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Moray Council
Strategic Environmental Assessment Environmental Report of Supplementary Planning Guidance
June 2005
Entec UK Limited
Report for Gary Templeton Planning Officer (Environment) The Moray Council Planning Officer Council Offices High Street ELGIN IV30 1BX
Main Contributors Pete Davis Katie Elmer Luke McDonald Kerri McGuire Ross McLaughlin Leona Mellis
Issued by …………………………………………………………
Leona Mellis
Approved by ………………………………………………………… Pete Davis
Entec UK Limited 6/7 Newton Terrace Glasgow G3 7PJ Scotland Tel: +44 (0) 141 222 1200 Fax: +44 (0) 141 222 1210
Moray Council
Strategic Environmental Assessment Environmental Report of Supplementary Planning Guidance
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June 2005
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Contents
1. Summary and Outcomes 1
1.1 Non-Technical Summary 1 1.1.1 Strategic Environmental Assessment 1 1.1.2 Scope of the Report 2 1.2 Statement on the Difference the Process has Made 2 1.2.1 Summary of Effects of the SPG’s 4 1.2.2 Conclusions on the Performance of the Supplementary Planning
Guidance 5 1.3 Statement of Compliance 5 1.4 How to Comment on the Report 6
2. Introduction 7
2.1 Purpose of this Report 7 2.2 Requirement for Appraisal of the SPG 7
3. Methodology 9
3.1 Overview of Approach 9 3.2 Stage 1: Description of the Baseline Characteristics and the
Predicted Future Baseline 9 3.2.1 Main Issues and Problems Identified 10 3.2.2 Difficulties in Collecting Data and Limitations of the Data 11 3.3 Stage 2: Refine the SEA Objectives and Agreeing
Methodology for Appraising the SPG’s 12 3.3.1 Assessing the Compatibility of the Objectives 15 3.3.2 Establishing an Appraisal Framework 16 3.4 Stage 3: Assessing the Effect of the SPG 22 3.5 Stage 4: Provide Views on Implementation of the SPG and a
Commentary on Monitoring 22
4. Supplementary Planning Guidance 23
4.1 Role of Supplementary Planning Guidance 23 4.1.1 Development Requirements 23 4.1.2 Wind Energy 23
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4.1.3 Housing in the Countryside 24 4.1.4 Forestry Strategy 24 4.1.5 Parking Standards 24 4.1.6 Trees and Development 25 4.2 Compliance with the SEA Directive/Regulations 25 4.3 Treatment of Alternatives 26
5. Result of Appraisal 27
5.1 Overview 27 5.2 Development Requirements 27 5.3 Wind Energy 27 5.4 Housing in the Countryside 28 5.5 Forestry Strategy 28 5.6 Parking Standards 28 5.7 Trees and Development 29 5.8 Effects of Supplementary Planning Guidance Documents on
Overall Objectives 29 5.9 Conclusions 30
6. Monitoring Framework 33
6.1 Proposal for Monitoring the Implementation of the Moray Development Plan 33
Table 1.1 Appraisal Recommendations 2 Table 1.2 Summary of the Environmental Impacts of the Plan Policies 4 Table 1.3 Compatibility of Moray Council Environmental Report with SEA Direction 6 Table 3.1 Key Issues and Problems 11 Table 3.2 Objectives and Key Questions 13 Table 3.3 Compatibility of Different Objectives 16 Table 4.2 Schedule 2 of the SEA Regulations: Information for Environmental Reports 25 Table 6.1 Issues That May Require Future Monitoring 33 Table 6.2 Documenting the Monitoring Data 33
Appendix A Related Plans and Programmes Appendix B Baseline Information Appendix C Sources of Information Appendix D Supplementary Planning Guidance – Appraisal Matrix
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1. Summary and Outcomes
1.1 Non-Technical Summary
1.1.1 Strategic Environmental Assessment This document is the final Environmental Report of the all the emerging Supplementary Planning Guidance (SPG) produced by Moray Council. The Environmental Report covers the following SPG’s:-
• Development Requirements;
• Wind Energy;
• Housing in the Countryside;
• Forestry Strategy;
• Parking Standards; and
• Trees and Development.
This document is the draft final Environmental Report of the emerging Supplementary Planning Guidance produced following the implementation of the European Commission Directive 2001/42/EC (enacted under the Environmental Assessment of Plans and Programmes (Scotland) Regulation 2004) which requires a ‘Strategic Environmental Assessment’ (SEA) of Development Plans, as well as other plans and programmes. A separate Environmental Report has been produced that covers the implications of the Moray Development Plan. However, as the SPGs also represent an extension of aspects of the Moray Development Plan, they have been included within the scope of plans to be included within the SEA.
The Directive provides a high level of protection of the environment and contributes towards the integration of environmental considerations into the preparation and adoption of plans and programmes in order to promote sustainable development. This assessment focuses on considering the effects of the SPGs on environmental objectives, although a social and economic objective is also included within the appraisal framework. Where those impacts on the environment are considered likely to be significant, mitigation measures are proposed. On occasions, these measures will take the form of proposed amendments to the SPG which seek to mitigate these adverse impacts.
