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PAS response to the consultation on Scotland’s Third National Planning Framework

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In July 2013, PAS responded to the consultation on Scotland’s Third National Planning Framework (NPF3).

PAS is very aware of the challenge of awareness-raising and education to engage effectively with members of the public on a national spatial plan as opposed to a more geographically specific development plan proposal or planning application. PAS appreciates efforts to publicize NPF3 by attracting interest through a series of exhibitions undertaken in public venues.

However, there are a number of improvements that PAS would suggest in relation to NPF3, including:

 

Publicity and Awareness-raising

  • A move towards an integrated five year review process of national planning policy documents, with an eye towards awareness-raising and clarity to members of the public
  • Raising awareness of this nationally important document to the public and to community groups, not only community councils, as a wide range of such groups is capable of engaging effectively if encouraged to do so
  • A focus on obtaining the highest and best resourced consultation processes in the earliest stages of consultation, with the document clearly flagging up national developments and explaining their status in terms of section 25 of the planning acts

        Format and Content

  • A clear statement at the start of NPF3 regarding the status and purpose of the document and setting out clearly where it sits within the Scottish planning system
  • A clear statement up-front in NPF3 regarding the designation and status of proposed national developments
  • A listing of proposed national developments at the start of the document in addition to being introduced thematically throughout – again, in terms of public awareness-raising of geographically-specific proposals
  • A better explanation in NPF3 of the implications for the subsequent consent processes for national developments and other projects which are referred to in the text as of national significance
  • A need to evaluate the spatial consequences of planning and other policies (e.g. energy, regeneration, environment and transport) already adopted, but which are likely to have had much less effective grassroots public consultation. In particular, the Scottish Natural Heritage wild areas map has not undergone public scrutiny in its own right and this aspect of NPF3 should be consulted upon as policy rather than being taken for granted.

You can view the response in its entirety here (hyperlink here). If you or your organization have questions or comments, please get in touch with David Wood at 0131 659 9774 or david@pas.org.uk

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