the document, which addresses these issues, might be strengthened.
74. The Committee also notes the suggestion made in evidence that short-sea shipping has potential to make a greater contribution to Scotland’s economy. The Committee is of the view that this ties in with other proposals for developing freight distribution mechanisms such as rail freight, which is discussed below.
75. At section 5.18 the proposed NPF3 document acknowledges that rail freight will become increasingly important “as our export potential grows.”
76. The Rail Freight Group (RFG) highlights in its submission that the combined throughput of the railheads at Coatbridge, Grangemouth, and Mossend is already similar to that of the port of Grangemouth.
77. Both the Rail Freight Group and Transform Scotland, in their submissions, suggest that the acknowledged importance of rail freight in the futures at odds with the lack of national developments in this area, when compared to the status given to several deep-sea harbour projects. Transform Scotland stated—
“…we see a discrepancy between there being three sea freight proposals against the absence of any rail freight proposals.”38
78. The Rail Freight Group, in its submission to the Committee, acknowledges that the Grangemouth Investment Zone and Freight Handling Capacity on the Forth includes rail developments but argues that—
“…from a strategic Scottish perspective, rail freight should not be seen simply as an adjunct to shipping.”39
79. Following the conclusion of evidence taking, the RFG received information from the Scottish Government which it suggests would support its view that there is a strong case for the promotion of rail freight developments in Scotland, with scoring being equal to that of two of the sea ports awarded national development status.40
80. The Committee acknowledges the important role rail freight will play in Scotland’s future, and welcome’s the Scottish Government’s recognition of this in the proposed NPF3 The Committee also notes stakeholders’ concern that rail freight may not be receiving a level of Scottish Government consideration comparable to that afforded to sea freight related projects.
81. Whilst, the Committee recognises the Scottish Government’s position that national development status is conferred where that status is deemed to be vital to driving development forward, it recommends that the Scottish Government consider whether national development status in relation to rail freight developments might be made in future iterations of the NPF. The Committee is of the view that the case for its inclusion in future NPF documents is strengthened by the current parity of scoring against sea port developments appearing as national developments in the proposed NPF3.
82. Given that the NPF is a document which aims to look forward to identify key developments in the next 30 years, the Committee considers it to be important that full consideration is given by the Scottish Government to the future contribution that increased freight capability – rail freight and short-sea shipping have been highlighted in evidence – might make to assist it in meeting its wider objectives regarding enhanced connectivity and, importantly, sustainability.
83. In section 6.6 of the proposed NPF3, the Scottish Government sets out its vision for a National Long Distance Cycling and Walking Network. The Scottish Government envisages the network supporting the wider adoption of active travel, promoting tourism, and improving visitors’ experience of their environment.
84. The Committee heard that stakeholders widely welcomed the inclusion of the National Long Distance Cycling and Walking Network as a national development, and saw it as a positive move, and a step forward from NPF2. However, stakeholders suggested that it may not greatly assist in achieving a modal shift towards active travel on a day to day basis. Transform Scotland, Spokes, and Sustrans argued in their written submissions that—
“we would note that while this project can be expected to assist with the development of leisure cycle tourism and leisure walking, we do not expect this National Development to lead to significant increases in day-to-day levels of walking and cycling.”41
85. In evidence to the Committee, the Minister from Transport and Veterans reiterated the funding which had already recently been made available for active travel projects. He stated—
“We said to individual councils and others who asked about it that it is done through Sustrans, with money that we allocate to it for such projects. Local authorities must come forward with their proposals and work with Sustrans. Our role is in relation to funding. The Edinburgh project is intended to be an exemplar project from which other authorities can learn lessons.”42
86. Another development in active travel which was widely welcomed was the proposal in section 5.26, which looks for local authorities to “identify one walking- and cycling-friendly settlement where accessibility will be significantly improved by 2030”43. John Lauder suggested in his evidence to the Committee that the proposal at section 5.26 could be effectively combined with the proposal at section 4.13 and that—
“The proposal could be to have a sustainable transport town in each local authority area. That would be aimed at a green transport future and would encourage people to be more active. That proposal could be strengthened, certainly from an active travel perspective, by placing an emphasis on behaviour change through engagement with people.”44
87. However he also raised questions about the logic of the 2030 target date. He stated—
“I do not understand the 2030 date. It does not fit in with the cycling action plan, which is to have 10 per cent of trips made by bike by 2020.”45
88. In response to John Lauder’s point, the Minister for Transport and Veterans was keen to emphasise the necessity of a partnership approach to such projects and an awareness of wider economic circumstances, which guided the proposed date of 2030. He stated—