To ensure that the process was independent, objective and rigorous, Moray Council commissioned Entec UK Ltd to complete this Environmental Report.
This Environmental Report presents relevant baseline information, outlines key environmental issues, highlights future trends and targets and outlines proposals for monitoring the impacts of the subsequent implementation of the SPG.
There will always be significant tensions in the process of assessment. This report makes explicit the conflict between economic growth and environmental impacts. Whilst these cannot
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always be resolved, the assessment, in highlighting such tensions is able to provide this information to decision makers. Decisions can then be taken that are informed, based on evidence and that has sought to balance potentially competing interests.
1.1.2 Scope of the Report This Environmental Report comprises of the following:-
• Background to the purpose and objectives of the appraisal process;
• The methodology used to complete the appraisal;
• A summary of the key problems/issues in the Moray Council area (the baseline situation) and the key issues that need to be considered;
• An assessment of the contribution of the SPG’s to social, economic and environmental objectives within the Moray Council area;
• An outline of proposed mitigation measures; and
• Proposed monitoring arrangements.
It remains at the Council’s discretion whether it decides to accept or decline the proposed amendments to the SPG’s.
The report also contains a number of appendices which contain additional information regarding the assessment. This includes the completed appraisal framework for each of the SPG documents, the review of plans and programmes (necessary to inform the appraisal framework objectives) and more detailed information on the monitoring and baseline information gathered.
Where appropriate and consistent with the assessment, for specific policies, recommendations have been made (which are summarised in Table 1.1). It remains at the Council’s discretion whether it decides to accept or decline the proposed amendments to the plan policies.
1.2 Statement on the Difference the Process has Made This report highlights specific problems of the SPG that are suggested to require amendment to mitigate specific effects. Suggested recommendations from the appraisal are given in Table 1.1.
Table 1.1 Appraisal Recommendations
SPG Recommendations of Appraisal Matrix Moray Council Response
Recommended Revisions
Development Requirements
It is considered that the SPG does not adequately specify how development will incorporate sustainable design and construction techniques. The SPG should include reference to the provision and safeguarding of green space. The SPG should also provide encouragement for development to take place on previously developed land. This SPG should set out
These are matters most appropriately dealt within the Local Plan policy section. Whilst there is a focus on housing development as the
None
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SPG Recommendations of Appraisal Matrix Moray Council Response
Recommended Revisions
guidelines for the incorporation of landscaping schemes and design elements within new developments. This SPG currently focuses on development requirements for new housing developments and to ensure compliance with policy IMP1 of the Local Plan the SPG should provide a more general approach to development requirements. This would provide guidance for all new forms of development and would ensure that new development is sustainable.
main development type, the SPG applies across all development types.
Wind Energy The SPG on wind energy should provide a strong linkage with Policy ER1 of the Local Plan. The SPG contains a list of Environmental Assessment Requirements, which includes such issues as landscaping, natural and built environment and infrastructure etc. . In reference to the list of areas regarded as ‘unsuitable’ for wind farm development, guidance should be added to show that development will not be permitted in the areas unless it can be demonstrated that there will be no adverse impact on biodiversity, the natural and built environment and the landscape of the area.
Noted Reference made to biodiversity, natural and built environment and landscape.
Countryside Housing
Other than providing guidance on dwelling orientation and the like, it was considered that the SPG does not adequately specify how development will incorporate sustainable design and construction techniques, as specified in SPP3 and SPP15. The need for the implementation of such requirements in the SPP’s is a recognition that dwellings in the open countryside will perform less well against sustainable development objectives than more concentrated development within existing settlements . Therefore, strong sustainable construction and materials guidance is required to redress this imbalance. This will include incorporating Scottish Homes’ ‘Sustainable Design Guide’ principles to improve performance.
The focus of the SPG is on design of housing in the countryside. The matters on sustainable design and construction are considered within the policy section of the Local Plan.
None.
Parking Standards
The Council should provide guidance that is concise and explicitly defines the maximum and minimum Parking Standards. The use of minimum parking standards is deemed to be an effective way of tailoring national guidance into the Council’s own situation. The use of a Class Use Table as used in SPP 17 may be a useful format to present the Council’s guidance. Consideration should also be given to the cumulative effects of smaller scale development and development which is not defined within national guidance. The SPG must be amended to include both maximum and minimum standards for all relevant types of development.
Noted. Table of standards included in supplementary guidance.
Trees and Development
It is recommended that this SPG is not necessary for the protection of trees as it is assumed that without this SPG, the Town and Country Planning (Scotland) Act 1997 would still offer protection to existing trees through the designation of Tree Preservation Orders (TPO’s) and Conservation Areas. Trees are also protected through policy ENV3 in the Local Plan. The Council should give consideration as to the need for this SPG in regard to the additional protection it affords trees within the area.
The guidance was prepared to afford proper protection of trees before, during and after construction. The SPG is considered to be an essential addition to the policy which deals with Tree Preservation Orders and Trees within Conservation Areas.
None.
