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SP Paper 204

EE/S3/09/R1

1st Report, 2009 (Session 3)

Report on the Scottish Government's National Planning Framework 2

Contents

Remit and membership

Report

Background

KEY ISSUES

Contribution to economic growth and to sustainability
Efficiency of the planning system
Measuring delivery of the NPF2 and sanctions for poor performance
The national developments (energy)
The national developments (non-energy related)

CONCLUSIONS AND RECOMMENDATIONS

Introduction
Economic growth and environmental protection
National developments (energy)
National developments (other)
Wider issues

Annexes

Remit and membership

Remit:

To consider and report on the Scottish economy, enterprise, energy, tourism and all other matters falling within the responsibility of the Cabinet Secretary for Finance and Sustainable Growth apart from those covered by the remits of the Transport, Infrastructure and Climate Change and the Local Government and Communities Committees.

Membership:

Ms Wendy Alexander
Gavin Brown
Rob Gibson (Deputy Convener)
Christopher Harvie
Marilyn Livingstone
Lewis Macdonald
Iain Smith (Convener)
Dave Thompson

Committee Clerking Team:

Clerk to the Committee
Stephen Imrie

Senior Assistant Clerk
Katy Orr

Assistant Clerk
Gail Grant

Report on the Scottish Government's National Planning Framework 2

The Committee reports to the Parliament as follows—

Background

1. The National Planning Framework 2 (NPF2) was laid before the Scottish Parliament on 12 December 2008.1 This document sets out the Scottish Government’s strategy for Scotland’s spatial development until 2030. The framework outlines, in broad terms, how the Scottish Ministers consider that the development and use of land could and should occur. The NPF2 is the second such framework to be produced, but the first to be produced since the passage of the Planning etc. (Scotland) Act 2006 (the Act) provided a statutory basis for a spatial plan for Scotland to be known as the “National Planning Framework”.

2. Under the provisions of the Act, the Scottish Parliament has a period of 60 days (not including any recess of more than 4 days) to consider the NPF2 and the Scottish Ministers are to have regard to any resolution or report of, any committee of, the Scottish Parliament made, during the period for Parliamentary considerations, as regards the proposed framework.

3. On 25 November 2008, the Parliamentary Bureau agreed that the Local Government and Communities Committee would act as the lead committee for consideration of NPF2. It is open to other relevant committees in the Parliament to carry out their own scrutiny of the NPF2 according to their remit and to report any findings to the lead committee.

4. Consequently, the Economy, Energy and Tourism Committee resolved at its meeting of 10 December 2008, that it too would scrutinise the NPF2 and report to the lead committee. In particular, the Committee agreed that it wished to look at the energy projects within NPF2 that had been identified as candidate “national developments” and also at the overall perception amongst the business community and others of the Scottish Government’s proposals and whether the NPF2 would contribute to sustainable economic growth and the Scottish Government’s targets as set out in its economic strategy.2

5. To assist the Committee in developing its view, members received a number of submissions of written evidence, which are set out in the annexes of this report. The Committee also took oral evidence from a range of witnesses at its meeting of 14 January 2009, namely—

  • Iain McMillan, Director, Confederation of British Industry (CBI) Scotland;
  • Iain Duff, Chief Economist, Scottish Council for Development and Industry (SCDI);
  • Stephen Boyd, Assistant Secretary, Scottish Trades Union Congress (STUC);
  • Scott Mathieson, Regulation Director, and Ross Baxter, Head of Environmental Planning, Scottish Power Energy Networks;
  • Mike Barlow, System Development Manager, Scottish and Southern Energy Power Systems;
  • Andrew Hiorns, Strategy Review Manager, National Grid;
  • Stuart Cook, Director of Transmission, Ofgem;
  • David Anderson, Chief Executive, The Industrial and Power Association;
  • Jason Ormiston, Chief Executive, Scottish Renewables;
  • Duncan McLaren, Chief Executive, Friends of the Earth;
  • Aedan Smith, Head of Planning and Development, Royal Society for the Protection of Birds (RSPB) Scotland.

6. The Committee is grateful to all of the individuals and organisations that gave evidence, both written and oral, to us.

KEY ISSUES

7. The Economy, Energy and Tourism Committee’s focus for scrutiny of the NPF2 has considered the following issues—

  • Will the provisions of the NPF2 contribute to sustainable economic growth and to the targets and objectives as set out by the Scottish Government as part of its economic strategy?
  • Is the Committee content with the energy-related projects identified as “national developments” within the NPF2?
  • Whether the Committee has any comments on the other “national developments” or wishes to see the inclusion of projects currently omitted in the NPF2?
  • Whether an appropriate balance has been struck in the NPF2 between economic growth and environmental protection?
  • Whether an appropriate consultation process has or will be followed for the “national developments” to achieve a balance between an efficient and swift planning consent system and one that enables local organisations and individuals to have their say?
  • How it will be possible to identify and measure whether the objectives and proposals set out in the NPF2 have been efficiently delivered, i.e. whether there is a case for the inclusion of ‘performance metrics’? Furthermore, whether there are sufficient safeguards to ensure a rapid delivery of the associated city/region and local development plans?

8. The Committee has also taken an interest in some of the wider issues relating to the planning system, such as—

  • Whether there is a sufficient number of suitably qualified planning officials within the public sector to expedite applications for major and strategic projects?
  • The views of the Scottish Government on whether relevant public agencies are now aligned in the sense of working together to deliver the aims of the NPF2 (e.g. the enterprise bodies, local authorities, planners, statutory regulators such as SEPA and SNH etc)?

9. Each of the key issues identified above is addressed in more detail in the sections below.

Contribution to economic growth and to sustainability

10. Most of the organisations that gave evidence to the Committee, particularly the business organisations, were complimentary about the NPF2 and had a positive outlook as to whether it would contribute to economic growth. In written evidence to the Committee, CBI Scotland stated that it “welcome[d] the Scottish Government’s positive ambition to raise the growth rate of the economy, and the draft NPF2 is crucial to achieving this and to helping underpin successful planning reform”.3 Furthermore, CBI Scotland indicated that it—

“believes that the finalised NPF2 provides a unique opportunity for the devolved government to deliver on their top priority and plan for growth, founded on the premise that Scotland in 2030 will have a larger and more dynamic economy, with a growing and wealthier population. This will help the Scottish Government realise its Economic Strategy and enhance the global competitiveness of Scotland as a business location.”4

11. Similarly, Iain Duff of the Scottish Council for Development and Industry told the Committee that—

“We welcome the production of the second framework, and we particularly welcome the fact that it will have a statutory basis. We hope that that statutory backing will, upon agreement by the Parliament, provide a more efficient and effective means of delivering big, nationally significant projects. In general, NPF 2 is a useful document and a welcome addition to the Government’s policies.”5

12. Endorsing these views, Stephen Boyd of the Scottish Trades Union Congress stated—

“We welcome it and its statutory basis, and the substantial consultation that was engaged in before it was produced.”6

13. Other organisations, whilst generally supportive of the principles in the NPF2, were less convinced that the framework would be beneficial towards stimulating economic growth, particularly from the perspective of balancing growth with environmental sustainability. For example, Friends of the Earth Scotland (FOE(S)) stated in its written evidence to the Committee that it “agrees with the principle of a statutory national planning framework to guide regional and local plans and development decisions in support of a dynamic economy, a healthy environment and a better quality of life for all our communities”.7 However, this organisation also indicated that—

“the overall compatibility of the NPF with the Scottish Government’s welcome aspirations to help address climate change. In this latter respect, and with respect to some other policies included in the NPF, we do not believe that the NPF as a whole can be expected to meet its statutory duty to contribute to sustainable development.”8

14. Friends of the Earth Scotland’s opinion is that the policies and proposals in the NPF2 must contribute to sustainability. FoE(S) believes that it is not adequate for some measures in the NPF2 to contribute to sustainability if others of significance detract from it.

15. Similarly, the RSPB Scotland stated that “there is a conflict between some of the proposed national developments and Government’s climate emissions reduction and renewable energy ambitions”.9

16. This view is not shared in its entirety by the Commission for Sustainable Development Scotland, which indicated to the Committee in its evidence that “the new Framework is set more clearly within the principles of sustainable development than its predecessor”.10 However, the Commission also indicated that it had a significant concern that the infrastructure and transport developments proposed or supported by NPF2 will not contribute towards a lower carbon Scotland.11

17. The views of Friends of the Earth Scotland and RSPB Scotland were explicitly rejected by Iain McMillan of CBI Scotland. He said—

“Some organisations might take the view that some of the projects, particularly on transport, contravene the Scottish Government’s environmental agenda, but I do not think that. Things always have to be balanced. We cannot go back to living in caves.”12

18. In response to the issue of whether all projects in the NPF2 must contribute to sustainable development and not exacerbate climate change, the Minister for Transport, Infrastructure and Climate Change has said he is confident that there will be no basis for a legal challenge that is based on the sustainable development duty in relation to the NPF2.13 Furthermore, he has told MSPs that—

“Development is a necessary part of ensuring that we address the climate change agenda. We must renew our infrastructure to make it more carbon efficient and to ensure that we have an economy that can afford to make the interventions that will reduce Scotland's carbon footprint. Far from being at odds with our environmental and sustainable growth credentials, the planning framework supports them.”14

Efficiency of the planning system

19. The Committee has previously expressed concerns about the planning system in Scotland and specifically the number of suitably qualified planners within Scotland’s local authorities. This was manifest in the Committee’s recent report on the tourism industry.15 It was clear to us then that there were problems with recruitment and especially retention, which were causing delays and inefficiencies in dealing with planning applications.

20. Similar issues have been raised by witnesses giving evidence to the Committee as part of our scrutiny of the NPF2. For example, the CBI Scotland stated that it has “estimated that Scotland’s cumbersome planning system costs the country £600 million a year through a combination of deferred benefits of infrastructure investment, lost turnover from delays to commercial investments, the impact of higher housing costs on salaries, and the opportunity cost of lost investment”.16 The CBI Scotland and others therefore supported any efforts that could be made through the NPF2, the national developments and the planning system more generally to speed up the planning process.

21. However, a cautionary note was expressed by other organisations regarding whether the NPF2 and the designation process (of projects as national developments) would override the need for adequate scrutiny of projects. For example, Friends of the Earth Scotland believed that giving a project status as a national development “should not exclude such developments from full scrutiny of need at a public inquiry”.17 Likewise, the John Muir Trust stated that—

“It is critical that the National Planning Framework does not become a vehicle for fast-tracking controversial decisions, using the “national interest” argument to rule out any rigorous examination of the plan by all interested parties. This would be a dangerous erosion of democratic rights.”18

22. More widely, other witnesses expressed concerns about the current system for educating and training planning officials. In this regard, Stephen Boyd of the STUC noted—

“We need to think about how we train more planners—we have, of course, shut the planning schools in Scotland—and how we make local authority planning a more rewarding career for individuals who are entering the profession. A vicious circle has been set in motion now that the incentives are for local authority planners to move into the private sector. We have to overcome that”.19

23. Finally, the Committee was also interested in ascertaining whether the Scottish Government has achieved a greater alignment between the roles of, and decisions taken by, various public sector bodies, such a local authorities, the enterprise agencies and statutory bodies such as Scottish Environment Protection Agency (SEPA) and Scottish Natural Heritage (SNH). As the CBI Scotland noted, “NPF2 provides a valuable opportunity to help deliver the Scottish Government’s aim of aligning all of the public sector behind the key purpose of enhanced levels of economic growth”.20 This organisation believed that “all government and non-departmental public agencies and bodies should be directed – rather than advised - to align their business plans and budgets with the targets set out in the finalised NPF2”.21 Likewise, Stephen Boyd of the STUC stated—

“In general, the public sector agencies try to be aligned with wider priorities for economic growth. They are becoming better in that respect, and the present Government has put in a lot of effort to try to ensure that that is the case. There is still some way to go, but the tensions will always exist to various extents; I do not think that they will ever be completely overcome.”22

24. In response to the issue of the resources available to local authorities for planning, the Minister for Transport, Infrastructure and Climate Change told MSPs that—

“… we cannot magic planners out of the ether. We are engaged in the subject and are seeking, through reform of the planning system, to ensure that councils have the opportunity to make the best use of their staff.”23

25. Additionally, the Scottish Government’s Chief Planner made reference to the £10 million e-planning project that the Scottish Government expects to launch in the spring, the £400,000 to set up the strategic development planning authorities across Scotland, and the £650,000 spent on the Improvement Service to help with the training and development of planners.24

Measuring delivery of the NPF2 and sanctions for poor performance

26. As currently drafted, the NPF2 does not contain reference to a specific set of performance metrics that would be used to measure the delivery of its provisions. Previously, guidance issued as part of the Scottish Planning Policy series contained a requirement for local authorities to report on the length of time taken to deal with planning requests25. There was also a statutory duty for planning applications to be determined within 2 months from the receipt of a valid planning application (4 months where applications require an Environmental Statement)26. Recently introduced planning guidance removed this requirement and it would appear that there are no longer any performance measures of this type.