“As with many areas, the date will be dictated partly by the resources that are available. The committee has seen fairly strong evidence for an additional commitment from the Government. If we have additional resources, we can take that forward. I emphasise that, as I think John Lauder is aware, such commitments involve a partnership. The Government is not simply saying that it will do something; we are not saying to councils, “We’re coming to your area to do this active travel project.” ”46
89. The Committee asked whether there was an opportunity to give more guidance to local authorities on encouraging a modal shift to active forms of transport. The Minister for Local Government and Planning agreed that there was a need for greater guidance and committed to issuing this. He told the Committee—
“Having conducted…a roadshow to every planning authority in the country, I am aware that there is a need for greater guidance, so that planners know more clearly what is required of them. For that reason I will commit, once we have concluded NPF3 and SPP, to issuing further guidance. We will have to refresh and update the policies, and perhaps we will give a bit more clarity, as you request, around what issues they should take into account.”47
90. The Committee welcomes the inclusion in the draft NPF3 of the National Long Distance Cycling and Walking Network as a national development. It also welcomes the Scottish Government’s proposal for active-travel friendly settlements, and believes that there is a wide range of potential benefits to local communities in terms of environment, health, safety and achieving modal shift. The Committee also acknowledges and welcomes the Scottish Government’s willingness to consider committing further resources to this initiative should these become available.
91. The Committee also welcomes the commitment by the Minister for Local Government and Planning to issue further guidance to local authorities regarding planning for active travel friendly communities. It recommends that this also include guidance on how wider modal shift such as to sustainable public transport might be incorporated more effectively into the planning system. The Committee also recommends the Scottish Government consider the viability of Sustrans’ proposal that sections 4.13 and 5.26 be combined.
92. Patricia Ferguson MSP attended the Committee’s evidence session on 5 February 2014 and expressed disappointment that the Glasgow Canal partnership, located in her constituency, had not received mention in the proposed NPF3, although it had previously appeared in NPF2. She argued that this was and would continue to be a long-running project, and subject to a great deal of investment. She added that, since the publication of NPF2, the project had become more ambitious, and as such should feature in the proposed NPF3.
93. The Minister for Transport and Veterans responded, indicating that he was unsure whether mentioning the project in the proposed NPF3 would add value. He stated—
“Quite a lot of the canal regeneration that was referred to in the previous document has already been carried out; indeed, it is part of a wider national regeneration strategy for Scottish Canals, including work from Inverness across the country to Fort William as well as in Falkirk. Those projects are equally significant.”48
94. The Minister for Local Government and Planning added—
“The question I come back to is whether the project itself requires the national planning framework in order to achieve planning progress. I do not believe that that is essential for the project, but I appreciate that the member would like it to be included.”49
95. Both the Ministers agreed that a mention of this project could be included in the document, and would ‘fit with the current narrative’, providing the Committee was happy to recommend it.
96. The Committee welcomes the update from the Minister for Transport and Veterans that the canal regeneration work set out in the NPF2 is now at an advanced stage. It also welcomes Ministers’ willingness to consider the inclusion of a reference to the Glasgow Canal Partnership project in the finalised NPF3 document.
97. The proposed NPF3 acknowledges the need for new housing, especially in areas of high demand, and the Scottish Government’s commitment to meeting housing need across the country (NPF3, section 2.5, p4). However, as it stands, the proposed NPF3 document contains no specific housing projects with national development status, although the issues around housing and planning are woven throughout the document.
98. The Committee asked the Minister for Local Government and Planning what would constitute a housing national development, and the Minister replied—
“We do not have a definition for the purposes of NPF3. There are criteria in relation to a range of indicators that determine whether a project has that status. It is not just about how many houses are involved. If a development met a few of the criteria, it might be able to feature.”50
99. The Minister went on to suggest that the Ravenscraig national development might be considered to meet the criteria for a national housing development insomuch as it is a large regeneration project which will feature a significant number of residential properties. He stated—
“That is a national development because it is mixed use. I disagree that there are no housing developments; it might just be that housing is connected to the project as a whole.”51
100. He went on to add—
“Our policies are incredibly supportive of house building and growth in Scotland. Households are becoming smaller, so we will require more houses. All the housing demand needs assessments tell us that there is housing demand. Building will happen at a different pace in different parts of the country.”52
101. Currently, the Scottish Planning Policy holds that local authorities should ensure that a plan-led housing system is in place to determine the location and sustainability of housing developments in their area.
