Key questions relevant to the Astley Ainslie

As one would expect given the huge scope of the framework, the consultation is extensive, and has a total of 70 questions. Fortunately, you do not have to answer all 70. Below, we highlight the questions that we think are particularly relevant to the Astley Ainslie, and the AACT response to the consultation, which you may want to consider in your own response to the consultation.

Part 1 - A National Spatial Strategy for Scotland 2045

• Q 1: DO YOU AGREE THAT THIS APPROACH WILL DELIVER OUR FUTURE NET ZERO PLACES WHICH WILL BE MORE RESILIENT TO THE IMPACTS OF CLIMATE CHANGE AND SUPPORT RECOVERY OF OUR NATURAL ENVIRONMENT?

  • Given the nature of the climate emergency, the Scottish Government’s targets, and the high carbon emissions from construction, “encouraging” low emission design is clearly insufficient. Low- and zero- emission design must be clearly defined and mandated. We are very supportive of the aims of improving biodiversity and improving nature networks, but without firm legislation and a Natural Capital approach to measuring the value of our natural world, such aims will not be achievable. Furthermore, the detailed policy provides for too many exemptions and loopholes, which will allow developers to avoid having to meet such requirements and result in a failure to deliver the strategy.

• Q 2: DO YOU AGREE THAT THIS APPROACH WILL DELIVER OUR FUTURE PLACES, HOMES AND NEIGHBOURHOODS WHICH WILL BE BETTER, HEALTHIER AND MORE VIBRANT PLACES TO LIVE?

  • We agree that the 20 minute neighbourhood is a key approach to improving quality of life while encouraging sustainable living.

• Q 3: DO YOU AGREE THAT THIS APPROACH WILL DELIVER OUR FUTURE PLACES WHICH WILL ATTRACT NEW INVESTMENT, BUILD BUSINESS CONFIDENCE, STIMULATE ENTREPRENEURSHIP AND FACILITATE FUTURE WAYS OF WORKING – IMPROVING ECONOMIC, SOCIAL AND ENVIRONMENTAL WELLBEING?

  • Without a way of measuring wellbeing and the value of the environment it will be impossible to sensibly balance competing needs. A Natural Capital approach that measuring the value of the natural environment across multiple axes will be key to delivering this strategy.

• Q 4: DO YOU AGREE THAT THIS APPROACH WILL DELIVER OUR FUTURE PLACES WHICH WILL BE DISTINCTIVE, SAFE AND PLEASANT, EASY TO MOVE AROUND, WELCOMING, NATURE-POSITIVE AND RESOURCE EFFICIENT?

  • We agree with this approach, but it is unclear whether it will deliver. Much will depend on the detail of the legislation.

• Q 5: DO YOU AGREE THAT THE SPATIAL STRATEGY WILL DELIVER FUTURE PLACES THAT OVERALL ARE SUSTAINABLE, LIVEABLE, PRODUCTIVE AND DISTINCTIVE?

  • We agree with this approach, but it is unclear whether it will deliver. Much will depend on the detail of the legislation.

• Q 6: DO YOU AGREE THAT THESE SPATIAL PRINCIPLES WILL ENABLE THE RIGHT CHOICES TO BE MADE ABOUT WHERE DEVELOPMENT SHOULD BE LOCATED?

  • No. The implicit assumption under Compact Growth is that the brownfield, vacant or derelict land has no existing value and value can only be realized through urban development. Both assumptions are false. Brownfield/vacant/derelict land may already have significant value in terms of biodiversity and wellbeing that must be measured and considered in any development consideration. Such land may also provide much more value by being enhanced as greenspace or for community use rather than simply being used for commercial or residential development. Development of such land must be considered more broadly than a presumption of building at density. The government must develop standard methods to be able to accurately measure the value of such land, e.g. through a Natural Capital approach.

Part 2 - National developments

• Q 20: IS THE LEVEL OF INFORMATION IN THE STATEMENTS OF NEED ENOUGH FOR COMMUNITIES, APPLICANTS AND PLANNING AUTHORITIES TO CLEARLY DECIDE WHEN A PROPOSAL SHOULD BE HANDLED AS A NATIONAL DEVELOPMENT?

  • Yes.

• Q 21: DO YOU THINK THERE ARE OTHER DEVELOPMENTS, NOT ALREADY CONSIDERED IN SUPPORTING DOCUMENTS, THAT SHOULD BE CONSIDERED FOR NATIONAL DEVELOPMENT STATUS?