27. In evidence to the Committee, when asked, most witnesses supported the inclusion of some form of measurements by which delivery of the NPF2 can be monitored. For example, Iain McMillan of the CBI Scotland stated—

“We are concerned about the withdrawal of metrics. We were always concerned that, even when metrics were in place, local authorities faced no financial sanction—nor was planning approval deemed to have been granted—if they did not deal with an application on time”.27

28. Furthermore, one specific aspect of the NPF2 that the CBI wanted to see tightened was the timescale for the delivery of the city/region and local development plans. In this organisation’s view, “City Region Plans and Local Plans must accord with NPF2, and state how each Plan will meet the economic and population growth targets”.28 The CBI Scotland also indicated that it “believes City Region Plans should be updated and approved within two years of the introduction of the finalised NPF2, and subsequently Local Plans within two years of the City Region Plans”.29

29. Views on the sanctions that should be available for a failure to deliver on city/region and local development plans were mixed. Iain Duff of the Scottish Council for Development and Industry stated—

“Sanctions are a difficult issue. What type of sanctions are we talking about? Financial sanctions would involve taking money from local authorities, which may hinder the system more. I am not saying that we are opposed to sanctions, but you would have to be careful about their form and how onerous they were. Would financial sanctions just mean that money was being taken out of the system when resources are already tight? A balance needs to be struck, but some sanction may be appropriate”.30

The national developments (energy)

30. The Committee’s main interest in the NPF2 from a subject-matter perspective was the inclusion of a number of energy projects to be designated as “national developments”. Specifically, the annex to the NPF contains three projects (N° 8, 9 and 10) in the energy field:

  • N° 8 - New Power Station and Transhipment Hub at Hunterston
  • N° 9 - New Non-Nuclear Baseload Capacity at Other Existing Power Station Sites (Longannet, Cockenzie and Boddam)
  • N° 10 - Electricity Grid Reinforcements, specifically:

    - an overhead line and substation works to increase north-south transfer capacity in Central Scotland.

    - a new 275kV South-West Scotland transmission line and associated infrastructure.

    - strengthening of the Scotland - England interconnectors to increase export capacity to 3.2GW.

    - upgrading the East Coast transmission route to 400kV.

    - upgrading the existing Beauly – Dounreay overhead transmission line.

    - reinforcement of the Beauly – Keith overhead transmission line.

    - reinforcement of the sub-sea cable link between Orkney and the Scottish mainland.

    - new sub-sea cable links for the Outer Hebrides and the Shetland Islands.

31. Designation as a “national development” is an indication by the Scottish Ministers that these projects are considered to be essential to the delivery of the spatial strategy as set out in the NPF2. These projects will still require planning permission and other relevant consents, but it is the case that their designation will mean the Scottish Ministers will be able to intervene at any stage of the planning process to ensure that decisions are made expeditiously.31 Furthermore, any examination of the national developments as part of a public inquiry or a hearing will not be able to consider the principle of the development, only issues to do with siting, design and the mitigation of environmental impacts.

32. Views on the inclusion of the three proposed national developments outlined above were mixed. Perhaps unsurprisingly, power companies in Scotland were very supportive of their inclusion. For example, Scottish Power stated in relation to grid reinforcements (project N°10) that—

“The National Planning Framework plays a key role in enabling strategic investment priorities for Scotland and, in particular, we support the designation of electricity transmission investment as a national development. We regard the prompt delivery of further electricity transmission capacity as being a fundamental enabler in meeting the Scottish Government’s renewable electricity energy targets.”32

33. Similarly, Scottish and Southern Energy welcomed the inclusion of the project to strengthen the electricity transmission system in the new National Planning Framework and recommended that the Scottish Parliament strongly supports this particular prospective national development.33

34. Other energy sector organisations were also in favour. For example, Andrew Hiorns, Strategy Review Manager at National Grid, told the Committee that—

“As far as the transmission plan is concerned, I am always trying to determine what transmission capacity is required for the future. If we have some indication of where future power stations may be situated, that helps me in the planning of the network. I can then identify the appropriate reinforcements. It helps to complete the picture.”34

and Jason Ormiston, Chief Executive of Scottish Renewables stated—

“NPF 2 is important because the next 20 or 30 years is the timeframe in which it works. That is also the timeframe for the decision making that is happening now because of the time that is spent on planning and deciding on infrastructure and large plant. That is why it is pleasing to see the framework’s emphasis on grid reinforcements and the need for a mixed supply of generation to meet post-2020 demand”.35

and Stuart Cook, Director of Transmission at Ofgem, who told the Committee that—

“The transmission and distribution infrastructure is essential to the delivery of renewables targets. It is therefore important that the planning framework has within its scope all the likely investments that the transmission companies will have to make in order to make connections to the new generators.”36

35. Other organisations that gave evidence to the Committee were less supportive of some of these three projects (N° 8 and 9) being designated as “national developments”. Friends of the Earth Scotland stated that—

“[the] new coal power capacity at Longannet, Cockenzie and Peterhead must feature fully operational carbon capture and storage technology from the outset or be refused planning permission. It should not therefore be designated as of national need. Instead the NPF should establish the principle of a strictly enforceable emissions performance standard for new combustion plant.”37

36. Similarly, RSPB Scotland indicated that the “current proposals for a new powerstation at Hunterston would involve a very significant loss of intertidal habitat from the Portnencross SSSI.”38 Concerns were also raised by the Scottish Government’s own advisers, the Commission for Sustainable Development Scotland, regarding this particular “national development”, stating ”our primary concern is related to the equating of ‘carbon capture readiness’ with the actual delivery of low carbon generation capacity.”39

37. On the other hand, the Commission for Sustainable Development Scotland was more supportive of the planned electricity grid reinforcements stating that it welcomed “the commitments made to reinforcing the electricity grid, important as they are in exploiting Scotland’s renewable energy resources”.40 This was not a view supported by the John Muir Trust, which was particularly critical of this proposed “national development” (N° 10). The Trust stated that “this Candidate National Development is not suitable for inclusion in the NPF2”.41 In the Trust’s opinion, this project was a complex bundle of ten developments which are scattered throughout the country and which are not spatially defined, and that there has been little if any consideration of alternative options.

38. However, the critical nature of these particular national developments (N° 8 and 9) was emphasised by David Anderson, Chief Executive of the Industrial and Power Association. He told the Committee that—

“We have five main generation hubs in the UK, many hydro stations and a growing wind portfolio, all of which are welcome. Four of the five hubs will disappear by 2023; three will probably disappear between 2015 and 2020. Rebuilding those stations would take somewhere between five and 10 years, depending on how long the planning process takes. Therefore, we are already at the edge of the cliff”.42

39. Mr Anderson also expressed concerns about the planning system and the impact that delays can have on developers. He told the Committee that—

“When we put our head above the parapet and propose major line schemes, the process takes 10 years. As a private individual, I find that horrific. The Beauly to Denny line has not been decided on yet, but if it takes less than 10 years from initial concept to being built, I will eat my hat, frankly. Whatever happens in the system must be an improvement on that kind of situation.

[…]

It is so difficult and the timeframes are exasperating, in my view. We need a much neater planning process that can look at point-to-point developments across a multitude of landowners and deliver something within four years rather than 10—that should be the objective.”43

40. Duncan McLaren of Friends of the Earth Scotland questioned whether an alternative to the process proposed by the NPF2 would indeed delay national developments. He stated that putting national developments through an assessment of need would not lead to significant delays and that this would add only “two to three months” to the public inquiry timeframe whereas a judicial review or referral to the European Court of Justice would add a “matter of years” to delays44.

41. The Committee did raise issues relating to these three proposed “national developments” with the Scottish Ministers. Our questions covered the Scottish Government’s justification for including these three projects as “national developments” rather than simply stating the basic principles behind the need for such developments in the narrative of the NPF2 itself and that we should be technology-neutral rather than favour, or rule out, particular generating technologies. We also questioned the Scottish Government’s view, as indicated in the annex of the NPF2, that all three projects will “help meet climate change, renewable energy or waste management targets”. Finally, we asked the Scottish Government for a view on why it had omitted a project or projects covering energy efficiency, renewable heat and/or demand reduction, such as a home insulation programme, as a project of “national importance”.

42. Some of the organisations giving evidence to the Committee had sympathy with the issues raised in some of the questions asked by the Committee. For example, in a written submission of evidence, the Scottish Chambers of Commerce (SCC) stated that—

“In a world where energy is becoming an increasingly important commodity and is an essential component of our economic wellbeing, SCC had argued that a wider range of energy related projects, particularly in the area of electricity generation, should be included in the list of National Developments. Whilst we are pleased that this argument has in part been accepted by the Scottish Government in the revised NPF2 proposals, we do not agree that the document should be prescriptive in the definition of the sources of electricity generation. The omission of nuclear power from the list of national developments removes a tried and tested source of electricity which has contributed in large measure to the balanced energy mix currently enjoyed by Scotland, and we feel that this cannot be justified on practical grounds.”45

43. The suggestion of a technology-neutral approach for the NPF2 was also highlighted by Duncan McLaren of Friends of the Earth Scotland. He told the Committee that—

“We would not support a completely technology-neutral approach

[…]

I would not necessarily include those measures [national development projects N° 8 and 9] as national developments. The principle should be included in the narrative and commentary of the framework, alongside the development of a carbon dioxide transport and storage network, which seems to be lacking some weight.”46

44. In a related point, the CBI’s Director for Scotland, Iain McMillan stated—

“We need to do all that we can to promote that technology [carbon capture and storage], but it has not thus far been proved financially viable, so the framework should not impose that condition on the new plants.”47

45. Finally, on the issue of energy efficiency and renewable heat projects and their omission as proposed national developments, Stephen Boyd of the STUC told the Committee that “It is difficult to think of a national priority project for heat that could have made it into the list of 12 projects, but the framework makes it clear that such issues are important for Scotland.”48 However, Jason Ormiston of Scottish Renewables cautioned that “We must not give up on energy-efficiency measures in using electricity and heating our homes.”49

46. In his response on the issue of why projects N°8 and 9 should be included, the Minister for Transport, Infrastructure and Climate Change told MSPs that—

“We must ensure that Scotland's energy needs are met, so it is proper for us both to provide for electricity grid replacements to support our renewable energy sources, especially the tidal energy in the north and the Pentland Firth that has been mentioned, and to establish spatial planning and locational principles that enable us to specify where generation can take place. As you know, the Government's policy is that there should be no nuclear generation. It is right that we should consult on non-renewable means of generation in relation to CO2 emissions—we can move forward from there.”50

47. He also said in response to a question on whether the NPF2 should be less prescriptive in relation to technologies and more technology-neutral in relation to projects N° 8 and 9 that—

“.. there is no question but that the settled policy of the Government at this moment is not to have new nuclear power stations built. It is perfectly proper that the NPF reflects that.”51

The national developments (non-energy related)

48. Although the Committee took a specific interest in the three energy sector projects proposed as “national developments”, we also had questions regarding other subject areas, such as transport. This is because, in our role as the Economy Committee, such projects have the potential to play an important part in developing the Scottish economy.

49. In relation to transport, we questioned the Scottish Government as to why the enhancement of rail services in the north of Scotland and the strategic rail connections to the north of Scotland – specifically the proposed new track north of Inverkeithing - are not included as national developments. We also asked why a high-speed rail link to England is not included as a national development. Furthermore, we asked witnesses who appeared at the Committee for their views on the sense of proposing separate developments for a freight hub at Grangemouth and an international container terminal at Rosyth.