102. Phil Matthews noted in evidence that suitable guidance was in place, but he was of the view that it was not being used in practice. Using the example of location of housing with regard to access to public transport he said—
“What is striking is that albeit people have said that the guidance is fairly weak—it does not require the location of housing in the most suitable and sustainable locations—the guidance is clear in the SPP, in the planning policies, and in NPF3 about locating new development around decent public transport and integrating it with walking and cycling. However, the reality is that that is not happening—that guidance is not being followed.”53
103. The Minister for Local Government and Planning said—
“We hold that the plan-led system—where the planning authority has suggested development should go—should be the foundation of the planning system. That said, developments do not have to happen within a particular zone if material considerations allow you to depart from the plan, and that is made all the more vulnerable if a planning authority does not have a robust, credible and up-to-date local development plan, which, unfortunately, is still the case for far too many planning authorities. The law says that a development plan should be less than five years old. It may surprise you to learn that almost half of them are more than five years old.”54
104. The Committee is concerned that if planning for housing development rests so heavily on a plan-led system, and local authority plans are out of date, the credibility of this system could be undermined and left open to exploitation.
105. The Committee recommends that the Scottish Government work with local authorities to ensure their housing plans are updated in line with legislative requirements. The Committee considers this to be essential if local authorities are to be positioned to effectively meet the housing needs of the people in their area, taking into account the prevailing economic, social and environmental circumstances.
106. One of the major concerns heard by the Committee, cited as a constraint on housing development, especially in areas of growing population density, is the pressure created on existing infrastructure and the cost of developing new infrastructure to meet additional need.
107. Section 2.18 outlines the Scottish Government’s position that it is expected that planning authorities, developers, government agencies and infrastructure providers will make “more concerted efforts… to remove these constraints”.55 The Scottish Government also takes the view that the most viable and sustainable solutions to overcome infrastructure constraints will make use of existing infrastructure, but that new infrastructure provision could be considered in some cases.
108. The Committee heard that housing developments planned for the west of Edinburgh in particular have been highlighted as requiring additional infrastructure considerations. One of the core issues raised by witnesses in their evidence to the Committee was the question of ‘who pays?’ for infrastructure developments. There was no clear consensus in evidence, with different groups of stakeholders suggesting different approaches.
109. City of Edinburgh Council was of the view that Scottish Government funding should help meet infrastructure development costs, which was echoed in the coordinated responses from Aberdeen Council, Aberdeenshire Council, Nestrans, and Aberdeen City and Shire Strategic Development Planning Authority, which also expresses criticism of the Scottish Government’s response to infrastructure constraints. They state—
“…the Scottish Government’s response to this issue is limited to an Action Programme reference to sharing best practice. This is not an appropriate response to an issue which has the potential to significantly undermine the ability to deliver growth and it requires more considered treatment in NPF3 and its Action Programme if the growth objectives of the framework are to be achieved.”56
110. However, other witnesses suggested that where additional pressures on infrastructure are created by increased housing development the cost of additional infrastructure provision should be met differently. Professor Glen Bramley suggested that developers could be expected to meet the cost of provision. Using the example of the Shawfair development in the south east of Edinburgh, he stated—
“I suspect that a lot of these problems are around questions of who is expected to pay for it, with a continuing expectation in many quarters that the government will pay for most of it…In high demand/high value areas, the developments should pay for it, through tariffs and planning agreements…. Once this expectation becomes clearly established, the cost of this will fall on the residual land values, not households or businesses.”57
111. However, the Minister for Local Government and Planning was of the view that current systems for infrastructure cost mitigation in response to new developments are already effective. He stated—
“The planning system already demands that where there is a question about infrastructure contribution, any required mitigation is delivered through the planning obligations or sometimes the conditions. Where development requires infrastructure improvement to make it happen, that is delivered at the moment. You might question some of the decisions that planning authorities take, but that is already a requirement in the planning system.”58
112. In terms of the infrastructure costs incurred by increased development, the Committee asked the Minister whether there was a need for a mechanism to enable infrastructure works to be funded by the developer or landowner, and whether the Government was considering that. The Minister responded that—
“It depends on the nature of the application and the nature of the development…It is still a matter for the planning authority, but generally the approach would be to require the full cost of the development. …It should really be a question of what mitigation is required to allow the development to happen. Generally, full cost is required, but sometimes there is flexibility, although that is for the planning authority to determine and it might allow flexibility for a range of reasons.”59
113. The Committee is of the view that pressure on existing infrastructure can only be expected to increase, especially if the Scottish Government’s wider objective of meeting housing demand is to be met. The Committee also understands from evidence that a great deal of confusion exists around where the responsibility of funding infrastructure developments sits.