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1.2.1 Summary of Effects of the SPG’s The following Table 1.2 summaries the impacts of the SPG’s. This presents the impacts relative to the requirements of the SEA Regulation (as defined in paragraph 6, Schedule 2).
Further detail on these impacts can be found in the main body of the report and in the appendices.
Table 1.2 Summary of the Environmental Impacts of the Plan Policies
Air The SPG relating to parking standards is considered to have a negative impact on air quality. However, this is due to the assumption that only maximum standards will be implemented which may lead to an inadequate provision of parking and therefore increase congestion and air pollution. Mitigation could be effected by developing minimum parking standards.
The Forestry Strategy will have a positive impact on air quality within Moray as new planting will help to absorb carbon dioxide emissions
Landscape and Soil
The Wind Energy SPG will have a positive impact on the landscape as it encourages the safeguarding and enhancement of International, national and locally designated areas. These sites are protected from wind farm developments as the SPG deems them unsuitable for such developments. The SPG will have a positive impact on soil quality as it specifies that ground should be restored to its original condition during the decommissioning of the wind farm.
The SPG on countryside housing seeks to ensure that housing does not significantly infringe on agricultural land by encouraging siting to be in appropriate locations in relation to existing land uses.
Biodiversity (Fauna and Flora) The Wind Energy SPG will have a positive impact on biodiversity as it encourages the safeguarding and enhancement of species, habitats and natural heritage.
This SPG specifies areas which are unsuitable for wind farm developments due to their biodiversity value.
The Forestry Strategy has a positive impact on biodiversity and aims to promote biodiversity within Moray’s forestry areas. The SPG has aims to safeguard and promote existing wildlife and habitats within forestry areas. Forestry in Moray is identified as providing important habitats for red squirrel and roe deer.
Climatic Factors The SPG relating to parking standards is considered to have negative impacts on air quality. This is due to the assumption that only maximum standards will be implemented which may lead to an inadequate provision of parking, increasing congestion, air pollution and greenhouse gas emissions. Mitigation to develop minimum parking standards may resolve this impact.
The SPG for Wind Energy could have a positive impact on reducing the emission of greenhouse gas emissions from the area through encouragement of renewable energy generation developments. Whether this will be significant will be in proportion to the scale of the proposed development.
The Forestry Strategy will positively impact on the climate as the encouragement of new planting, especially in Countryside Around Towns would help to reduce greenhouse gas emissions. The Forestry Strategy also outlines opportunities for the use of Biomass to generate energy using forestry waste produces and poor quality timer.
The SPG for countryside development and development requirements could all make a positive contribution to the reduction in Green House Gas emissions through the use of sustainable design and construction techniques that will seek to reduce the energy consumption requirements per capita. Depending on specification it could also reduce embodied energy associated with the
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construction of properties.
Cultural Heritage (including architectural and archaeological heritage)
The Forestry Strategy aims to conserve and enhance the built environment through the identification of culturally sensitive sites; this will have a positive impact on the cultural heritage of Moray.
Human Health The Supplementary Planning Guidance will have no impact on human health
Material Assets The SPG on Development Requirements and Housing in the Countryside could have potentially negative impacts on material assets since they do not explicitly encourage the use of sustainable technologies, sustainable construction and renewable energy sources. However, these could be mitigated through changes to the SPGs.
The SPG for Wind Energy could potentially have a positive contribution to the economic performance of the area (through the additional temporary employment) required during construction of any wind farms.
The Forestry Strategy has a positive impact on material assets, it provides protection against development on prime quality agricultural land and aims to maximise the wood resources within the Moray area.
Population The Supplementary Planning Guidance will have no impact on population
1.2.2 Conclusions on the Performance of the Supplementary Planning Guidance
In broad terms the Supplementary Planning Guidance performs well against the environmental objectives and it provides a robust framework from which to progress sustainability within the Council area. Many of the individual SPGs make a positive contribution towards the environmental objectives and the proposed changes refer predominately to improvements in the accompanying text. . In particular the SPG promotes:-
• The use of renewable energy sources;
• Strengthening the role of rural settlements;
• Protection of the natural and built environment of the Moray Area.
However, consideration should be given to promoting the following in the plan:-
• The promotion of development on previously developed land;
• The provision and enhancement of green space;
• Higher standards in design and sustainable construction methods; and
• A stronger commitment to alternative modes of transport.
• Statement of Compliance
1.3 Statement of Compliance Table 1.3 below assesses the compatibility of this Environmental Report against the SEA Directive. Further information on the compliance of this report is given in Section 4.
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Table 1.3 Compatibility of Moray Council Environmental Report with SEA Direction
Environmental Report Sections
Information included Section of SEA Directive
Section 1: Summary of Outcomes
Non technical summary, statement of the difference that the process has made, how to comment on the report
Article 5(1) Annex i(J)
Section 2: Introduction Purpose of the Report, plan objectives, compliance
Article 5(1) Annex 1 (a)
Section 3: Appraisal Methodology
Appraisal method
Article 3 (5)
Section 4: Moray Development Plan Objectives, baseline and context
Links to other plans, programmes and strategies, description of the baseline and trend information, any difficulties encountered, the SEA framework and the main issues
Article 5(1) Annex 1 (a), (b) (c) ,(d) and (e) and Article 3 (5)
Section 5: Plan policies Summary of the significant environmental effects of the preferred policies, outline of how they were considered, and proposed mitigation.