  • Yes. The Central Scotland Green Network is predicated on Classes of Development decisions that will have already been made. As such, it limits the set of developments to those which have already classed as greenspace. A wider view needs to be considered to consider opportunities elsewhere to enhance the Green Network.

Part 3 - National Planning Policy

• Q 22: DO YOU AGREE THAT ADDRESSING CLIMATE CHANGE AND NATURE RECOVERY SHOULD BE THE PRIMARY GUIDING PRINCIPLES FOR ALL OUR PLANS AND PLANNING DECISIONS?

  • Yes

• Q 23: DO YOU AGREE WITH THIS POLICY APPROACH?

  • Yes

• Q 24: DO YOU AGREE THAT THIS POLICY WILL ENSURE THE PLANNING SYSTEM TAKES ACCOUNT OF THE NEED TO ADDRESS THE CLIMATE EMERGENCY?

  • No. “All development should be designed to minimise emissions over its lifecycle in line with the decarbonisation pathways set out nationally.” is insufficiently strong. “should” to be replaced with “must”.

• Q 25: DO YOU AGREE THAT THIS POLICY WILL ENSURE THAT THE PLANNING SYSTEM TAKES ACCOUNT OF THE NEED TO ADDRESS THE NATURE CRISIS? 

  • Yes.

• Q 27: DO YOU AGREE THAT PLANNING POLICY SHOULD SUPPORT COMMUNITY WEALTH BUILDING, AND DOES THIS POLICY DELIVER THIS?

  • The scope of Community Wealth Building must go beyond the narrow view of economic development to consider wider community development.

• Q 29: DO YOU AGREE THAT THIS POLICY SUFFICIENTLY ADDRESSES THE NEED TO SUPPORT LOCAL LIVING?

  • Yes

• Q 31: DO YOU AGREE THAT THIS POLICY MEETS THE AIMS OF SUPPORTING THE DELIVERY OF HIGH QUALITY, SUSTAINABLE HOMES THAT MEET THE NEEDS OF PEOPLE THROUGHOUT THEIR LIVES?

  • No. There needs to be a consideration of the need to provide suitable greenspace as as an integral part of the process of building new homes, and enhancing biodiversity on sites.

• Q 32: DO YOU AGREE THAT THIS POLICY WILL REDUCE THE NEED TO TRAVEL UNSUSTAINABLY, DECARBONISE OUR TRANSPORT SYSTEM AND PROMOTE ACTIVE TRAVEL CHOICES?

  • Yes

• Q 34: DO YOU AGREE THAT THIS POLICY WILL HELP TO MAKE OUR PLACES GREENER, HEALTHIER, AND MORE RESILIENT TO CLIMATE CHANGE BY SUPPORTING AND ENHANCING BLUE AND GREEN INFRASTRUCTURE AND PROVIDING GOOD QUALITY LOCAL OPPORTUNITIES FOR PLAY AND SPORT?

  • No. The focus of this policy is purely to retain existing blue and green infrastructure. There is no explicit policy to expand the blue and green infrastructure, other than to “identify opportunities”. This is insufficient. There needs to be an explicit policy to create new infrastructure.

• Q 36: DO YOU AGREE THAT THIS POLICY WILL ENSURE PLACES SUPPORT HEALTH, WELLBEING AND SAFETY, AND STRENGTHEN THE RESILIENCE OF COMMUNITIES?

  • Yes

• Q 46: DO YOU AGREE THAT THIS POLICY WILL PROTECT AND ENHANCE OUR HISTORIC ENVIRONMENT, AND SUPPORT THE RE-USE OF REDUNDANT OR NEGLECTED HISTORIC BUILDINGS?

  • Yes

• Q 48: DO YOU AGREE THAT THIS POLICY WILL  HELP TO PROACTIVELY ENABLE THE REUSE OF VACANT AND DERELICT LAND AND BUILDINGS?

  • No. The wording of the policy does not adequately address the aim of the first sentence “The reuse of vacant and derelict land and properties can contribute to climate change targets and support biodiversity, health and wellbeing improvements and resilient communities by providing much needed greenspace, growing spaces and other community benefits.”. There needs to be an explicit policy for development of vacant and derelict land into productive greenspace providing community benefit.

• Q 50: DO YOU AGREE THAT THIS POLICY WILL PROTECT AND RESTORE NATURAL PLACES?

  • No. While this policy provides safeguarding of existing statutory greenspace, it does not safeguard existing green networks, nor does it provide any policy regarding restoration or active enhancement of natural places. A such it will at best stop encroachment of existing natural places. Given the stated need to increase biodiversity that is inadequate.