Land and housing supply
114. Paragraph 2.17 of the draft NPF3 lays out the Scottish Government’s understanding of population shift, and the resulting pressure this can put upon particular areas, especially in cities. The document highlights that “there will be a need to ensure a generous supply of housing land in sustainable places where people want to live, providing enough homes, and supporting economic growth.”60
115. Stakeholders agreed with the Scottish Government’s view on land supply for housing, but wished to reinforce the application of a planned approach. Professor Glen Bramley stated in his evidence to the Committee that—
“the locations of major future housing developments should be determined through the forward planning part of the statutory planning system, not through individual applications or appeals.”61
116. He added—
“There is a considerable need for additional houses in some parts of the country and it is unrealistic to think that those can all be built on brownfield land. There is some greenfield land that is not of particularly high value ecologically or in its present use, and in some cases the best option might be to provide housing on that greenfield land.”62
117. West Dumbartonshire Council suggested that the NPF3 may have a role to play in suggesting the types of strategy which might be most appropriate in different areas. In its written submission to the Committee it suggested—
“The National Planning Framework, being a spatial document could set out that different approaches to settlement strategies would be appropriate for different parts of the country. For example, suggesting a greater focus on previously developed land in the west of Scotland.”63
118. The Committee asked the Minister for Local Government and Planning whether he saw any conflict between the various bodies of advice and policy on redevelopment of brownfield sites and use of greenfield land and marketability. He responded—
“I think that they are compatible, because the hierarchy starts with NPF3 and SPP, and the planning advice notes are to advise those making decisions on what should be taken into account. When producing plans on the generous supply of housing land and sustainable places, it would be unfair to developers and to communities to have whole tracts of land that were not developable, either because there was no demand or because they were contaminated or too complex. It would be pointless having a land supply system if you could not actually market the houses.”64
119. The issue of housing supply is closely tied to the issue of land supply for housing, in terms of type and location of housing.
120. Paragraph 2.19 of the proposed NPF3 document suggests that more high-density housing in urban areas and areas well served by public transport could absorb much of the expected growth in urban centres. Professor Glen Bramley, however, disagreed with this. He stated—
“Evidence on social sustainability, general preferences or market values does not support a predominant pattern of high density flatted development, although there is support for medium density mixed housing types.--”65
121. City of Edinburgh Council, in its submission, added that even an emphasis on high density housing was still unlikely to meet demand—
“The Council fully supports the concept of a compact city and in the urban area it requires all sites to be used to their full potential. However the housing requirement is so large that brownfield land, even at high densities, cannot possibly accommodate it.”66
122. Amnesty was more critical in its written submission to the Committee, stating that the proposed NPF3 does not provide any new mechanism by which housing shortages in Scotland can be addressed. It states—
“Without this, little change can be expected and there is little chance of a positive move towards the realisation of the right to adequate housing.”67
123. It also highlights that no consideration is given to the supply of housing specific to the needs of people with disabilities.
124. The Committee asked the Minister for Local Government and Planning whether there was a role for the planning system and planning guidance in setting a level for what would represent a fair return on a developer’s investment. The Minister responded that this was not a route which the Scottish Government considered it appropriate to pursue. He responded—
“It is not for the planning system to make any judgment on what profits someone is making. It is for the planning system to get the right developments in the right places, to meet local and national needs and to do that in a fair and transparent way…”68
125. The Committee asked the Minister for Local Government and Planning whether regional housing supply targets should be in the NPF rather than in strategic development plans. The Minister responded—
“We have commissioned work on strategic development plans and the added value that they provide to the system. Right now, housing need is determined through local authorities’ assessments, and local authorities deliver housing as part of the development plan process. The approach broadly works well.” 69
126. The Committee acknowledges the Minister’s view that local authorities are best placed to decide what type of housing is required in their areas and where it should be situated to most effectively meet demand.