Article 5(1) Annex 1 (f), and(g)
Section 6: Monitoring Framework and Implementation
Links to other plans and programmes and proposals for monitoring
Article 10, Annex 1 (i)
1.4 How to Comment on the Report We would welcome your comments on this Environmental Report. If you do have comments, please send your comments to:
Gary Templeton Planning Officer (Environment) The Moray Council Council offices High Street Elgin
IV30 1BX
The Council will acknowledge receipt of your submission and provide a response to your views as part of the consultation process on the plan.
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2. Introduction
2.1 Purpose of this Report This document is the Environmental Report of the Supplementary Planning Guidance on the following areas:-
• Development Requirements;
• Wind Energy;
• Housing in the Countryside;
• Forestry Strategy;
• Parking Standards; and
• Trees and Development.
A Scoping Report was produced in April this year by the Moray Council and this Environmental Report accompanies this document. This Environmental Report has been produced to meet the SEA Directive requirements. There is also a separate Environmental Report of the Moray Development Plan. Both documents should be read in conjunction with this report.
The Environmental Report sets out the appraisal methodology, the objectives, baseline information used in the appraisal process, the assessment of the SPG’s, proposed and agreed changes to the SPG’s and proposals to monitoring the plan implementation.
2.2 Requirement for Appraisal of the SPG The European Directive 2001/42/EC requires a ‘Strategic Environmental Assessment’ (SEA) of Development Plan Documents. The objective of the Directive is “to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promote sustainable development” (Article 1). These aims are consistent with a range of Scottish Executive policies on the environment and sustainable development.
The Directive applies to all relevant plans and programmes whose formal preparation began after 21st July 2004 and those that will not be adopted by 21st June 2006. The directive has been enacted in Scotland through the Environmental Assessment of Plans and Programmes (Scotland) Regulations 2004.
The Directive defines “environmental assessment” as a procedure comprising:
• Preparing an Environmental Report on the likely significant effects of the draft plan or programme;
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• Carrying out consultation on the draft plan or programme and the accompanying Environmental Report;
• Taking into account the Environmental Report and the results of consultation in decision making; and
• Providing information when the plan or programme is adopted and showing how the results of the environmental assessment have been taken into account.
It is uncertain whether the SEA requirements which cover town and country planning should be definitively extended to Supplementary Planning Guidance and guidance is ambiguous on this point. However, the Council has taken the precautionary approach to developing the Plan and in consequence has determined that the SPGs shall be exposed to the same degree of scrutiny and independent assessment as the Development Plan itself. Not only will ensure consistency but it will also improve the quality of the SPGs to be adopted.
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3. Methodology
3.1 Overview of Approach The key stages in undertaking the independent appraisal of the Supplementary Planning Guidance documents can be summarised as:
• Stage 1: Description of the baseline characteristics and the predicted future baseline;
• Stage 2: Refine the SEA Objectives and agreeing methodology for appraising the SPG’s;
• Stage 3: Assessing the Effect of the SPG’s by an appraisal of the SPG’s by considering the guidance against each sustainability objective or criteria and the results recorded in an appraisal matrix; and
• Stage 4: Provide views on implementation of the SPG’s and a commentary on monitoring.
3.2 Stage 1: Description of the Baseline Characteristics and the Predicted Future Baseline
The SEA Regulations 2004 requires an analysis of the Plan’s “relationship with other relevant plans and programmes.” (Schedule (1)) and of “the environmental protection objectives… which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation.” (Schedule 2 (5)).
Appendix A of this document and in Appendix 1 of the Scoping Report contains a full list of relevant plans and programmes.
The SEA Directive requires an analysis of the “relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan.” (Annex 1B, Scoping Report) and “the environmental characteristics of areas likely to be significantly affected.” (Annex 1C, Scoping Report).
Appendix B lists the baseline data, highlights any applicable comparisons and targets (i.e. at a national or local level), and identifies trends where information is available.
The data was collected from a wide range of sources, including the Moray Council Monitoring Information and other Moray Council reports and departments. A detailed list of sources of information is included in Appendix C.
The baseline information and assessment of other plan and policies was also used to identify the key issues relevant to the development of the Moray Development Plan. There are a number of
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sustainability pressures in the Moray area most of which detailed in Appendix 3 of the Scoping Report. Some of the main key issues have been summarised below:-
• In terms of population, there is a trend towards an ageing population which has continued over the past 10 years, and this is projected to continue into the future. Over 40% of the population of the Moray area are now over the age of 45 years. By 2018 it is projected that 52% of the population will be 45 years or older. Population projections are also showing a decline in the population.
• In terms of employment, figures for 2001 illustrate 45,057 people as being ‘economically active’ which represent an increase of 1,463 since 1991. With this growth, unemployment has decreased by 511 since 1991. However Moray has the lowest average wage levels in Scotland and is well below the nation average.