50. In relation to high-speed rail, this was an issue on which the Committee had received comments from key stakeholder groups. For example, the Scottish Chambers of Commerce stated that it believes—

“that one of the key national transport projects undertaken in the United Kingdom in the early part of this century should be the development of a High Speed Rail network linking Scotland with London and other key English cities. Such a development is projected to boost Scotland’s economy by a significant amount and could help refocus our reliance on short haul domestic air transport within the UK for business travel. This is an initiative that Scotland should be leading and this must be reflected in our list of National Developments.”52

51. In evidence to the Committee, witnesses from the business sector were particularly supportive of the transport projects included in the NPF2. For example, the CBI Scotland stated that it welcomed “the transport projects designated within the draft NPF2 as being of national importance”.53 However, the CBI Scotland also stated that it was “concerned that several transport infrastructure projects of strategic important are not contained within the draft NPF2, and as such may therefore not be deemed of national significance nor deemed urgent.”54 In particular, the organisation highlighted the upgrading of the M8 to a three-lane motorway, the construction of an M8 spur to Edinburgh Airport and the complete dualling of the A9 from Perth to Pitlochry, with increased passing opportunities north to Inverness. CBI Scotland was also supportive of rail improvements to the north of Scotland calling for them to be “more than aspirational”55 and that—

“… we need to improve our rail links to Aberdeen, Inverness and other points north. I suspect that that has been left out of the national planning framework because its likelihood and timescale are less certain”.56

52. The CBI Scotland noted that that the draft NPF2 has as yet been unable to draw upon the published findings of the Scottish Government’s extensive Strategic Transport Projects Review. This raises a wider point identified by the Committee, namely, the NPF2 is only one of a series of processes and initiatives being taken forward by the Scottish Government in the transport as well as other sectors. It appears unclear in the NPF2 what the relative timescales are for projects proposed as “national developments” compared to other developments being taken forward as part of the Strategic Transport Projects Review or other such initiatives in other sectors of the economy.

53. This was a point supported by Iain Duff of the Scottish Council for Development and Industry who told the Committee that—

“Our members have said that they would not like to think that having projects in the STPR [strategic transport projects review] or NPF 2 means that other projects will not be considered and will not be able to proceed in another way, shape or form. The worry is that progress might grind to a halt in other parts of the country or for projects that have not been favoured by inclusion in the list of national developments or strategic transport projects. I would not like to think that that is how the documents should or would be interpreted.”57

54. Finally, outwith the transport sector, the Committee was interested in the call by the RSPB Scotland that the Parliament should specifically identify the need for landscape scale ecosystem and land management projects to complement/offset impacts of the proposed national developments, as well as historic habitat loss and environmental degradation in central Scotland. Its view was that “green infrastructure projects will be as essential as the more traditional type of infrastructure projects proposed in NPF2 if we are to achieve the Government’s objective of building a Scotland that is wealthier and fairer, greener; safer and stronger; smarter and healthier.”58

55. In response to the issue of the high-speed rail link raised above, the Scottish Government’s Transport, Infrastructure and Climate Change Minister has told MSPs that he agreed that the evidence is becoming ever stronger that high-speed rail is the only realistic way of reducing the carbon impact of that demand.59

56. Furthermore, on the issue of co-ordination between the NPF2 and other transport initiatives such as the STPR, the Minister said—

“As we took forward the strategic transport projects review and the national planning framework—both of which are in my portfolio—we sought to co-ordinate their activities. We will continue to co-ordinate their implementation through an action programme.”60

conclusions and recommendations

Introduction

57. The Economy, Energy and Tourism Committee welcomes the opportunity to scrutinise the national planning framework 2 (NPF2) recently published by the Scottish Government. We consider this to be an important document, which sets out the proposed development and use of Scotland’s land resource through to 2030.

58. Our interests as a Committee have been whether the Scottish Government has achieved a balance between the often competing challenges of driving forward economic growth through an efficient planning system with the need to protect our fragile environment, reduce our contribution to climate change and ensure all interested individuals and organisations can have their say in any proposals for strategic national developments.

59. The Committee’s particular focus has been on the three projects in the energy sector designated by the Scottish Government as “national developments” (project N° 8, 9 and 10). We have also taken an interest in transport projects because of their potential to contribute to economic growth.

60. Designation as a “national development” is a critical issue as, whilst it does not remove the possibility of a public inquiry or hearing, it does remove the question as to whether the project is needed. It also enables the Scottish Ministers to intervene at any stage in the planning process to ensure decisions are taken swiftly.

Economic growth and environmental protection

61. The Committee welcomes the emphasis given by the Scottish Government to the need to grow our economy. The current economic downturn is causing severe hardship to businesses, employees and their families across Scotland. We support the principles underpinning the national planning framework 2 as an initiative designed to ensure that our planning system does not unduly delay projects of strategic national importance. However, as a Committee, we do not wish to suggest that the national planning framework 2 should be seen as a signal for untrammelled development at any cost.

62. The Committee notes that designation of a project as a “national development” does not remove the possibility of a public inquiry or hearing. We believe that it will be important, going forward, that there still remains the scope for adequate consultation with interested organisations and individuals with a view on strategic developments.

63. We recommend that the Scottish Government makes every effort to ensure that our consultation procedures secure access for interested parties and that we seek to learn from other jurisdictions and legislatures as to how they achieve this goal (RECOMMENDATION 1).

64. We note the comment from the Scottish Government’s own, independent environmental advisers (the Sustainable Development Commission Scotland) that the second national planning framework is set more clearly within the principles of sustainable development than its predecessor.

65. We also note the concerns expressed by others, such as the environmental NGOs, that it is not necessarily the case that all the projects identified as “national developments” will all play a part in reducing the emission of greenhouse gases.

66. On balance, the Committee concludes that the national planning framework 2 strikes the appropriate balance between economic growth and environmental protection, and between an efficient planning system and one that provides adequate means of consultation. However, this is only the case when the technology required to provide this balance is available and commercially proven, which is not necessarily the case with certain energy projects. In this respect, the Committee recommends that the Scottish Government continues to have regard to the balance between such competing issues (RECOMMENDATION 2).

National developments (energy)

67. The Committee notes the proposed designation of three projects as “national developments. These are the plans for a new power station and transhipment hub at Hunterston (project N°8), new non-nuclear baseload capacity at other existing power station sites at Longannet, Cockenzie and Boddam (project N°9) and a series of electricity grid reinforcements (project N°10).

68. In respect of the latter (grid reinforcement), we note the calls from some that this project should not proceed and that we should await studies on sub-sea transmission initiatives as alternatives. However, given the Scottish Government’s targets for renewable energy and for reductions on emissions of carbon dioxide, the Committee believes that this proposed national development is critically important and we recommend that candidate national development N°10 should be approved by the Scottish Parliament (RECOMMENDATION 3).

69. In respect of the proposed clean coal-fired, carbon capture ready power station at Hunterston, the Committee has yet to complete its energy inquiry and so is not yet in a position to indicate its preferred generating mix for Scotland’s energy future. However, the Committee gives its support, in principle, to the need to ensure adequate baseload/load-following plant in Scotland and that such plant should be as efficient as possible with minimal emissions of carbon dioxide and other harmful gases.

70. The Committee welcomes and supports the progress being made to develop carbon capture and storage technologies but we recognise that it is not yet proven on a sufficiently large commercial scale. This is an issue we will return to in the conclusions of our energy inquiry. We do need clarity as to what the phrase ‘carbon capture ready’ means and the extent of the output of a power station that will be covered.

71. At this stage, the Committee believes that it is too early for the Scottish Government to be technology specific in the case of candidate national developments N° 8 and 9 as the preferred technological solutions have still to prove their commercial viability on a large-scale. We recommend that the Scottish Government makes reference to the policy objective and principle behind these projects in the NPF2 report itself and removes any technology specific references from these candidate national developments (RECOMMENDATION 4)61.

72. Furthermore, the Committee recommends that the Scottish Government gives consideration as to whether there should be an energy efficiency/renewable heat/demand reduction initiative as part of the proposed national developments (e.g. a home insulation/refurbishment scheme) or through some other appropriate initiative outwith the NPF2 (RECOMMENDATION 5).

National developments (other)

73. In addition to the proposed national developments in the energy sector, the Committee also considered other sectors of the economy, namely transport, as a major contributor to economic growth.

74. On balance, the Committee is supportive of the remainder of the projects proposed as national developments in the national planning framework. We are aware that some of these projects may have the potential to have an environmental downside and we recommend that the Scottish Government and others make all efforts to minimise these during development and operation (RECOMMENDATION 6).

75. The Committee was disappointed to note the omission of other key transport projects, such as a high-speed rail link to England (with appropriate facilities for freight), the enhancement of rail services in the north of Scotland and the strategic rail connections to the north of Scotland (specifically the proposed new track north of Inverkeithing) as national developments. We recommend that the Scottish Government reconsiders including these proposals as national developments (RECOMMENDATION 7).

Wider issues

76. The Committee is interested in understanding how the Scottish Government will be able to measure the effectiveness of the national planning framework 2 and the delivery of projects and the implementation of the framework’s objectives. We recommend that the Scottish Government looks again at the proposal to include clearer performance measures and/or sets out more clearly how it will monitor the delivery of the provisions in the national planning framework 2 (RECOMMENDATION 8).

77. The Committee has expressed views in the past regarding the number of suitably qualified planning officials in the public sector and local government in particular. We remain seriously concerned as a Committee at the lack of qualified planning officers and other key officials within local government and the delays that this so patently causes for developments that boost our economy. We recommend that the Scottish Government, with the Scottish Funding Council, Skills Development Scotland and others continues to look at this issue as a matter of urgency and work with the Royal Town Planning Institute and local government to see what can be done in the short-term (e.g. sharing of services) and the longer-term (e.g. improved terms and conditions offered for these key workers, better training etc) (RECOMMENDATION 9).

78. The Committee notes that the Parliament’s agreement to the national planning framework 2 is just the start of the process and that the next stage is to develop city-region and local development plans. We have no specific view on the proposal that these plans should be developed within 2- and 4-years respectively of agreement to the framework. However, we do agree that they need to be produced in as short a timeframe as possible and that, whilst we do not necessarily support the case for sanctions on local authorities, all efforts must be made to prevent slippage. We recommend that the Scottish Government regular publishes details on the progress towards the delivery of such development plans and rethinks the removal of performance measures from planning guidance notes (RECOMMENDATION 10).

79. Furthermore, we recommend that the Scottish Government sets out more clearly as part of the national planning framework 2 what the expected delivery times are for the various national developments and other strategic projects being taken forward through other initiatives such as the Strategic Transport Projects Review (RECOMMENDATION 11).

80. Finally, the Committee has sympathy with the call by the RSPB Scotland that the national planning framework 2 should also include a landscape scale ecosystem and land management project to complement/offset impacts of the proposed national developments, as well as historic habitat loss and environmental degradation in central Scotland. We recommend that the Scottish Government considers the inclusion of a project such as the central belt green network as a national development or takes forward the principles behind such a project through some other means (RECOMMENDATION 12).

Annexe A: EXTRACT FROM THE MINUTES

2nd Meeting, 2009 (Session 3), Wednesday 14 January

National Planning Framework 2: The Committee took evidence from—

Iain McMillan, Director, CBI Scotland;

Iain Duff, Chief Economist, Scottish Council for Development and Industry;

Stephen Boyd, Assistant Secretary, Scottish Trades Union Congress;

Scott Mathieson, Regulation Director, and Ross Baxter, Head of Environmental Planning, Scottish Power Energy Works;

Mike Barlow, System Development Manager, Scottish and Southern Energy Power Systems;

Andrew Hiorns, Strategy Review Manager, National Grid;

Stuart Cook, Director of Transmission, Ofgem;

David Anderson, Chief Executive, The Industrial and Power Association;

Jason Ormiston, Chief Executive, Scottish Renewables;

Duncan McLaren, Chief Executive, Friends of the Earth Scotland;

Aedan Smith, Head of Planning and Development, Royal Society for the Protection of Birds Scotland.

National Planning Framework 2: The Committee considered emerging issues from its consideration of the National Planning Framework 2 and identified questions it wishes the lead Committee to raise with the Scottish Government.

3rd Meeting, 2009 (Session 3), Wednesday 21 January

1. Decision on taking business in private: The Committee considered and decided to take item 4 in private.

4. National Planning Framework 2 (in private): The Committee discussed a draft report.

ECONOMY, ENERGY AND TOURISM COMMITTEE OR 14 JANUARY 2009

ANNEXE C: WRITTEN EVIDENCE

CBI Scotland’s response to the National Planning Framework 2:

GENERAL

1. CBI Scotland welcomes the opportunity to comment formally on the Scottish Government’s second National Planning Framework (NPF2). We have appreciated the opportunity to contribute to the Scottish Government’s deliberations on the revised framework, through the opportunities the Planning Directorate itself has provided and through our own roundtable discussions with senior officials, most recently through the CBI Scotland Planning Group62.

2. The draft NPF2 is a comprehensive document, in that it sets out well the present situation and likely future trends, and provides clarity on the aspirations and long-term approach needed to meet the challenges and opportunities for spatial development and infrastructure investment for the period to 2030.

3. CBI Scotland has consistently argued that planning is of crucial importance to Scotland’s economy and its future prosperity, and that greater weight should be given to the needs of the economy within the planning system. Indeed, previous CBI Scotland research63 has estimated that Scotland’s cumbersome planning system costs the country £600 million a year through a combination of deferred benefits of infrastructure investment, lost turnover from delays to commercial investments, the impact of higher housing costs on salaries, and the opportunity cost of lost investment. This message has recently been endorsed by the First Minister’s new Council of Economic Advisers, which considered as its first item of business the state of the planning system.