127. The Committee is concerned, however, by evidence which suggests that even a focus on high-density housing developments (for example on urban brownfield sites) in areas of high demand, might not be enough to ensure that demand was met, and that appropriate consideration may not have been given to the housing needs of vulnerable groups.
128. The National Digital Fibre Network has been designated as a national development, and is listed under the ‘Connected place’ chapter of the proposed NPF3 document. The Scottish Government envisages better access to broadband across the country as being a means by which to create a more connected country. It is also anticipated that broadband infrastructure development will have a positive impact both economically and environmentally.
129. Stakeholders broadly welcomed the inclusion of digital in the proposed NPF3, and recognised the benefits it may bring across the country. BT Scotland, as the provider contracted to carry out the major digital infrastructure project under the Step Change programme, was welcoming of the national development status. In its written submission to the Committee, BT Scotland stated—
“By being classified as a national development the planning and consent regime recognises the established need for these developments. This is important as the majority of the subsea cabling will be laid within a 6 month weather window in summer 2014. To deliver the project on time and to reach the coverage targets for the project, the installation of the subsea cables is essential.”70
130. David Connolly of Systra highlighted to the Committee that the benefits of improved digital broadband infrastructure would be felt particularly in rural areas of the country, where an equality of impact in transport development may be hard to achieve. He noted that—
“In a situation that is almost the opposite of a cluster, the wider that you can spread the digital investment, the better, as people in remote and rural areas are the ones who will benefit from not having to travel. No matter how much you spend on some of those communities, they will still be a long way from the central belt, and if people do not have to travel because they have good digital connectivity, they can join meetings by videoconference and so forth. That is much better than trying to provide an equally good dual carriageway all the way to Wester Ross.”71
131. However, some stakeholders felt that digital matters had not been considered in sufficient depth. Regarding the rollout of broadband infrastructure projects in Scotland, Professor Michael Fourman was critical in particular of what he considered to be the lack of detail about how the new digital infrastructure would be accessed. He stated—
“More attention is required for the way in which the infrastructure gets used within the strategy…We need to ensure not only that the infrastructure is in the ground, which is much to be welcomed, but that it is accessible to lots of different businesses in lots of different ways. I do not think that that will happen naturally.”72
132. The other area of criticism the Committee heard regarding broadband links with housing issues. Professor Fourman stated in his evidence to the Committee that there were still cases where houses and business parks were not being fitted with the infrastructure necessary for high--speed internet connections—
“At the moment, it often happens that we still put in copper connections when we build new things because there is no national guidance on the matter and there is no incentive for the provider to provide new fibre connections because the exchange might need upgraded before they can do it. We need to ensure that fibre goes into the premises in a new housing or, in particular, business development because that is future proof. That could be achieved through planning.”73
133. This was a point echoed in BT Scotland’s written submission to the Committee, which stated that BT Scotland was in discussion with the Scottish Government to establish how planning can mitigate this. BT Scotland added—
“BT Scotland would support sensible measures, via the planning system, that would require future developments to provide the necessary civil engineering to ensure future fibre connectivity.”74
134. In his evidence to the Committee, the Minister for Local Government and Planning responded that it was not the role of the NPF3 and planning policy to be prescriptive about the details of these housing and business developments, but that he understood the rationale for the argument—
“We have to be mindful of what NPF3 and planning policy are about. Really, they are about decisions on land use; they are not necessarily about the quality of the product, although I agree that it is a fair assumption and expectation that the developer will provide the infrastructure for a development to be connected…Planning involves a decision around land use and not necessarily the internals of a property. I absolute agree with the sentiment, but I think that developers should consider best practice in that regard...”75
135. The Committee welcomes the inclusion of the National Digital Fibre Network as a national development, and recognises the important role this project has to play in supporting the Scottish Government’s vision of a ‘connected’ Scotland. The Committee also recognises the positive social and environmental impacts which improved broadband access will support.
136. The Committee agrees with stakeholders and the Minister that it is essential that access to digital fibre connections be available at a local level throughout Scotland. The Committee also acknowledges that it is not for the proposed NPF3 to prescribe on access to fibre connections at a local development level.
137. However, the Committee queries whether assuming developers will adopt best practice in this regard is sufficient, and recommends that the Scottish Government examine ways in which developers can be more actively required through the planning system to ensure that appropriate digital connectivity measures feature in all proposals for new developments.