• There is also a dominance of the type of jobs with 32% of the workforce of the Moray area being employed in public sector.
• Lack of serviced and readily developable land.
• Much of Moray is covered by nature conservation designations and the number of Tree Preservation Orders is increasing.
• Diverse range of landscapes many of which are protected through international designations such as the new Cairngorms National Park and Cairngorms National Scenic Area. There are also scenic designations including 7 Areas of Great Landscape Value, a Coastal Protection Zone and several Historic Gardens and Landscapes.
• The area also has a number of listed buildings, conservation areas, scheduled ancient monuments and archaeological sites.
• The Council has seen an increase in applications and interest in renewable energy developments, particularly wind farm developments.
• The use of public transport has declined over the last decade.
• Community facilities and services have declined.
• Flooding is a problem with the Moray being severely affected by floods in 1997 and 2002.
3.2.1 Main Issues and Problems Identified The key problems and issues have been identified through the baseline data review and are summaries in Table 3.1.
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Table 3.1 Key Issues and Problems
Air Due to the rural nature of the Moray area there is a high dependency on the use of the private car. This high dependency on the private car can have a negative impact on the air quality of the Moray area.
Landscape & Soil
Diverse range of landscapes many of which are protected through international designations such as the new Cairngorms National Park and Cairngorms National Scenic Area. There are also scenic designations including 7 Areas of Great Landscape Value, a Coastal Protection Zone and several Historic Gardens and Landscapes all of which under pressure from human influences.
Biodiversity (Fauna and Flora)
Much of the Moray area is covered by nature conservation sites. There are 275 of the nationally listed species of conservation concern (21%) and 45 (73%) of the habitats of conversation concern in Moray.
Climatic Factors
Landscape is under pressure for renewable energy developments particularly wind farms. The use of public transport is also declining and due to the rural natural of the Moray area there is high dependency on the private car.
Cultural Heritage
There are a number of cultural heritage features in the Moray area, such as Listed Buildings, Conservation Areas and Historic Gardens and Landscapes. There has been an increase in the number of archaeological sites.
Human Health
There is currently an overuse of community facilities as there has been an increase in the number of people taking part in sports.
Material Assets
Waste is currently a problem in the area, although the Moray Waste Strategy is focused on reducing, reusing, recovering waste instead of landfill. Currently within the Moray area there is on waste treatment and recycling centre which is in Elgin The main waste streams in the Moray area are household, commercial, construction/demolition and industrial. households generating the main waste for the area.
The Moray area has the lowest average wage levels in Scotland and the large majority of the population are employed in the public administration/defence sector.
Population Over 40% of the population of the Moray area are now over the age of 45 years. By 2018 it is projected that 52% of the population will be 45 years or older. Population projections are also showing a decline in the population. This has the potential to have a negative impact on the health care provision for the area.
3.2.2 Difficulties in Collecting Data and Limitations of the Data
In addition to providing background information that has been useful in characterising the existing environmental issues, the baseline information has been used to develop indicators for each of the objectives, used within the appraisal. The indicators are used to summarise key performance against the objectives and which assist the process of plan and SPG appraisal. This information could also be used to help support the assessment of the potential impacts of the Moray Development Plan and are also reflected in the monitoring requirements of the SEA Regulations, addressed in later sections of this Report.
The indicators, which use much of the same information presented in Appendix B, are shown in Table 3.2, which brings together objectives, indicators and the framework for assessing potential impacts.
The main problems encountered in collecting the baseline information and developing the indicators is focused around the following:-
• Data not available at local level;
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• Date available did not match the ideal of information; and
• Unable to identify trends for a number of indicators due to the monitoring data only being available for the past year.
3.3 Stage 2: Refine the SEA Objectives and Agreeing Methodology for Appraising the SPG’s
Establishing and using environmental objectives are not a requirement of the SEA Directive; however, their development and application in an appraisal is a key element within the methodology. The objectives define the environmental outcomes that are anticipated for the area and to which the spatial plan will make a contribution. They form the structure around which the subsequent plans and policies will be appraised. They also provide the context to complete the scoping of various datasets that are to be gathered. Ultimately, the objectives will influence the indicators against which the plans and policies will be monitored.
Moray Council had already produced a set of objectives in the Scoping Report. However, the objectives in the Scoping Report were devised from the Council’s Environmental Charter and when compared to the requirements and scope of Schedule 2 (6) of the SEA Regulation, there were a number of areas where improvements could be made to ensure adequate coverage of all issues. Specifically, the SEA Regulation requires that the assessment should include “likely significant effects on the environment, which also includes issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage (including architectural and archaeological heritage), landscape and the interrelationship between the above factors”. In addition, when developing the revised objectives, consideration was also given to the range of plans and programmes that have been reviewed. This has sought to ensure that the objectives reflect the scope of existing agreed commitments and aspirations for the environment within the district.
The revised objectives are presented in Table 3.2. The Final Column of Table 3.2 indicates the main SEA topics relevant to each objective, although as the Directive itself recognises, there are many areas of overlap.
For each objective, a number of key questions are also presented. These questions are used to clarify and interpret the objectives and ensure consistency throughout the appraisal process.