4. We welcome the Scottish Government’s positive ambition to raise the growth rate of the economy, and the draft NPF2 is crucial to achieving this and to helping underpin successful planning reform. Planning for growth must be the priority. The fact that the NPF is being continually monitored and updated every five years is sensible, and provides the opportunity to ensure that the aims and objectives are being delivered.

5. However, we recognise too that in many respects the situation in Scotland is in advance of that south of the border. It is therefore important that, in terms of developing a coherent approach to infrastructure planning that targets and stimulates private and public sector investment, the final NPF2 is informed by the policy considerations of the UK Government, especially where investment is necessary for cross-border development, such as the upgrading of the transmission networks. The English Planning Bill currently before the Westminster Parliament will introduce long overdue reform to the way major infrastructure projects are planned for in England and Wales and, if enacted, will include powers for the establishment of national policy statements (NPS) across the transport, energy, waste and water sectors. The Scottish Government should pro-actively ensure that any risk of disconnect resulting from a lack of co-ordination between the final NPF2 and emerging thinking on the future nature and content of NPSs is limited as much as possible, otherwise uncertainties are likely to develop for promoters of nationally significant infrastructure projects which will be of detriment to both the growth prospects of Scotland and the UK as a whole.

POPULATION & HOUSING

6. We welcome the fact that the draft NPF2 is explicitly orientated towards planning for sustainable economic and population growth. It is right that it should be founded on the positive premise that Scotland in 2030 will have a bigger, more diverse and more dynamic economy, and a larger, growing, wealthier and more active population.

7. The Scottish Government’s welcome target for population growth64 is reflected in the document, which is right to note that current household projections are likely to underestimate the number of households that are likely to form. However, there is no mention in the document of specific area targets, and it is thus unclear what contribution each local authority area, for example, should make to the overall national target for population growth. Without such area targets, how will the Scottish Government ensure local authorities and key agencies plan for population growth?

8. Including such area targets in the finalised NPF2 will give a clear direction to stakeholders throughout the planning system that they must also systematically plan for population and household growth in their City Region and Local Plans. Such plans should also take into account travel to work times, which if lengthy can act as a constraint on economic development. We commend West Lothian’s vision as an excellent example of where the local authority is planning for sustainable population growth, and where the private sector is meeting the challenge of delivering the projects. This joined-up approach ought to be replicated everywhere in Scotland.

DIRECTION TO AGENCIES

9. NPF2 provides a valuable opportunity to help deliver the Scottish Government’s aim of aligning all of the public sector behind the key purpose of enhanced levels of economic growth.

10. The NPF should be ‘owned’ widely across the public sector, and not just by the stakeholders directly involved in the planning system. To ensure that the right infrastructure (transport, water and sewerage, waste, energy, etc) is in place in a timely fashion to meet and facilitate development demand, all government and non-departmental public agencies and bodies should be directed – rather than advised - to align their business plans and budgets with the targets set out in the finalised NPF2. The presumption should be that well planned, sensitively thought through sustainable development is a positive thing, and that public agencies should attempt to promote such initiatives and should not use their powers to block this activity. Without such direction we remain to be convinced that the aspiration of a coherent and connected approach will be delivered, and that NPF2 will impact in practice on the actions of publicly-funded agencies and bodies.

11. City Region Plans and Local Plans must accord with NPF2, and state how each Plan will meet the economic and population growth targets. This direction ought to be included in the finalised NPF2.

12. CBI Scotland believes City Region Plans should be updated and approved within two years of the introduction of the finalised NPF2, and subsequently Local Plans within two years of the City Region Plans. The necessary capacity to undertake this work can if necessary be outsourced to the private sector. With the city regions rightly seen as the main drivers of the economy, the drafting of the City Region Plan should involve a regional reference group including the private sector and economists.

13. Where City Region Plans and Local Plans fail to accord with NPF2, or where they are not updated and approved within the timescales set out, then sanctions ought to be applied. In the event that Local Plans fail to deliver the NPF vision or are late, then there must be a presumption in favour of any planning application that accords with both the NPF and the City Region Plan, and which has met the necessary community consultation requirements. If a key agency fails to contribute to the development of a Plan then it should forfeit the right to be allowed to frustrate an application.

TRANSPORT

14. CBI Scotland welcomes the transport projects designated within the draft NPF2 as being of national importance, many of which we have consistently lobbied for.

15. However, we are concerned that several transport infrastructure projects of strategic important are not contained within the draft NPF2, and as such may therefore not be deemed of national significance nor deemed urgent. Examples of such projects were outlined in our recent manifesto65, and include:

The upgrading of the M8 to a three-lane motorway;
Construction of an M8 spur to Edinburgh Airport;
Complete dualling of the A9 from Perth to Pitlochry, with increased passing opportunities north to Inverness.

16. We are similarly disappointed that the draft NPF2 has as yet been unable to draw upon the published findings of the Scottish Government’s extensive Strategic Transport Projects Review. However, we understand that the STPR will be completed this summer and will presumably therefore form part of the finalised NPF2 document.

ENERGY

17. We are supportive of the energy-related infrastructure projects ear-marked as National Developments within the draft document, indeed CBI Scotland has actively lobbied for many of them. However, we do have concerns about the apparent lack of provision for certain replacement sources of energy generation. This must be addressed by the Scottish Government when it publishes its finalised NPF2 to ensure there is an appropriate and convincing long-term strategy for maintaining adequate and diverse sources of electricity. If this is not done, Scotland’s economy could suffer from a lack of competitively priced power.

18. The draft NPF2 document, for example, appears to omit a comprehensive appreciation of the significant contribution made by base-load (as opposed to intermittent) power generation, and the likely location of individual power plants in the future. The finalised NPF2 needs to draw upon the expected new base-load generating capacity as identified by the country’s leading power generators, acknowledging the lengthy lead in times to bring such plants to fruition.

19. The Scottish Government is right to highlight the potential of renewables, but is wrong to rule out new low carbon nuclear energy capacity in Scotland in the future. CBI Scotland believes the Scottish Government should enter into a proper dialogue with business and industry in Scotland on how our future energy needs will be met securely and economically, rather than what appears to date to be an out of hand dismissal of what is currently around a third of existing generating capacity north of the border. The publication of the Scottish Government’s forthcoming energy overview is an opportunity to address this.

20. New nuclear energy generation need not be at the expense of renewables and other low carbon sources - both have a role in delivering the country's energy supplies, and both ought to be adequately provided for in the finalised NPF2. Some new forms of renewables and environmentally-friendly technologies related to energy production face significant technical and commercial hurdles. Their feasibility and financial viability is yet to be proven, and indeed may only do so many years in the future. Tried and tested means of base-load generation must therefore remain a part of the energy mix, especially given the proven volatility of wholesale global energy markets and concerns over security of supply.

21. We acknowledge that the Scottish Government is currently opposed to new nuclear. However, we recognise too the transient nature of political administrations. As a result, and to ensure proper contingency planning has been undertaken should a future administration wish to alter policy, we believe that potential sites for new nuclear power generation should be identified and allocated now and provided for within the finalised NPF2. New nuclear generating capacity would meet the criteria66 which Ministers have identified in order to determine national developments. Failure to make adequate provision along these lines for the future could put at risk Scotland’s future as an exporter of electricity and provider to business and industry of competitively priced energy.

22. We support a strong emphasis on renewable forms of energy generation. However, there remains is a perceived lack of linkage between the ambitious national policies set by the Scottish Government and implementation at a local level. There is no mention in the draft document of specific area targets, and it is thus unclear what contribution each local authority area, for example, should make to the overall national target for renewable generation. Without such area targets, how will the Scottish Government ensure local authorities and key agencies plan accordingly?

CONCLUSION

23. It is right that there is and should continue to be extensive opportunity for individuals and communities to be involved in the development of planning policy. Indeed, it can be argued that there are more such opportunities, guaranteed under law, for public involvement in planning policy and decision making than in any other area of devolved public policy.

24. Recognising this, CBI Scotland believes that the finalised NPF2 provides a unique opportunity for the devolved government to deliver on their top priority and plan for growth, founded on the premise that Scotland in 2030 will have a larger and more dynamic economy, with a growing and wealthier population.This will help the Scottish Government realise its Economic Strategy and enhance the global competitiveness of Scotland as a business location.

25. The finalised NPF2 must underpin the successful reform to the planning system that CBI Scotland has long-called for, providing for a fit-for-purpose planning system that facilitates much needed commercial and public infrastructure investment and which breaks the cycle of frustration and delay that has bedevilled the system for too long.

26. The fundamental challenge remains the need for continued political leadership, both at national and local authority level, to drive forward the agenda so that all public agencies and bodies are responsible for and contribute to meeting the aspirations for growth. Failure to successfully reform Scotland’s planning system and make a success of NPF2 could put at risk the Scottish Government’s own welcome and ambitious targets for economic growth.

27. We would welcome any further opportunities to contribute to the consideration of the finalised NPF2 document, and to the drafting of the detailed action programme that will be published subsequently.

CBI Scotland
April 2008

Friends of the Earth Scotland submission on the National Planning Framework 2

1. Introduction

1.1 Friends of the Earth Scotland (FoES) welcomes the opportunity to provide its views on the second National Planning Framework to the Committee. This evidence has been prepared by Duncan McLaren, Chief Executive of FoES.

1.2 Friends of the Earth Scotland exists to help people in Scotland look after the planet for everyone’s future. We think globally and act locally in Scotland, delivering solutions to the problem of climate change by enabling and empowering people to take both individual and collective action. Friends of the Earth Scotland is an independent Scottish charity (SC003442) and an independent national member group of the Friends of the Earth International federation.

1.3 Friends of the Earth Scotland is an active member of Scottish Environment LINK and Stop Climate Chaos Scotland (SCCS). While this evidence reflects our understanding of the shared views of those coalitions, we understand they will make direct representations to the Committee, and this evidence should only be treated as the views of Friends of the Earth Scotland.

2. Summary

2. 1 We have focussed in particular on the second and third questions the Committee pose, namely the balance between economic development and environmental protection, and the extent to which proposals fit with the criteria set out by Ministers.

2.2 Friends of the Earth Scotland agrees with the principle of a statutory national planning framework to guide regional and local plans and development decisions in support of a dynamic economy, a healthy environment and a better quality of life for all our communities.

2.3 However we have major concerns regarding the procedural and substantive approach to national developments, and the overall compatibility of the NPF with the Scottish Government’s welcome aspirations to help address climate change. In this latter respect, and with respect to some other policies included in the NPF, we do not believe that the NPF as a whole can be expected to meet its statutory duty to contribute to sustainable development.

2.4 We therefore urge the Parliament to seek improvements in the policy content of the NPF to promote sustainable development and climate compatibility, and to seize the opportunity to begin the urgent transformation to and to recommend – in the strongest possible terms – that status as a national development should not exclude such developments from full scrutiny of need at a public inquiry.

3. Has the correct balance has been struck between economic development and environmental protection?

Sustainable Development duty

3.1 Under the Planning Act 2006 the NPF is required to contribute to sustainable development. This is a stronger test than a ‘balancing of economic development and environmental protection’. It requires an integrated delivery of economic progress, social equity and environmental health. For the duty to be delivered, the policies and proposals in the NPF as a whole must contribute to sustainability. It is not adequate for some measures to contribute to sustainability if others of significance detract from it. Moreover, while the statutory requirement does not apply to specific elements of the NPF, if it is desirable that the NPF as a whole contributes to sustainable development, it is clearly also desirable that every policy and proposal in the NPF contribute to sustainable development.

3.2 Friends of the Earth Scotland believes that the NPF on balance, and therefore as a whole, does not contribute to sustainability. This is principally because in practice it primarily takes a ‘predict and provide’ approach to issues with potentially severe environmental and social impacts, such as motorised transport; energy use and waste management.

3.3 For instance, despite clear aspirations to shift from motorised transport to more sustainable modes (para 21); the infrastructure proposals set out for transport (primarily summarised in para 109) suggest a significant increase in road capacity, likely to generate significant additional traffic; while the national developments identified include what has subsequently been acknowledged to be an additional Forth road crossing; as well as port developments predicated on increased heavy goods vehicle traffic at Loch Ryan (and at Rosyth) using Scotland as ‘a land bridge’ between Ireland and mainland Europe. These proposals detract significantly from the delivery of sustainable development; and indeed cannot comply with the outcomes outlined in paragraph 21.