138. The draft NPF3 proposed one national development relating to water issues: the Metropolitan Glasgow Strategic Drainage Partnership. This has been given national development status as an exemplar of the Scottish Government’s strategy to tackle the impacts of climate change.76
139. This £250m drainage project in Glasgow has been widely welcomed, especially by stakeholder groups in and around Glasgow itself.
140. However, some stakeholders felt that more emphasis on the interconnectedness of different catchment aspects of the water cycle and recognition of the role changing land use has upon natural water drainage patterns was important.. Professor Geoffrey Gooch stated in evidence he wanted to see closer connection between three areas in his evidence to the Committee—
“Those areas are flood defence…ecosystem services and river basin management plans…I think that it could be made clearer that flood defence starts way up in the catchment, and not at the point of problematic issues when the flood happens… we would like to point out that the increase in floods has a lot to do with land use up in the catchments, and one of the ecosystem services is flood prevention or flood minimisation.”77
141. However, the Minister for Local Government and Planning was of the view that the Scottish Government’s response to the potential challenges presented by climate change in terms of flooding was proportionate, and that lessons were being learned from experiences south of the border during recent flooding events. He stated—
“As we embrace the challenges and ramifications of climate change, the planning system will have to be quite adept. I do not concur with the view that we have not taken such matters into account. Of course, what is appropriate for NPF3 is quite different from how we engage with matters in SPP. We would expect not only an environmental impact assessment but any assessment to take such issues into account.”78
142. The Committee welcomes the Minister’s assurances that flood mitigation and climate change were being considered fully as part of the SPP.
143. The Committee agrees that there is a need to understand the impact of land-use in catchment basin systems, especially in the light of changing climate systems. The impacts of the recent flooding events in the south of England highlight the importance of this. However, this is a matter which falls into the remit of the Rural Affairs, Climate Change and Environment Committee, which has taken evidence on flooding, climate change and resilience as part of its scrutiny of the proposed NPF3.
144. The ICI Committee, along with the Economy, Energy and Tourism Committee; the Local Government and Regeneration Committee and the Rural Affairs, Climate Change and Environment Committee, look forward to the final NPF3 and SPP reflecting its views and recommendations. The Committee also looks forward to the positive impact both documents will have on its work in the coming years.
ANNEXE A: EXTRACTS FROM THE MINUTES OF THE INFRASTRUCTURE AND CAPITAL INVESTMENT COMMITTEE
27th Meeting, 2013 (Session 4) Wednesday 18 December 2013
5. National Planning Framework 3: The Committee considered and agreed its approach to the scrutiny of the National Planning Framework 3.
3rd Meeting, 2014 (Session 4) Wednesday 29 January 2014
2. Draft Third National Planning Framework: The Committee took evidence from—
Professor Glen Bramley, Director, Institute for Housing, Urban and Real Estate Research, Heriot Watt UIniversity;
David Connolly, Director for Technical Development, Systra;
Professor Michael Fourman, Professor of Computer Systems, University of Edinburgh;
Professor Geoffrey Gooch, Chair of Water and Environmental Policy, Scottish Centre for Water Policy;
Derek Halden, Consultant, Derek Halden Consultancy;
John Lauder, National Director for Scotland, SUSTRANS;
Phil Matthews, Chair, Transform Scotland.
4th Meeting, 2014 (Session 4) Wednesday 5 February 2014
2. Draft Third National Planning Framework: The Committee took evidence from—
Derek Mackay, Minister for Local Government and Planning,
Keith Brown, Minister for Transport and Veterans,
David Anderson, Head of Planning and Design, Transport Scotland,
Fiona Simpson, Assistant Chief Planner, and;
Helen Wood, Principal Planner, Scottish Government.
4. Draft Third National Planning Framework (in private): The Committee considered the evidence heard at Item 2 on the Draft Third National Planning Framework.
7th Meeting, 2014 (Session 4) Wednesday 5 March 2014
4. Draft Third National Planning Framework (in private): The Committee considered a draft Stage 1 report and agreed to consider a revised draft at its next meeting.