The majority of the objectives have environmental considerations; however, there is an objective which includes social and economic factors. The re-fined objectives were discussed and agreed with Moray Council. The relevant statutory consultees were also sent copies of the refined objectives and were given the opportunity to comment.
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Table 3.2 Objectives and Key Questions
Objectives Key Questions Source of Objectives SEA Topic
To improve air quality within the Moray Council area
Will it have an adverse impact upon the Council’s target to comply with air quality standards?
EU Directive ***
The Air Quality Strategy for England, Scotland, Wales and Northern Ireland
Air
To reduce the causes and impacts of climate change
Will it contribute to the reduction of greenhouse gas emissions in line with national targets?
Will it actively seek to manage the flood risk to commercial and residential property in development areas to as low as practicable?
Climate Change: The UK Programme
National Planning Framework For Scotland
NPPG6 – Renewable Energy
SPP7 Planning and Flooding
Climatic factors, material assets
To increase energy efficiency and the proportion of energy generated from renewable sources
Will it promote the use of sustainable design and construction?
Will it lead to an increased proportion of energy needs being met from renewable sources?
Will energy usage be positively influenced by location and development?
Climate Change: The UK Programme
National Planning Framework for Scotland
NPPG 6 – Renewable Energy
NPPG17- Transport and Planning
Climatic change, material assets
To protect and enhance the biodiversity and landscape of the Moray Council area. Including the protection and enhancement of species, habitats, geology and landform
Will it contribute to the protection and enhancement of the biodiversity in the Moray Council area?
Will it have a detrimental effect on protected species?
Will it contribute to improving and/or maintaining the favourable condition of designated sites of scientific and natural interest?
Will it contribute to achieving local, regional and national biodiversity action plan targets?
Will it have a detrimental effect on landscape character and designations?
The Rio Convention on Biodiversity Strategic Plan
EU Directive ***
Nature Conservation Bill
North East Scotland Local Biodiversity Action Plan
NPPG14 Natural Heritage
SNH Moray and Nairn Landscape Character Assessment
Biodiversity, fauna, flora
To protect and enhance cultural heritage and diversity with the Moray Council area
Will it protect and enhance the district’s sites and features of historical and archaeological importance?
National Planning Framework for Scotland
NPPG 18- Planning and the Historic Environment
NPPG 5 Archaeology and Planning
Cultural heritage including architectural and archaeological heritage, material assets
To protect and enhance the quality of the districts ground, river and sea
Will it help prevent pollution of groundwater and rivers?
Will it protect the quality of the seawater?
EU Directive on Water Quality (2000/60/EC)
National Planning Framework for Scotland
Water
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Objectives Key Questions Source of Objectives SEA Topic
water systems Will it protect and enhance the coastline?
SPP7 - Planning and Flooding
To improve soil quality and use soil in a sustainable manner
Will it protect and improve the quality of the soil?
PAN 33 Development and Contaminated Land
Soil
To reduce the amount of waste produced and increase the amount of recycling
Will it ensure that the management of wastes is consistent with the waste management hierarchy by reusing/recycling a residual disposal through the least environmentally damaging option?
National Planning Framework For Scotland
NPPG 10 Waste Management
Moray Waste Disposal Strategy
North East of Scotland Area Waste Strategy
To promote the use of sustainable transport options
Will it improve public transport?
Will it encourage walking and cycling?
Will it reduce the need to travel by car?
Will it shorten the duration of journeys?
National Planning Framework for Scotland
SPP1 – Planning System
SPP17 – Transport Planning Maximum Parking Standards amendment to NPPG 17 – Transport Planning
Local Transport Strategy
To ensure prudent use of natural resources
Will it minimise the use of water?
Will it minimise the demand for raw materials?
Will it protect and enhance the use of prime agricultural land?
National Planning Framework for Scotland
SPP1- Planning System
NPPG 14- Natural Environment
Water, material assets
To protect, enhance and create green spaces and to regenerate degraded environments
Will green spaces be promoted?
Will it result in the loss of green spaces?
Will it make a significant contribution towards the regeneration of an area?
Will it result in further degradation of environments?
NPPG3 – Housing
NPPG 11 Sport, Physical Recreation and Open Space
PAN 65 Planning and Open Space
Harbours Improvement Plan
SPP1 Planning System
NPPG 3 – Housing
Material assets, landscape
To secure a better quality of life for local people through improvements to service provision, sustaining a healthy economy with high levels of employment and improving the health and well being of local people
Will it contribute to adequate access to and provision of services and leisure and recreational facilities for all including, those without a car and those with mobility difficulties?
Will it help to maintain high levels of employment?
Will it help to maintain a healthy economy?
National Planning Framework for Scotland
Moray Joint Economic Strategy
Moray Community Plan
Human Health, material assets, Population
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Objectives Key Questions Source of Objectives SEA Topic
Ensure accessibility for all to jobs?
Ensure the provision of sufficient employment land?
Improve access to health facilities?
