APRS Resources

Response for Call for Ideas on planning evaluation framework

We were invited to give input to the Improvement Service call for ideas on a new evaluation framework for NPF4

We do see it as crucial the climate and biodiversity are high up the list of considerations for monitoring to ensure that NPF4 helps create the changes needed. We would be happy to engage further on this and bring in other eNGO colleagues if that would be helpful.

APRS input to call for ideas on What a High Performing Planning system looks like and what impact it could have

Call for Ideas Questions:

  1. What are the outcomes we need the planning system to deliver to have impact?

Need to ensure that new framework emphasises the new prioritises elements of NPF4 – climate and biodiversity recovery

Zero carbon places

Nature positive places – biodiversity is enhanced and better connected

Emissions from development are minimised

Places are more resilient to climate change impacts

Rebalanced development 

Rural revitalisation

In absence of more strategic approach to where energy infrastructure goes – can planning system make development effective and efficient and less wasteful and manage significant impacts on landscape so less damaging? 

That the public are more engaged and understanding of the planning system and the system allows them to make constructive input so that engagement is worthwhile. Should be seen as an asset to help ensure planning system is delivering public benefit.

Land use change/ protected land – amount and quality rising (biodiversity/intactness/functional ecosystems/connectedness) – 30×30 targets; nature networks delivered etc

Planning conditions (of all types but particularly those related to climate and biodiversity) are implemented, monitored and enforced if necessary.

  1. What makes a high performing planning authority?

Need authorities to deliver on to development planning; management and monitoring of outcomes and enforcement. Enforcement important to deliver outcomes and to win public engagement in planning. A high performing planning authority would know whether the conditions attached to consented applications, eg those are in place to safeguard habitats, protect species and restore and enhance habitats, are actually being met. So high performing Planning Authorities to have proper systems and good governance around their processes for monitoring compliance.

Crucial decade to mitigate climate and nature loss risks has already begun – NPF4 makes the importance of this clear eg:

Spatial strategies “will reduce, minimise or avoid greenhouse gas  emissions” and “adapt to current and future risks of climate change by promoting nature recovery and restoration in the area

When considering all development proposals significant weight will be given to the global climate and nature crises

Requirement to engage with local community on LDPs. Purpose of planning is to deliver public benefit in the longterm … PAs need to engage and involve communities in constructive way: demonstrate that reducing emissions is not all on the individual, it can be planned for by delivering better places holistically.

Plan-led system – LDP delivered (on the ground) in line with NPF4? Delivers emissions reductions, more biodiversity

  1. How can we measure this?

NPF4 is ambitious and hopefully a gamechanger/apocalypse stopper on climate and biodiversity. Worth measuring this as could be influential beyond Scotland as well as delivering healthier, liveable places here.

NPF4 recognises that being nature positive is not just about landscaping developments it’s about : protect; conserve, restore and enhancing biodiversity in line with mitigation hierarchy (ie not just short lived wildflowers meadow and some dying shrubs)

One young planted sapling does not adequately replace an established tree etc etc…

So biodiversity needs to be part of the monitoring framework – and it needs to be sustained long enough to be meaningful…And those discharging planning conditions after consent need to evidence what they have done – so ‘lost paperwork’ or incomplete evidence should be a red flag of potentially not having fulfilled conditions. Monitoring and enforcement need to cover onsite work and offsite mitigation – this likely will require conditions to stipulate planning monitoring officers and oversight groups.

Reporting on monitoring of conditions – and whether or not they are fulfilled who’ll be full and transparent.

NPF4 policy on Soil is also new and should be monitored – this is likely to develop overtime as it is a change but monitoring will help drive improvements in practice. 

Cumulative impacts – guidance needed both for landscape impacts and biodiversity

Deviation from plan – should be monitored. If communities input to plan and then it is not followed, what are the impacts (greenspace, biodiversity, emissions etc) and the implications (will community continue to engage if system doesn’t deliver what’s in the plan and delivers unexpected speculative development instead.

Measure how much productive agriculture land is lost to development.

Measure extent of Green Belt that is undeveloped open and green(ish)/natural space…

Impact of LPPs – so communities can judge if worthwhile?

Get citizens involved cf citizen science? 

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