Scottish Environment LINK is supportive of having a national planning framework. We think that it is important to have a national spatial strategy to help to decide where the big things are going to go across Scotland and to have a long-term vision about how to make Scotland a more sustainable place. However, some of the changes are a little concerning. Although it is good to have a national planning framework that takes a long-term view of where Scotland wants to go, shifting to a 10-year cycle is a bit of a worry, as things can change a lot in 10 years. What was happening 10 years ago in the planning world? Donald Trump was getting planning consent for his golf course in Aberdeenshire. It is hard to imagine that happening now—things have moved on quite a lot. I am not sure that shifting to a 10-year cycle is necessarily a good thing, although I believe that a long-term vision should be set out in the national planning framework.
We think that including Scottish planning policy in the national planning framework risks overloading it. At the moment, Scottish planning policy sets out different sorts of specific criteria-based policies, whereas the national planning framework is much more spatial, as Graeme Purves described. There is a risk of making the document quite heavy and burdensome.
The other disadvantage of including Scottish planning policy in the national planning framework is that it would mean that it is likely that there would be only one consultation on SPP and the NPF together, whereas, at the moment, they are consulted on separately, which gives communities and others an opportunity to get involved in thinking about what the criteria policies mean, separate from what the spatial strategy means. There is also, at the moment, an opportunity for an environmental assessment of those.
Likewise, we are a bit worried about the implications of including strategic planning in the national planning framework. We are pretty neutral on where strategic planning sits, but we think that there is an essential role for strategic planning at a regional level—that is, a sub-national but greater than local level. As they stand at the moment, the proposals are a bit unclear about how that would be safeguarded.
Although we are neutral on the question of whether regional planning and strategic development plans sit within the national planning framework or sit with local authorities, as they do at the moment, they definitely need to be dealt with somehow.
There are other issues where we think that there might be opportunities in relation to the national planning framework. There should be clear links across to other sectors of spatial planning in Scotland, particularly marine planning and agriculture, forestry and other areas of land use, through the land use strategy. Taken together, the land use strategy, the national marine plan and the national planning framework create a holistic mission for Scotland, so they need to be thought about in a consistent way.
Even more important, the national planning framework sets out a long-term vision for how we might want to make Scotland a better place in future, yet it sits quite separate from the budgeting process at the moment. The last two national planning frameworks have both been introduced with a phrase that ministers have included, which states that the national planning framework is a spatial expression of the Government’s economic strategy. It makes sense to have a link between the Government’s economic strategy and the spatial vision for the sort of place that we want Scotland to be. However, to have the long-term vision being the spatial expression of a shorter-term budget-setting strategy seems to be the wrong way round. We think that it would be much more sensible if the budgeting process were to follow the long-term vision for a future Scotland that is set out in the national planning framework. Therefore, we are keen to see that link between shorter-term budget setting and the longer-term vision for how we are making Scotland a sustainable place, which can be set out in the national planning framework.