3.3.1 Assessing the Compatibility of the Objectives
The objectives have been considered for compatibility and to ensure that they are complementary with each other. Table 3.3 shows that the majority of objectives are compatible with each other. However, for some combinations of objectives, there are clearly tensions between the objectives. This is particularly the case for objectives requiring change or increased development to meet social and economic aims that may result in pressure on the natural environment.
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Table 3.3 Compatibility of Different Objectives
1. To improve air quality within the Moray Council area
2. To reduce the causes and impacts of climate change
�
3. To increase energy efficiency and the proportion of energy generated from renewable sources
� �
4. To protect and enhance the biodiversity and landscape of the Moray Council area. Including the protection and enhancement of species, habitats, geology and landform
� � X
5. To protect and enhance cultural heritage and diversity with the Moray Council area
� � � X
6. To protect and enhance the quality of the districts ground, river and sea water systems
� � X � �
7. To improve soil quality and use soil in a sustainable manner
- � X � � �
8. To reduce the amount of waste produced and increase the amount of recycling
- � � � - � �
9. To promote the use of sustainable transport options
� � � � ? � - �
10. To ensure prudent use of natural resources
X � � � � � � �
11. To protect, enhance and create green spaces and to regenerate degraded environments
� � - � � � � - � �
12. To secure a better quality of life for local people through improvements to service provision, sustaining a healthy economy with high levels of employment and improving the health and well being of local people
X ? ? X X - X - � ? ?
1 2 3 4 5 6 7 8 9 10
11
12
���� compatible x potentially incompatible
? uncertain - no impact on each other
3.3.2 Establishing an Appraisal Framework In order to undertake the appraisal it was necessary to have a framework in which to assess the potential impacts of the policies included in the Development Plan. The framework allowed the potential impacts of each policy in the Development Plan to be assessed against the objectives set out in Table 3.2. Therefore, a matrix has been developed that included the objectives, against some indictors, and the columns for carrying out the appraisal of potential impacts. This
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is included here as Table 3.4. For each objective, it was necessary to consider the potential impacts in terms of the following issues:
• Direction of Effect – is the policy moving towards or away from the objective?
• Severity of Effect – Will the effect be marginal or significant?
• Trans-boundary Effects – does the effect impact on adjoining authorities?
• Urban/Rural Impacts – will the policy have different impacts on the care settlements and the outlying rural areas?
• Timing of Effect – does the effect occur immediately or later, and does it last indefinitely or only temporarily?
• The matrices also highlight where there is uncertainty over the effect, and where different issues and options enhance or contradict the effects of others.
Some of these issues are included in separate columns, some in symbols used in the columns and some in the accompanying commentary.
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Policy:
Timescale
Impa
ct
Scale
Objective Questions
Sho
rt te
rm
Long
term
Sev
erit
y
Loca
l
Tran
-bo
unda
ry Rur
al
Urb
an
Commentary
1. To improve air quality within the Moray Council area
Will it have an adverse impact upon the Council’s target to comply with air quality standards?
2. To reduce the causes and impacts of climate change
Will it contribute to the reduction of greenhouse gas emissions in line with national targets?
Will it actively seek to manage the flood risk to commercial and residential property in development areas to as low as practicable?
3. To increase energy efficiency and the proportion of energy generated from renewable sources
Will it promote the use of sustainable design and construction?
Will it lead to an increased proportion of energy needs being met from renewable sources?
Will energy usage be positively influenced by location and development?
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Policy:
Timescale
Impa
ct
Scale
Objective Questions
Sho
rt te
rm
Long
term
Sev
erit
y
Loca
l
Tran
-bo
unda
ry Rur
al
Urb
an
Commentary
4. To protect and enhance the biodiversity and landscape of the Moray Council area. Including the protection and enhancement of species, habitats, geology and landform
Will it contribute to the protection and enhancement of the biodiversity in the Moray Council area?
Will it have a detrimental effect on protected species?
Will it contribute to improving and/or maintaining the favourable condition of designated sites of scientific and natural interest?
Will it contribute to achieving local, regional and national biodiversity action plan targets?
Will it have a detrimental effect on landscape character and designations?
5. To protect and enhance cultural heritage and diversity with the Moray Council area
Will it protect and enhance the district’s sites and features of historical and archaeological importance?
6. To protect and enhance the quality of the districts ground, river and sea water systems
Will it help prevent pollution of groundwater and rivers?
Will it protect the quality of the seawater?
Will it protect and enhance the coastline?
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Ju
ne 2
005
Pol
icy:
Tim
esca
le
Impact
Sca
le
Obj
ectiv
e Q
uest
ions
Short term
Long term
Severity
Local
Tran-boundary
Rural
Urban
Com
men
tary
7.
To im
prov
e so
il qu
ality
and
use
soi
l in
a s
usta
inab
le m
anne
r W
ill it
pro
tect
and
impr
ove
the
qual
ity o
f the
soi
l?
8.
To re
duce
the
amou
nt o
f was
te
prod
uced
and
incr
ease
the
amou
nt
of re
cycl
ing
Will
it e
nsur
e th
at th
e m
anag
emen
t of w
aste
s is
co
nsis
tent
with
the
was
te m
anag
emen
t hie
rarc
hy b
y re
usin
g/re
cycl
ing
a re
sidu
al d
ispo
sal t
hrou
gh th
e le
ast e
nviro
nmen
tally
dam
agin
g op
tion?