8th Meeting, 2014 (session 4) Wednesday 12 March 2014
6. Draft Third National Planning Framework (in private): The Committee agreed a revised draft report.
ANNEXE B: ORAL EVIDENCE AND ASSOCIATED WRITTEN EVIDENCE
3rd Meeting, 2014 (Session 4) Wednesday 29 January 2014
Professor Glenn Bramley
4th Meeting, 2014 (Session 4) Wednesday 5 February 2014
ANNEXE C: OTHER WRITTEN EVIDENCE
Supplementary Written Evidence—
1 Scottish Government. (2014) Ambition, Opportunity, Place: Scotland’s Third National Planning Framework – Proposed Framework. Available at: http://www.scotland.gov.uk/Publications/2014/01/3724 [Accessed 13 February 2014]
2 Scottish Parliament Infrastructure and Capital Investment Committee. Minute, 18 December 2013.
3 Scottish Parliament Infrastructure and Capital Investment Committee. Call for views on the proposed Third National Planning Framework. Available at: http://www.scottish.parliament.uk/parliamentarybusiness/CurrentCommittees/71965.aspx
4 Friends of the Earth Scotland. Written submission, p1.
5 COSLA. Written submission, p 1.
6 COSLA. Written submission, p 1.
7 Transform Scotland. Written submission, p1.
8 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2543.
9 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2544.
10 Nestrans. Written submission, p1.
11 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Cols 2542-2543.
12 Scottish Government. (2014) Ambition, Opportunity, Place: Scotland’s Third National Planning Framework – Proposed Framework. P 41.
13 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Cols 2542-2543.
14 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2547.
15 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2543.
16 City of Edinburgh Council, written submission, p 2.
17 Royal Town Planning Institute, written submission, p 2.
18 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2493.
19 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2544.
20 Scottish Government. (2013) NPF3 & SPP Review: NPF3 documents – Full analysis table. Available at: http://www.scotland.gov.uk/Topics/Built-Environment/planning/NPF3-SPP-Review/NPF3-documents/Full-analysis-table [Accessed: 6 March 2014]
21 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2492.
22 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2495.
23 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2496.
24 Scottish Council for Development and Industry. Written submission, p3.
25 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2499.
26 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2499.
27 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2550.
28 Renfrewshire Council, written submission, p1.
29 Scottish Council for Development and Industry., written submission, p3.
30 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2499.
31 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Cols 2550-2551.
32 The Scotsman, 28 February 2014. Trams considered for Glasgow Airport. Available at: http://www.scotsman.com/news/transport/trams-considered-for-glasgow-airport-rail-link-1-3322620 [Accessed: 1 March 2014]
33 Scottish Government. (2014) Ambition, Opportunity, Place: Scotland’s Third National Planning Framework – Proposed Framework, p38.
34 Scottish Council for Development and Industry. Written submission, p4.
35 Aberdeenshire Council. Written submission, p2.
36 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2545.
37 Scottish Council for Development and Industry. Written submission, p5.
38 Transform Scotland. Written submission, p2.
39 Rail Freight Group. Written submission, p1.
40 Rail Freight Group. Written submission, p4.
41 Transform Scotland. Written submission, p1.
42 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Cols 2546-2547.
43 Scottish Government. (2014) Ambition, Opportunity, Place: Scotland’s Third National Planning Framework – Proposed Framework, p39.
44 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2486.
45 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2504.
46 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2548.
47 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2558.
48 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2565.
49 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2564.
50 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2560.
51 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2559.
52 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2559.
53 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2513.
54 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2554.
55 Scottish Government. (2014) Ambition, Opportunity, Place: Scotland’s Third National Planning Framework – Proposed Framework, p7.
56 Aberdeen City and Shire Strategic Development Planning Authority, written submission, p2.
57 Prof Glen Bramley, written submission, p3.
58 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2553.
59 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2553.
60 Scottish Government. (2014) Ambition, Opportunity, Place: Scotland’s Third National Planning Framework – Proposed Framework, p6.
61 Professor Glen Bramley. Written submission, p3.
62 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2509.
63 West Dunbartonshire Council. Written submission, p7.
64 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2554.
65 Professor Glen Bramley. written submission, p3.
66 City of Edinburgh Council. Written submission, p3.
67 Amnesty International. Written submission, p2.
68 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2557.
69 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2559.
70 BT Scotland. Written submission, p1.
71 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2494.
72 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Col 2487.
73 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Cols 2508-2509.
74 BT Scotland.Wwritten submission, p2.
75 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2551.
76 Scottish Government. (2014) Ambition, Opportunity, Place: Scotland’s Third National Planning Framework – Proposed Framework, p32.
77 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 29 January 2014, Cols 2488.
78 Scottish Parliament Infrastructure and Capital Investment Committee. Official Report, 5 February 2014, Col 2561.
Back to top