3.4 The failure is further highlighted by the contradiction between reducing the need for motorised travel (para 22), and commitments restated from the National Transport Strategy to address congestion and improve journey times by road through engineering works. A sustainable approach would seek to reduce traffic levels, thus reducing congestion as a consequence of effective demand management; and improving health through the widespread expansion of active travel modes (notably walking and cycling). The National Planning Framework is the best place to pursue this approach as planning and transport policies must be integrated to deliver reductions in the need to travel, and opportunities to prioritise active modes. Unfortunately such integration has not been achieved, and the potential economic benefits of traffic reduction are foregone.

3.5 The failure to consider the role of demand management is also significant in the areas of energy and waste. Energy efficiency gets passing mention in paras 25 and 79, but as conservation and efficiency lie at the top of the energy hierarchy, they should be central to any discussion of energy infrastructure or building and planning standards. Waste reduction (as opposed to reuse and recycling) is not even mentioned. Yet reduced waste of energy and materials would both generate greater wealth, and reduce environmental impacts. Indeed both are central to the potential for sustainable economic growth – especially in the face of economic recession, where a ‘green new deal’ is needed to stimulate the economy. Recent proposals from the incoming US administration to invest $150 billion over 10 years in clean energy and create 5 million jobs67; and from the UN68 have highlighted the scale of the opportunity here. Yet the NPF has failed to grasp this opportunity.

3.6 The same failures make it much less likely that the Government will be able to achieve its climate change targets for emissions reduction (currently proposed to be a 50% cut by 2030 – although this is scientifically inadequate69; and an 80% reduction by 2050). Enabling growth in demand for mobility by road and air, growth in demand for energy, and growth in waste generation makes it much harder to deliver the levels of renewable energy generation, public transport and recycling that will be needed to deliver emissions reductions. The overall compatibility of the NPF with climate targets is addressed in the next section of this evidence.

Climate compatibility

3.7 There are significant proposals and policies set out in the NPF that would (other things being equal) lead to a significant increase in climate changing emissions. The framework provides for additional road transport capacity, and enables growth in air travel (para 116);; indicates increased combustion of waste for energy purposes (para 164) (even though typical incinerators are more polluting than coal fired power stations per unit of electricity produced); and promotes a significant increase in housing provision (para 72) (which even with improved building standards still adds to overall emissions from the building stock). These are of particular concern because the scientific evidence on climate change argues that significant reductions in emissions in the coming five years – the period covered by the NPF 2 – is critical to stabilising the climate. Action cannot be postponed to NPF 3 or 4.

3.8 For the proposals in NPF 2 to be compatible with climate targets would require very significant improvements in technology to be delivered and adopted across the existing and replacement stock of buildings, facilities and vehicles. This is unlikely on the timescale of the NPF, and moreover, the NPF does not set out any policies or other measures to enable the planning system to help force the delivery and adoption of such improvements. In the absence of such policies the NPF2 is incompatible with climate targets.

3.9 Such concerns are most acute with respect to major long-lived developments such as the additional Forth Crossing, power stations and airports. The climate effects of a decision taken today will be felt for many decades, and in most cases well beyond 2030 or 2050. It is therefore particularly significant for proposals designated as national developments.

3.10 Several climate threatening candidates for national developments – such as road improvements around Dundee and on the A90 - considered in the strategic environmental assessment have not been included in the NPF. This is welcome, as their exclusion from the list of national developments may indicate that Ministers do not consider the need for them has been demonstrated. However their inclusion in the Strategic Transport Projects Review leads us to fear that they may not be subjected to the rigorous scrutiny of a public inquiry that is properly allowed to consider the need for the road. The very limited scope of the recent inquiry into the Aberdeen Western Peripheral Route has demonstrated the need for full and comprehensive scrutiny.

3.11 Given uncertainties about developing technologies for abatement of emissions from road vehicles, aircraft and power stations, Friends of the Earth Scotland believes it is irresponsible to designate airport capacity increases, road capacity increases or new unabated fossil fuel power stations as national developments. The climate implications are not simply a matter of design or location – they are typically fundamental to the existence of the development. A decision in principle on such developments should therefore only be considered in the light of best available knowledge as to technological options through a rigorous and participatory process. The level of assessment provided by the NPF and the accompanying SEA is not adequate to make such decisions. Even though Friends of the Earth Scotland is optimistic regarding the likely future development of electric vehicles and carbon capture and storage technologies (cf para 69-70), the developments as currently set out in NPF2 are incompatible with the delivery of Scotland’s climate targets.

3.12 For instance regarding airports, it is unclear how proposals for new runways would be assessed within the current NPF. It does not appear that land is being set aside for new runways but the NPF expresses enthusiasm about increasing international connectivity and includes airport enhancements designed to enable increased passenger and freight movements as national developments. The second NPF suggests that growth at Scotland’s international airports will be facilitated through a mix of access enhancements and surface measures such as new taxiways and hangar facilities. In the last decade growth in air travel has driven annual increases in emissions from the sector in Scotland of 7% a year since 1990, and almost 9% a year in the last decade70.

3.13 However, the climate implications of growth are a simple factor of the number of flights and the efficiency of the aircraft. The design and location of new public transport links, hangars, terminal buildings and so forth will have negligible impact on climate implications. Estimates suggest aircraft efficiency could improve by 1-2% per year71. So simply to hold emissions stable, flight numbers must not grow more than this. To contribute to the target reductions in emissions it is necessary for flight numbers to fall. Using the NPF to designate measures to increase air travel as a national need therefore sends the wrong message when urgent action on climate change is needed.

3.14 In some other respects the NPF makes substantial efforts to contribute to the delivery of climate targets – notably in its approach to renewable energy and transmission developments. In the energy sector, we are encouraged to see plans to deliver Scotland’s renewable energy targets, strengthen the electricity grid to enable renewables and to provide for Scotland’s future energy security. However, we note that the development of the grid needs to respect sustainability criteria – both with respect to the location and design of new capacity; and to the strategic role of demand management. We are also encouraged, despite over-optimism regarding the potential for energy from waste, to see strong and positive reference to renewable heat and the decentralised production of energy, which offers significant potential for mitigation of climate changing emissions. However for the reasons set out below with respect to procedure, Friends of the Earth Scotland cannot endorse the application of ‘national development’ status to such proposals either.

3.15 More generally the energy systems analysis is partial and in some respects poor, notably in its failure to properly consider demand management and efficiency (see above) and in relying on a combination of a misconceived notion of ‘baseload’ demand and a meaningless commitment to ‘carbon-capture readiness’ to justify continued fossil fuel use. New coal power capacity at Longannet, Cockenzie and Peterhead must feature fully operational carbon capture and storage technology from the outset or be refused planning permission. It should not therefore be designated as of national need. Instead the NPF should establish the principle of a strictly enforceable emissions performance standard for new combustion plant.

4. Do the proposals listed as potential national developments meet the criteria set out by Ministers in a statement to Parliament on 13 September 2007?

4.1 Ministers set out six criteria. Whilst it is clear that not every development must meet every criterion, in his statement to Parliament the Cabinet Secretary for Finance and Sustainable Growth argued that they would be applied in a transparent and ‘joined-up’ fashion. The Cabinet Secretary also made clear that all the developments would be critical for the delivery of sustainable economic growth.

4.2 In our view these tests have not been demonstrated for many of the national developments included. Most of them could be compatible with a sustainable economy, but only if other conditions were also met (such as particular technological advances). In the current circumstances several of them might not even generate additional economic activity, but instead may simply redistribute it - most notably the additional Forth road crossing – or even generate an economic loss for Scotland. Increasing passenger numbers through Scottish airports could actually worsen the balance of trade, as expenditure by Scots travelling abroad significantly outweighs expenditure in Scotland by visitors72. In other cases there may be an increase in economic activity, but not one which is sustainable. The Loch Ryan gateway port may increase HGV traffic through Scotland, with some additional economic activity, but as Switzerland has discovered, such through traffic imposes excessive environmental, congestion and economic costs as well. None of these developments are compatible with the subsidiary climate criterion either, and thus the aim of ‘joined-up’ consideration has not been achieved.

4.3 We are also not convinced that the proposals for additional baseload electricity generation capacity adequately meet the criteria. Given Scotland’s increasing levels of renewable electricity generation, what is needed for the economy is a combination of ‘load-following’ or ‘peaking’ plant (not baseload) and improved electricity storage. This might be provided by fossil fuel in ways compatible with climate objectives but only if such plant operates with full carbon capture and storage from the outset. Additional generation capacity is not needed so urgently that unenforceable rules for carbon capture readiness are appropriate73.

5. Process

5.1 The Committee has not specifically requested evidence around process and procedure. However, these are crucial considerations and we urge the Committee to take them into account during the scrutiny period. Friends of the Earth Scotland has concerns regarding both the consultation process surrounding the NPF, and the proposed procedure for the national developments.
5.2 The consultation and participation procedures around the draft NPF have not offered an adequate alternative to a rigorous public inquiry. Research carried out by the independent consultancy ‘Building Alternatives’ indicates that the procedures provided fell well short of the commitments made in the Government’s ‘Participation Statement’ as well as failing to meet most of the ten National Standards for community engagement. There has been no parallel research into the effectiveness of the consultation process from the perspective of local authorities and statutory consultees, but the limited information provided on candidate national developments would suggest that such bodies would be unable to adopt properly informed positions on the need for the developments or their likely impacts.

5.3 In Friends of the Earth Scotland’s view, the main purpose of the NPF should be to direct Scotland’s planners as to how they can contribute to sustainable economic growth through a properly participative development planning process; not to mandate specific developments as ‘national priorities’ on the basis of a sketchy assessment.

5.4 Friends of the Earth Scotland believes that such priority projects should still be subject to proper democratic accountability by local people and local politicians. As it stands, such proposals could be held up far longer in legal wrangling than by a planning inquiry.

5.5 We fear that the process has been motivated by a misplaced belief that rapid decisions and greater certainty can be delivered to underpin economic growth. In practice we suspect that this approach to national developments will do less for the economy than one in which proposals are democratically and rigorously tested by the planning system to ensure they contribute to sustainable growth. If these national developments are challenged by objectors in the courts or protestors on the ground, delay could easily exceed the few weeks or months required to consider need at a planning inquiry. Delays could be particularly severe if challenges arose under European law with respect to participation, or the impacts on habitats protected by European law (which are potentially affected by at least four of the 12 proposed national developments). We note that for sound reasons, decisions affecting such sites should be made in a single instance, at which point the relevant tests - of whether there is no alternative site meeting the same economic or social need elsewhere in the European Union, and whether the economic or social need is of such overriding importance that it justifies the level of damage - can be properly applied.

5.6 In conclusion, Friends of the Earth Scotland urges Parliament to review the national developments in as much detail as possible, and to reject those which do not match its assessment of the criteria. More importantly, given the constraints on such assessment, we urge Parliament to recommend – in the strongest possible terms – that status as a national development should NOT exclude such developments from full scrutiny of need by way of a public inquiry.

January 8th 2009

Sustainable Development Commission Scotland submission on the National Planning Framework 2

1. Introduction

a. The Sustainable Development Commission
The Sustainable Development Commission Scotland (SDC) is the Scottish Government’s independent advisor on sustainable development.

The Commission publish an annual review of the Government’s progress on sustainable developmentand reports to the First Minister of Scotland on key policy areas including planning, transport, energy, the economy, climate change, governance and food. We help government, local authorities and businesses put sustainable development at the heart of what they do.

At a UK level the Sustainable Development Commission has 19 Commissioners and a secretariat of 50 staff. There are two Scottish-based Commissioners, Professor Jan Bebbington and Hugh Raven, supported by a secretariat led by Scottish Director Maf Smith. Commissioners and secretariat work with Scottish Government departments and agencies to promote sustainable development. We also work with a range of other organisations, such as the Scottish Sustainable Development Forum and the Sustainable Scotland Network.

b. Defining Sustainable Development
The Commission supports the Scottish and UK Governments’ definition of sustainable development as being based on 5 principles (overleaf). Two of these five principles represent the desired outcomes of policy action, namely that we should:

  • Live within environmental limits
  • Ensure a strong, health and just society

Three of the principles are mechanisms to help achieve these two ends, namely

  • Achieve a sustainable economy
  • Use sound science responsibly
  • Good governance

We regard planning policy as essential to the delivery of a more sustainable Scotland. Scottish planning policy should therefore be aligned with the 5 principles and have as its core aims the creation of a socially, economically and environmentally sustainable country.

Shared UK principles of sustainable development


Figure 1: Scottish and UK Government’s shared framework: principles for sustainable development(Source: Choosing Our Future: Scotland’s Sustainable Development Strategy, December 2005)

2. Planning and Sustainable Development

As noted above, the Commission regards planning policy as fundamental to the delivery of a more sustainable Scotland. In our recently published assessment of progress by the Scottish Government on sustainable development74 we identified the creation of a sustainable approach to planning and infrastructure as one of the 5 key challenges facing Scotland.

The Commission believes that of particular importance in this context is ensuring that all Government strategies and frameworks help contribute to significant reductions in Greenhouse Gas (GHG) emissions as set out in the Scottish Climate Change Bill. This commitment is also embedded in the Government’s Economic Strategy and so must underpin both the general approach and the specific developments outlined in the National Planning Framework 2 (NPF2).

Achieving a sustainable approach to planning will require a significant shift from that taken to date at national and local level in Scotland - policies over recent decades have not moved Scotland towards sustainability. Too many communities have been created which are poor in quality and which suffer high rates of crime and social disadvantage; much development has been low density and based around road transport; housing has been developed separately from places of employment and leisure; and development has been inefficient in its use of energy and resources.
Looking forward it is essential that all future planning decisions in Scotland help moves us to a more socially, environmentally and economically sustainable society. Given the lifespan of most buildings and infrastructure, poor planning decisions taken now will lock Scotland into many more decades of unsustainable development.

3. Overall Appraisal of the National Planning Framework

The Commission believes that the new Framework is set more clearly within the principles of sustainable development than its predecessor. The stated aim of the new Framework, as set out in the Planning etc (Scotland) Act 2006, is to contribute to sustainable development. At a broader scale the Framework is intended to be closely aligned with the Government’s Economic Strategy which has a commitment to ‘Sustainable Economic Growth’ supported by targets and commitments on Solidarity, Equity and Sustainability.

The Commission also welcomes the commitment to long-term planning (to 2030) set out in the Framework. This long term perspective is essential in helping align development to the aims of sustainable development.

We believe that in general the Framework also highlights many of the social and economic challenges facing Scotland. We also welcome the commitment to publish further planning guidance on sustainable development in 2009.

However we do have a significant concern, namely that the infrastructure and transport developments proposed or supported by NPF2 will not contribute towards a lower carbon Scotland.

Appraisal of National Developments

The Framework sets out a list of twelve national developments. A broad outline of each of the development proposals is provided in the Annex of the Framework along with a basic appraisal of the contribution of each development to the five Strategic Objectives of Government (Wealthier and Fairer, Smarter, Greener, Safer and Stronger, Healthier) and to a range of other criteria (to contribute to sustainable economic development; help to meet climate change, renewable energy or waste management targets; strengthen global links; etc).

Many of the national developments are of strategic significance and could be expected to deliver economic benefits. However, eight of the twelve projects are likely to lead to significant increases in emissions at a time when, as noted above, the Government is looking to make significant cuts in greenhouse gas emissions.

Of the other four national developments, one is transport related (West of Scotland Strategic Rail Enhancements) and three concerned with energy generation. We address the overall impact of planned transport infrastructure in the next section.

Regarding the proposals for investment in energy infrastructure, we welcome the commitments made to reinforcing the electricity grid, important as they are in exploiting Scotland’s renewable energy resources.
We do though have some concerns regarding the proposals for Hunterston and for new non-nuclear baseload capacity. Our primary concern is related to the equating of ‘carbon capture readiness’ with the actual delivery of low carbon generation capacity.

Carbon capture and storage has great potential to contribute to a lower carbon economy. It is not as yet developed to an extent where it is proven to work effectively and efficiently. Our concern is therefore that new fossil fuel plant could be given approval without any guarantee that it will indeed deliver low carbon energy in the future.

4. Transport and the National Planning Framework 2

The NPF2 includes a section on Transport (page 5) which recognises the high greenhouse gas emissions from the sector and the need to develop an approach to planning and to transport infrastructure that seeks to cut these emissions.

Transport developments feature significantly in the list of national developments, including plans for a replacement Forth Crossing, for Rail Enhancements, for Airport enhancement and for freight infrastructure investment. Also important in assessing the impact of transport infrastructure plans on carbon is the recently published Strategic Transport Projects Review (STPR).

The Commission’s concern is that, while there are aspects of the investment programme that are welcome, the overall impact of transport investment plans will be to increase greenhouse gas emissions despite one of the core aims of the National Transport Strategy being to reduce emissions.

The STPR states that the 29 projects outlined would together reduce emissions by 1% by 202075. However, although this is not clearly stated, this is actually only a 1% cut compared to business as usual – in other words it is a 9% increase in emissions. The achievement of the Government’s targets for greenhouse gas emission reductions will therefore require far more significant emission cuts to be achieved elsewhere in the economy.

Submission from ScottishPower on behalf of SP Transmission Ltd on the National Planning Framework for Scotland 2

SP Transmission Limited (SPTL) is the regulated transmission business which owns and maintains the electricity transmission network in central and southern Scotland. The National Planning Framework plays a key role in enabling strategic investment priorities for Scotland and, in particular, we support the designation of electricity transmission investment as a national development. We regard the prompt delivery of further electricity transmission capacity as being a fundamental enabler in meeting the Scottish Government’s renewable electricity energy targets.

Industry Structure
Since 2005, the licensing of electricity networks has been on a GB basis in order to support a single GB electricity market. National Grid Electricity Transmission Limited (NGET) as the Great Britain System Operator (GBSO) operates and manages access to the transmission system. Three transmission owners (SPTL, SHETL and NGET) maintain their transmission assets and, in coordination with each other and the GBSO, identify necessary reinforcements to their transmission system.

The transmission owners have a duty under their transmission licences to develop and maintain an efficient, co-ordinated and economical system for the transmission of electricity. The industry regulator, Ofgem, must ensure that the companies are able to finance the activities stemming from their licence obligations.

Identification of Transmission Reinforcements to Facilitate Renewable Generation
The dominant driver for transmission reinforcement works in Scotland has been connection applications by new renewable generation development projects. Before a windfarm developer can connect to the network, it is important to ensure that the Main Interconnected Transmission System can support this new generation. In 2002, the three transmission companies began studying transmission options for accommodating significant increases in the level of renewable generation in Scotland. The outcome of this work was a series of transmission reinforcements as set out in Map 8 of the NPF2 proposed framework. The table below details progress on reinforcements in SPTL’s area.

Renewables targets have increased significantly since the initial study was undertaken and in 2008 the Electricity Networks Strategy Group (ENSG) commissioned a study, to be undertaken by the transmission companies, on the development of the transmission network required to meet the UK target of 20% of all energy to be met from renewable sources by 2020. The initial conclusions of this study confirm (i) the need for the transmission reinforcements set out in NPF2, and (ii) the need for further incremental onshore reinforcements and two offshore subsea links. Any reinforcements that proceed will be part of a co-ordinated development plan across the GB transmission network, which will be implemented in incremental stages and avoid unnecessary investment.

Financing of Transmission Investment
The process for obtaining funding for transmission works involves an assessment by Ofgem of the works required and, if accepted, a licence change to reflect increased investment. Usually this funding process is managed as part of a regular five-yearly review. We regard these arrangements as being a proven mechanism to incentivise the transmission owner to deliver optimal, cost-efficient transmission investment and we believe that they should continue.

However, given the potential scale of future transmission investment beyond 2012, and the urgency to deliver this investment as quickly as possible, we agree that there is a need to look at future funding of major transmission infrastructure projects. In order to address the longer-term investment challenges, Ofgem and the Department for Energy and Climate Change have initiated work with the transmission licensees to develop new financial incentives to help deliver the necessary investment in a timely manner without exposing customers to excessive risk and/or inefficient costs.

9th January 2009

Table Transmission Reinforcements in SPTL’s Area

Central Scotland
(Boundary B5)

On schedule to complete by 2010.

A further incremental reinforcement, using existing overhead lines but requiring new substation consents at Wishaw, Kincardine and Harburn, is being considered by the ENSG.

Scotland-England
Interconnector
(Boundary B6)

The upgrade to increase capacity from 2200MW to 2800MW is on schedule to complete in 2010. The next upgrade to increase capacity to 3400MW is planned for completion in 2012.

A further incremental reinforcement to increase capacity to 4400MW, using existing overhead lines but requiring substation consents at Strathaven, Elvanfoot and Eccles, is being considered by the ENSG.

Sloy

Joint project with SHETL to establish a transmission substation near Inverarnan. Works underway and on schedule to complete in 2010.

South West
Scotland

We are about to submit Section 37 applications for a new overhead line network from our existing substation near Coylton southwards to near Dalmellington and then west towards Sanquhar.

Not in NPF2

Hunterston to Deeside HVDC Link

The ENSG are considering a new west coast offshore link from Hunterston to Deeside near Chester (circa 1200MW to 1900MW).

Peterhead to NE England HVDC link

The ENSG are considering a new east coast offshore link from Peterhead to North East England (circa 1200MW to 1900MW).

SHETL Response

  • 1. Key points

    Scottish and Southern Energy welcomes the inclusion of strengthening the electricity transmission system in the new National Planning Framework (NPF2), and recommends that the Scottish Parliament strongly supports this particular Candidate National Development.
  • Upgrading the electricity grid system is vital to facilitate renewable energy and to reduce carbon emissions, as recently highlighted in Scotland’s Sustainable Development Commission report on Scottish Government progress towards sustainable development in its consideration of the National Planning Framework76.

    The bulk of the electricity grid upgrades covered by the NPF2 would be similar in environmental impact to routine maintenance activity, with some substation works and no new major overhead routes.

    Additional grid capacity is not only needed for larger scale renewable projects – it is also essential for small-scale and community level projects from being able to feed electricity into the grid.
  • It is important to recognise that the NPF does not remove any project from local planning or consultation processes. What it does do is recognise the broad need for the development as nationally significant.

2. Introduction

Scottish Hydro Electric Transmission Limited (SHETL), part of the Scottish and Southern Energy plc group, is the regulated transmission business which owns and maintains the transmission system in the north of Scotland. Pursuant to both its statutory and licence obligations, it is responsible for the development of that system to accommodate generation customers and the transfer of power from generators to demand-side customers.

The Scottish Government has set a target of generating 50% of the electricity requirement from renewable sources by 2020. Furthermore it is also committed to working towards deriving 20% of all energy use from renewable resources by 2020, in line with EU objectives.

Taking this into account, some of the key elements of the National Planning Framework (NPF2) spatial strategy include:

  • To support strong, sustainable growth for the benefit of all parts of Scotland,
  • To promote development which helps to reduce Scotland’s carbon footprint and facilitates adaptation to climate change,
    To support sustainable growth in the rural economy, and
  • To realise the potential of Scotland’s renewable energy resources and facilitate the generation of power and heat from all clean, low-carbon sources.

In order to harness Scotland’s significant renewable resources, the electricity grid system requires upgrading. Without this, Scotland’s renewable energy development potential will falter. NPF2 correctly identifies the need for substantial upgrading of the electricity transmission network if the aspirations of Government and renewable energy generators are to be met.

More specifically, the NPF2 recognises that ‘These strategic grid reinforcements are essential to providing the transmission capacity necessary to realise the potential of Scotland’s renewable energy resources, maintain long-term security of electricity supply and support sustainable economic growth’.

The NPF2 also recognises the need for delivering these transmission system upgrades quickly so that significant renewable energy developments can be accommodated onto the system, such that the transmission system does not act as a barrier.

The lack of grid capacity is not only affecting larger scale renewable projects – it is also threatening small-scale and community level projects from being able to feed electricity into the grid.

The proposed Beauly-Denny rebuild, currently awaiting the outcome of a public inquiry process, is important in developing a transmission system in the north of Scotland of sufficient capacity to accommodate renewable generation developments. With the upgrade of Beauly Denny it will be possible for the further capacity improvements on the north of Scotland transmission system, identified in the NPF2, to be achieved making maximum use of the existing infrastructure and overhead line routes through relatively uncontentious re-conductoring and re-insulation work similar in impact to routine maintenance activity. The Candidate National Development upgrades and reinforcements identified in the NPF2 will all be required if Scotland is to deliver its 50% renewable electricity target by 2020. These projects need to be started very soon in order to be in place by the target date.

Beyond these reinforcements, and to accommodate potential further volumes of renewables, consideration is being given to subsea cabling for point to point transfer of power from coastal hubs for export to England and to link in with the European Grid directly from Scotland.

3. Role and licence obligations of SHETL as a Transmission Owner

There are three transmission licensees in GB: SHETL, SP Transmission Limited (SPT) and National Grid Electricity Transmission plc (NGET). All three licensees are Transmission Owners that own and maintain transmission systems. NGET is also the GB System Operator, responsible for co-ordinating and directing the flow of electricity onto and over the GB transmission system.

All three GB transmission licensees have a duty under the Electricity Act 1989 to develop and maintain an efficient, co-ordinated and economical system for the transmission of electricity. They also have a duty to facilitate competition in the generation and supply of electricity.

The GB transmission licence obliges Transmission Owners to make their transmission systems available for the purposes of conveying electricity. When new users (generation or demand) apply for connection to the GB transmission system, the Transmission Owners are obliged to offer to enter into an agreement for connection that includes details of the work required on the licensee’s transmission system.

4. Identification of Reinforcement requirements

Proposals to reinforce the transmission system are developed largely in response to customer requirements, together with an ongoing work programme to maintain and replace existing assets. Since 2000, the dominant driver of work on the Scottish transmission system has been applications for connection by new renewable generation projects.

In 2002, the three transmission licensees undertook a detailed study of how the GB transmission system could be developed to accommodate significant increases in the volume of renewable generation in Scotland. The resulting report proposed options for transmission network development to provide grid capability for new volumes of renewable generation in Scotland.

There was a significant upsurge in applications from renewable generation developers in 2004, in response to which the upgrade proposals were refined to align with the volumes and geographical location of contracted generation.

SHETL has identified grid projects that would provide capacity for around 5GW of new renewable generation in the north of Scotland. These projects include the proposed Beauly-Denny rebuild (currently awaiting a planning decision) and the Inverarnan substation reinforcement in Argyll & Bute (currently under construction). The further projects are currently under design and pre-consenting works.

These reinforcements, included in NPF2, have been identified to meet the needs of contracted generation developments, and to meet the Scottish Government target to deliver 50% of electricity demand to be provided by renewable energy by 2020.

Design and consenting work is currently being undertaken on these projects. The main factors that will determine the timing of construction work are the granting of necessary planning consents (for both generator and network developments) and the outcome of economic appraisal necessary to secure regulatory funding approval. Planned completion dates extend from 2010 to 2015.

A further study is currently underway to identify the GB transmission requirements that would be required to meet the UK target of 20% of all energy to be met from renewable sources by 2020.

5. SHETL input to ENSG Transmission Investment Options study

The overall approach of industry, OFGEM and the Whitehall and Scottish governments seeking to work in an integrated way to outline necessary infrastructure is a positive and necessary approach to co-ordinating government targets, developer aspirations, market requirements and integrated and funded transmission development.

In 2008, the UK Government asked the three transmission licensees to undertake a study of the development of the GB transmission that would be required to accommodate the UK target of 20% of all energy to be met from renewable sources by 2020. This study builds on the co-ordinated work of the licensees in planning for renewables that was begun in 2000. The licensees’ report is due to be completed in early 2009.

The initial conclusions of this study confirm that the necessary projects included in NPF2 for transmission upgrades in Scotland form the basis for meeting and accommodating current and future renewable generation requirements. The NPF2 projects will give Scotland a solid foundation upon which to build for the future. In the immediate term, the included schemes in the north of Scotland allow for around 5GW of renewable generation to connect in the north of Scotland. In the longer term, further renewable generation, whether onshore or offshore/marine technology, can be developed and connected in the area by the use of either offshore subsea cables or by continuing the upgrading of the mainland system.

Appendix
The Role of the Regulator And Transmission Upgrades

The electricity and gas industries in GB are regulated by the Gas and Electricity Markets Authority (GEMA), which is supported by the Office of the Gas and Electricity Markets (Ofgem).

GEMA’s powers and duties are largely provided for in statute; those relating to electricity are set out in the Electricity Act 1989. The regulator’s principle objective when carrying out its functions is to protect the interests of present and future customers.

The Electricity Act 1989 sets out a number of factors which the regulator has a duty to consider when carrying out its functions. The primary duties of the regulator include: the need to secure that all reasonable demands for electricity are met; and the need to secure that licence holders can finance their functions. Further duties relate to economy and efficiency by licence holders, the achievement of sustainable development and long-term energy security.

It is with respect to these factors that Ofgem assesses proposals to develop the GB transmission system. If Ofgem determines that a licence holder’s proposals are justified then it will allow the licence holder to recover its costs from its customers.

The three transmission licensees have made two submissions to Ofgem with proposals to develop the GB transmission system to accommodate new renewable generation in Scotland: the Transmission Investment for Renewable Generation (TIRG) review in 2004, and the Transmission Price Control Review (TPCR) in 2005-06.

As a result of the TIRG review, Ofgem determined that SHETL’s proposals for Inverarnan substation and the Beauly-Denny upgrade were justified. In 2005, SHETL’s transmission licence was modified to include specific funding for the two investment projects.

Further modifications were made to SHETL’s licence following the TPCR. These allow SHETL to recover its expenditure on the pre-construction (design and consent) of network reinforcements during 2007-12. In addition, a mechanism was put in place to allow SHETL to recover the cost of network reinforcement. This mechanism (the revenue driver) is triggered when the volume of generation connected in a geographic area exceeds a given level.

In summary, SHETL’s transmission licence currently allows funding for the Inverarnan substation project, the Beauly-Denny upgrade project and pre-construction of further network reinforcements included in NPF2. There is also a mechanism to allow recovery of the construction costs of further network reinforcements when trigger conditions are met.

Following the Review of Transmission Access co-ordinated by the UK Government and Ofgem in 2007, Ofgem concluded that it was appropriate to review the current approach to regulatory funding of reinforcements to the GB transmission system. The intention of this review is to out in place enhanced financial incentives on transmission licensees to encourage them to anticipate future demand from generators and invest efficiently to meet that demand. Ofgem published its initial consultation in December 2008, and expects this review to conclude in winter 2009.

Highlands Before Pylons submission on the National Planning Framework 2

Highlands Before Pylons is anxious to bring the following considerations before the committee as you scrutinise the NPF2 draft proposals for transmission infrastructure. We would be happy to provide further technical information in support of our case.

Our campaign to prevent the construction of a line of 50 metre high pylons between Ullapool and Beauly has been a partial success. SHETL has lodged a proposal for planning permission for an underground cable from Dundonnell to Beauly. This of course could be overruled by Ofgem on grounds of cost to the consumer.

During our campaign we researched and vigorously argued for a sub sea alternative, specifically a sub sea cable from Stornoway to Hunterston or even further south.

We also joined the Beauly Denny debate pointing out that reinforcement of the current grid combined with subsea cables down both the east and west coasts could cater for the transmission needs of Highland for the foreseeable future.

Since the Beauly Denny proposal was subject to inquiry, when we attended the Inverness consultation on NPF2 we were told we could not discuss it and that NPF2 was not based on an assumption that Beauly Denny will be approved.

However the objective evidence is that NPF proposals for transmission are based on all of SSE previous plans. We pointed out to Mr Jim Mackinnon that an arrow on the maps 18 and 20 pointed to a subsea link with the mainland of Wester Ross. There was no arrow for a putative subsea link with Hunterston, a route favoured by AMEC at the time as part of the Lewiswind project. He promised to consider this omission but the Plan has gone forward with no suggestion of a west coast subsea link.

In the meantime plans are advancing rapidly for subsea grids not just round the coast of Scotland (excluding the North West) but to serve Europe. We would earnestly ask the committee to question the logic of this apparent determined commitment to an overland transmission interconnector to Beauly, with an as yet unspoken commitment to the Beauly Denny upgrade without which the published plans do not make sense, when subsea cable links could carry energy from the Western and Northern Isles direct to its southern markets.

We have lobbied long and hard on this subject in the hope that at some point it must be possible given the far-reaching scope of NPF2 for a fresh look at SSE's now elderly proposals and for some genuine forward planning for transmission in our area. We'd be very happy to talk to members of the committee about our view of the best way forward for Northern Scotland's transmission needs.

John Muir Trust submission on the National Planning Framework 2

Background on the John Muir Trust

1. The John Muir Trust is a Scottish based charity whose aim is to conserve and protect wild places with their indigenous animals, plants and soils for the benefit of present and future generations. A major emphasis throughout all of our work is the recognition of the important role that local communities have in the management and care of their “wild landscapes”. The Trust owns eight areas of wild land and works in partnership with local communities on several other areas of wild land.

2. Whilst our overriding concern is the protection of wild places, we understand the need for many landscapes to evolve and change as technology and communities evolve and change. It is of critical importance that local communities have a real say in those changes – how they are managed, how to minimise any adverse impacts on the communities and whether adverse changes are actually necessary, taking into account both the national interest and the local one.

3. The Trust uses its experience with communities, and its involvement in site-specific planning issues, to inform its policies on national, strategic issues. The Trust’s aim to protect and enhance wild land has led to it gaining extensive experience on strategic energy and transmission issues, aided by advisors who are experts in this highly specific field.

4. The Trust is a member of Scottish Environment Link and is one of the signatories to the SE Link submission on the NPF2 and we completely support that submission. The points raised in this individual submission do not duplicate that submission but are additional, in areas of policy where the Trust has particular knowledge and expertise – either internally or through advisors.

National Developments – more significant than third party right of appeal?

5. Proposed National Developments are at very varied stages of the planning process. This means that, for some, there is not enough information to assess the need for that particular project. This is a critical issue since designation in the National Planning Framework is the mechanism for establishing the need for these developments and any subsequent examination of the detailed planning implications will not be concerned with the principle of the development. Therefore it is essential that Members of the Scottish Parliament assure themselves that the “need case” was proven.

6. It is critical that the National Planning Framework does not become a vehicle for fast-tracking controversial decisions, using the “national interest” argument to rule out any rigorous examination of the plan by all interested parties. This would be a dangerous erosion of democratic rights. This is of concern for a number of the National Developments but the John Muir Trust response concentrates on the one on which we have considerable expertise – the grid infrastructure.

7. Our opposition to this proposal being included in the National Developments is despite the fact that the John Muir Trust is very much in favour of some of the grid development included - i.e. the North East Coast route - and has not formed particular views on most of them. The Trust opposes the inclusion of these many developments as a single National Development, for the following reasons.

Proposed National Development 10 - Electricity Grid Reinforcements

Need for development

8. The statement of the need for these ten developments in the NPF2 is, in its entirety –
Need for development
These strategic grid reinforcements are essential to providing the transmission capacity necessary to realise the potential of Scotland’s renewable energy resources, maintain long-term security of electricity supply and support sustainable economic development.” However, this is a statement of the need for upgrading the grid in Scotland – not for doing it in this particular way.

Suitability of the candidate as a National Development

9. In the National Planning Framework 2 SEA Supplementary Assessment, the following criteria were listed as having been used to assess candidate National Developments as reasonable alternatives.
1.11 ………because they
a. raise significant planning issues that require to be addressed;
b. are at an appropriate stage in the planning process (i.e. planning or equivalent consent has not already been granted);
c. are transport, energy or environmental infrastructure projects, as opposed to more complex development proposals likely to involve multiple planning and other consents; and
d. are sufficiently defined to allow for a meaningful environmental assessment.”

10. Of these four criteria, the Energy Transmission Infrastructure fails to fulfil the third and fourth ones. The third criterion is that the projects “are transport, energy or environmental infrastructure projects, as opposed to more complex development proposals likely to involve multiple planning and other consents”.

11. Although this is an energy infrastructure proposal, there are ten separate transmission projects throughout Scotland included in this “single” Candidate National Development. Each of those is likely to involve several different planning/Section 37 of Electricity Act applications. This does not seem to fit with the description “as opposed to more complex development proposals”. Each one of the ten is a complex development proposal in itself.

12. The fourth criterion is that they “are sufficiently defined to allow for a meaningful environmental assessment.” The ten proposals included in this one are at varying stages of development. However, the Scottish Government team doing this Strategic Environmental Assessment (SEA) agreed, in the consultation meetings, that there was not enough information for a comprehensive SEA to be done on these transmission proposals – unlike some other proposed National Developments. The team also agreed that further work would need to be done before the SEA could be said to have adequately considered alternative routes for each of these ten transmission routes. There is no evidence that this necessary assessment has been done.

13. This Candidate National Development is the odd one out in the proposed NPF2– it includes ten developments which are scattered throughout the country and which are not spatially defined. The equivalent for the road network would be to say “ road upgrades at the A9, the A96, the A1, the A90 and any associated ring roads” count as one National Development. In fact, each of these possible road developments is put forward as a spatially defined, individual, Candidate National Development and the Trust believes the transmission proposals each also need separate consideration.

Strategic Environmental Assessment

14. The assessment of the grid proposals in the Strategic Environmental Assessment is very fair and notes a fairly equal number of negative and positive effects. There is absolutely no record of those negative effects in the final document so it is hard to see any indication that the SEA was considered or used to revise the final NPF2.

15. There is a common misunderstanding that “grid upgrades” are not as significant for either landscape or local amenity as, say, a road. In fact, the scale and size of the infrastructure which is referred to, in the phrase “Energy Transmission Infrastructure”, is of a scale that has not been seen in Scotland, except in a few urban hubs. One difference from those urban sites is that some of these proposed projects are passing through some of Scotland’s most scenic areas, critical for tourism and our heritage.

The separate roles of Ofgem and the planning system

16. One significant reason for not including the grid infrastructure in bulk as a single National Development is because each major proposal in that group, should be assessed as a planning application, as and when they come forward. These proposals have been included in the draft NPF2 because the transmission regulator, Ofgem, has considered there is a valid case for them. However, Ofgem’s role is to consider the commercial case for any proposed development which is placed before them, including the cost to the consumer - taking into account the electricity security standards (GBSQSS). Ofgem are on record as saying that they are “the judge, not the presenting solicitor” i.e. they can only assess the proposal before them, not look to see whether there is a better way. It is the planning system’s role, not that of Ofgem, to assess whether the development can go ahead - after considering all aspects relevant to the planning system, including the environmental effects and better alternatives if they are put forward.

Radical departure from current procedure

17. Until now, throughout the UK, the system has been that Ofgem provisionally approve a development, having properly had regard to the technical and commercial case, but the public could still make the case at Public Inquiry that the line should not go ahead – for instance, if the environmental case was too detrimental. Then it would be open for a new, possibly but not necessarily more costly, solution to be explored by the relevant Parties. Ofgem cannot and makes no attempt to weigh up these planning matters which are entirely outwith their regulatory role. For instance, with regard to the Beauly Denny line, Ofgem specifically said that it had not assessed environmental considerations, having left them to the planning system. Under the current proposal, a similar application could not be halted for major environmental, or even economic, reasons, even if an alternative was possible – because that alternative could not be considered in the planning process.

18. Ofgem, in their role as the regulator for the electricity consumer, has agreed to proposals put before it - with the expectation that these are the cheapest options. If the proposal goes through, there will be no occasion when that is balanced against other Planning concerns, e.g. environmental degradation. The democratic right for these options to be explored is removed. This Scottish Parliament consideration is the only occasion where the case against any one of the developments in this single proposed National Development can be heard.

Diminished role for planning

19. Although such a development will still be open to Public Inquiry, it will not be on the substantive issue of whether the development goes ahead or not. When this issue was raised at one of the NPF2 consultation meetings, it was suggested that alternatives had been considered whilst the NPF2 was being drafted, in the Assessment of Strategic Alternatives. However, questions to the SEA team confirmed that this has not been done for the grid options, due to lack of information and time. It is not possible, or appropriate, to assess such alternatives for ten grid developments throughout the country, as part of preparing the NPF2. This needs to be done on a site specific basis. This is why it is particularly inappropriate to include the grid options on the same basis as the other site-specific National Developments – the basis that the need for the development is now proven, since it clearly has not been.

Re-assessment of proposals in light of changing circumstance

20. In view of the long timescale which the NPF is looking at, these proposals should still be assessed for “need” at the time they are submitted - because the economic and technical case changes all the time, as we have seen with the recent economic upheavals. Of particular relevance is the advancing technology for sub-sea cabling, changes in costs and maturing of offshore energy technologies. These all affect the case for building these transmission projects onshore, as opposed to using subsea routes or different overhead routes. For instance, the assessment needs to be made in the context of recent Scottish Government policy announcements regarding prioritising subsea grid developments.

21. In the worst case scenario, Ofgem might say, “yes, there is a commercial case”; the NPF2 includes the development; several years later, the transmission company applies for planning permission and it is automatically assumed that the development must go ahead because it is in the NPF2. The economics and technology could have changed radically but there will be no ability for this to be considered or for the public to make representation on this absolutely fundamental aspect.

22. Indeed, some of these difficulties have already been seen. Although the first National Planning Framework did not have the same status as the NPF2 will have, the fact that it included the Beauly Denny transmission line was suggested as indicative that the Scottish Executive had decreed that the line had to go ahead. This was despite the fact that Beauly Denny had not had strategic alternatives examined – it not being Ofgem’s role to do that. (In fact, the Inquiry could not have gone ahead as it did if this had been the case). The long-term nature of the NPF means that it must not be used to embed commercial proposals, with no way for them to be re-examined in the light of new circumstances.

Prejudicial effect of NPF2 on Beauly Denny decision?

23. The NPF2 Consultation Draft states that the inclusion of the ten itemised grid developments does not pre-judge, and will not influence, the outcome of the Beauly Denny 400kV transmission line Public Local Inquiry - despite the fact that three of the proposed grid upgrades feed into Beauly and that any electricity brought along these upgrades would require additional capacity to be built. This appears to be a difficult argument to sustain, although ultimately one which might be settled at Judicial Review.

Conclusion

24. If Scotland had a National Energy Strategy then the Scottish population would have had a say in the strategic shape of energy development around them – whether they wish, in certain key areas, a, possibly more costly, option - subsea routes, to be used to protect their natural heritage and economic interests. In the absence of such a strategy, and with a privately run energy sector, there needs to be an opportunity for competing alternatives for energy development to be assessed – something which in the past would have been done by the state-run electricity sector. Otherwise, each transmission operator will propose what is best for their company’s profit and there will be no forum for strategic analysis. This has the potential to lead to stranded assets and an unnecessarily damaged landscape, with the economic consequences those bring.

25. Whilst the National Planning Framework 2 has included many worthy aspirations in its overview, and the scope of its aspirations are to be commended, inclusion of this particular National Development would be undemocratic and threaten to have the opposite effect to that which is hoped for, from such a document. These issues are of absolutely fundamental importance – both for democracy and our natural heritage.

26. The Trust submits that this Candidate National Development is not suitable for inclusion in the NPF2.

Helen McDade, Head of Policy 13th January 2009

ANNEXE D: LIST OF OTHER WRITTEN EVIDENCE

The Local Government and Communities Committee has received a number of written submissions in response to its call for written evidence on NPF2. These are available on the Local Government and Communities Committee webpages:

http://www.scottish.parliament.uk/s3/committees/lgc/inquiries/NPF2/evidence.htm

A number of these submissions refer to issues within the Economy, Energy and Tourism Committee’s remit.

  • Action for Planning Transparency
  • Alison Lowe
  • Ariane Loening
  • Babcock Marine
  • Buckingham Hamilton and Ruskin Association
  • Cindy Coutillier
  • City of Edinburgh Council
  • Clare Symonds (2 submissions)
  • Diana Cairns
  • Doug Piggot
  • Forth Ports plc
  • Gerry McCartney
  • Jim Hammond
  • Midlothian Council
  • Mrs Aileen Campbell
  • Mrs E Holland
  • North Ayrshire Council
  • Pamela McLean
  • Paul Jenkins
  • Plane Speaking
  • Ramblers Association Scotland
  • RSPB Scotland
  • Scotland Before Pylons and Friends of the Ochils
  • Scottish Environment LINK Planning Task Force
  • SEPA
  • Stuart Duncan
  • Vance Allan and Bill Rodger

Footnotes:

1 National Planning Framework for Scotland 2: Proposed Framework, Scottish Government. Available at: http://www.scotland.gov.uk/Publications/2008/12/12093953/0

2 The Government Economic Strategy, Scottish Government. Available at: http://www.scotland.gov.uk/Publications/2007/11/12115041/0

3 CBI Scotland. Written submission to the Economy, Energy and Tourism Committee

4 CBI Scotland. Written submission to the Economy, Energy and Tourism Committee

5 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1387.

6 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1388.

7 Friends of the Earth Scotland. Written submission to the Economy, Energy and Tourism Committee

8 Friends of the Earth Scotland. Written submission to the Economy, Energy and Tourism Committee

9 RSPB Scotland. Written submission to the Economy, Energy and Tourism Committee

10 Commission for Sustainable Development. Written submission to the Economy, Energy and Tourism Committee

11 Commission for Sustainable Development. Written submission to the Economy, Energy and Tourism Committee

12 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1406

13 Scottish Parliament Transport, Infrastructure and Climate Change Committee, Official Report, 13 January 2009, Col 1295

14 Scottish Parliament Transport, Infrastructure and Climate Change Committee, Official Report, 13 January 2009, Col 1310

15 Growing pains – can we achieve a 50% growth in tourism revenue by 2015?, 6th Report 2008, Economy, Energy and Tourism Committee, The Scottish Parliament

16 CBI Scotland. Written submission to the Economy, Energy and Tourism Committee

17 Friends of the Earth Scotland. Written submission to the Economy, Energy and Tourism Committee

18 John Muir Trust. Written submission to the Economy, Energy and Tourism Committee

19 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1404.

20 CBI Scotland. Written submission to the Economy, Energy and Tourism Committee

21 CBI Scotland. Written submission to the Economy, Energy and Tourism Committee

22 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1405

23 Scottish Parliament Local Government and Communities Committee. Official Report, 21 January 2009, Col 1583

24 Scottish Parliament Local Government and Communities Committee. Official Report, 21 January 2009, Col 1583

25 Scottish Executive, Scottish Planning Policy SPP1, November 2002

26 Scottish Executive, Scottish Planning Policy SPP1, November 2002

27 Scottish Parliament, Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1409.

28 CBI Scotland. Written submission to the Economy, Energy and Tourism Committee

29 CBI Scotland. Written submission to the Economy, Energy and Tourism Committee

30 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1410

31 National Planning Framework for Scotland 2: Proposed Framework, Scottish Government, p.67

32 Scottish Power. Written submission to the Economy, Energy and Tourism Committee

33 Scottish and Southern Energy. Written submission to the Economy, Energy and Tourism Committee

34 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1419

35 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1425

36 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1414

37 Friends of the Earth Scotland. Written submission to the Economy, Energy and Tourism Committee

38 RSPB Scotland. Written submission to the Economy, Energy and Tourism Committee

39 Commission for Sustainable Development. Written submission to the Economy, Energy and Tourism Committee

40 Commission for Sustainable Development. Written submission to the Economy, Energy and Tourism Committee

41 John Muir Trust. Written submission to the Economy, Energy and Tourism Committee

42 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1419

43 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1424

44 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1435

45 Scottish Chambers of Commerce. Written submission to the Economy, Energy and Tourism Committee

46 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1431

47 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1388

48 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1400

49 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1422

50 Scottish Parliament Transport, Infrastructure and Climate Change Committee, Official Report, 13 January 2009, Col 1310

51 Scottish Parliament Local Government and Communities Committee. Official Report, 21 January 2009, Col 1588

52 Scottish Chambers of Commerce. Written submission to the Economy, Energy and Tourism Committee

53 CBI Scotland. Written submission to the Economy, Energy and Tourism Committee

54 CBI Scotland. Written submission to the Economy, Energy and Tourism Committee

55 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1392

56 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1392

57 Scottish Parliament Economy, Energy and Tourism Committee. Official Report, 14 January 2009, Col 1392

58 RSPB Scotland. Written submission to the Economy, Energy and Tourism Committee

59 Scottish Parliament Transport, Infrastructure and Climate Change Committee, Official Report, 13 January 2009, Col 1301

60 Scottish Parliament Transport, Infrastructure and Climate Change Committee, Official Report, 13 January 2009, Col 1302

61 This paragraph was agreed to by division. The result was: For 5 (Wendy Alexander, Lewis Macdonald, Marilyn Livingstone, Gavin Brown and Iain Smith), Against 3 (Christopher Harvie, Dave Thompson and Rob Gibson).


62 CBI Scotland’s Planning Group was established in October 2007 and consists of members from the house-building, commercial property development, transport and finance sectors.

63 ‘Planning for growth: the business agenda for planning reform’, CBI Scotland publication, 2004

64 As set out in the Scottish Government’s Economic Strategy 2007

65 ‘The Scottish Economy: The Priority of Priorities’, CBI Scotland manifesto, 2006

66 National Planning Framework Newsletter, No.3 Autumn 2007

69 See for example www.tyndall.ac.uk/publications/briefing_notes/Livingwithacarbonbudget.pdf which suggests a 70% reduction by 2030 is necessary for the UK.

70 Greenhouse Gas Emissions Data for International Aviation and Shipping, 1990-2006. www.naei.org.uk

72 http://www.dft.gov.uk/consultations/archive/2002/fd/scot/mc/chapter9otherkeypolicyissues1516 para 9.1.17 notes annual tourism receipts from inbound passengers were £0.5bn in 2000, and the comparative figures for outbound expenditure by Scots travelling abroad was £0.7bn.

73 The energy consultancy Poyry conclude that additional replacement generation capacity is not needed before the 2020s if UK government renewables and efficiency targets are met. http://www.wwf.org.uk/filelibrary/pdf/energy_gap_summary.pdf


74 Sustainable Development: A Review of Progress by the Scottish Government (2008)

75 Strategic Transport Projects Review Report 4, page 18