9.
To p
rom
ote
the
use
of s
usta
inab
le
trans
port
optio
ns
Will
it im
prov
e pu
blic
tran
spor
t?
Will
it e
ncou
rage
wal
king
and
cyc
ling?
Will
it re
duce
the
need
to tr
avel
by
car?
Will
it s
horte
n th
e du
ratio
n of
jour
neys
?
10.
To e
nsur
e pr
uden
t use
of n
atur
al
reso
urce
s W
ill it
min
imis
e th
e us
e of
wat
er?
Will
it m
inim
ise
the
dem
and
for r
aw m
ater
ials
?
Will
it p
rote
ct a
nd e
nhan
ce th
e us
e of
prim
e ag
ricul
tura
l lan
d?
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June 2005
Policy:
Timescale
Impa
ct
Scale
Objective Questions
Sho
rt te
rm
Long
term
Sev
erit
y
Loca
l
Tran
-bo
unda
ry Rur
al
Urb
an
Commentary
11. To protect, enhance and create green spaces and to regenerate degraded environments
Will green spaces be promoted?
Will it result in the loss of green spaces?
Will it make a significant contribution towards the regeneration of an area?
Will it result in further degradation of environments?
12. To secure a better quality of life for local people through improvements to service provision, sustaining a healthy economy with high levels of employment and improving the health and well being of local people
Will it contribute to adequate access to and provision of services and leisure and recreational facilities for all including, those without a car and those with mobility difficulties?
Will it help to maintain high levels of employment?
Will it help to maintain a healthy economy?
Ensure accessibility for all to jobs?
Ensure the provision of sufficient employment land?
Improve access to health facilities?
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3.4 Stage 3: Assessing the Effect of the SPG Using the agreed SEA framework, the appraisal looked at how far the SPG’s contribute to the SEA objectives. Each SPG was appraised against each criterion and the result recorded in a matrix agreed with Moray Council. The contribution can be characterised as ranging from a strongly positive one to a strongly negative one. To aid what is necessarily a subjective appraisal, reference was made to key baseline information presented in the framework for each objective. The assessment of the likely significant effects of the plan alternatives and mitigation was included in this appraisal process. The completed matrices are included within Appendix D.
The following approach is adopted when appraising the SPG documents:-
• Appraisal of the Baseline option (‘business as usual’) on environmental objectives;
• Appraisal of the SPGs contribution to environmental objectives;
• Completion of SEA Report that focuses upon the key sustainability issues arising from the appraisal and any proposed mitigation measures.
3.5 Stage 4: Provide Views on Implementation of the SPG and a Commentary on Monitoring
This Report provides an analysis of the relative performance of the SPG’s against the SEA Objectives. In order to assess the on-going impact of the SPG’s it has been necessary to devise a series of indicators that can be used for monitoring. The development of the monitoring framework coincides with the development of the appraisal framework identified in Stage 2. In determining the indicators that could be appropriate and sourcing the relevant information, consideration has also been given to the quality, frequency and accuracy of the information. Such information has then been included within the proposed monitoring framework and as such will be subsequently implemented.
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4. Supplementary Planning Guidance
4.1 Role of Supplementary Planning Guidance This section sets out the various SPGs that have been appraised. It includes a summary of their purpose and content and the respective linkages to the Moray Development Plan. It also provides a commentary on the compliance of the process with the requirements of the SEA Regulations.
4.1.1 Development Requirements The SPG aims to supplement Policy IMP1 – Development Requirements by providing additional guidance on development requirements for housing developments. This SPG on Development Requirements aims to improve the quality of new development within Moray. The guidance addresses a number of requirements for new housing developments, these include:
• Site Layout and Design;
• Plot Detail;
• Amenity and Play areas;
• Trees and development;
• Roads;
• Crime;
• Energy Efficiency;
• Contamination;
• Waste; and
• Waste Water (Sewage).
The SPG recognises the importance of ensuring that new housing fits into its surrounding environment and where possible enhances it. This is supported through the protection of existing wildlife, distinctive features and landscaping. The SPG sets standards for the provision of amenity and plan areas and encourages the development of energy efficient housing.
4.1.2 Wind Energy The Wind Energy Policy Guidance has been produced in recognition that there has been a considerable interest from wind farm developers to locate within Moray. This guidance has two key principles:
• Moray Council aims to positively promote renewable energy developments;
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• Moray’s high quality environment must be safeguarded from inappropriate developments.
The guidance consists of two distinct sections. The first outlines preferred search area maps and the second outlines the supporting text. The Council have identified areas which are considered to be unsuitable for wind farm developments as a result of the potential adverse effects on the landscape, built and natural heritage and amenity value of the area. The SPG also outlines requirements for an Environmental Impact Assessment in terms of landscape, natural environment, built environment, tourism and recreation, infrastructure, pollution, proximity to settlements and effects on aircrafts.
4.1.3 Housing in the Countryside The purpose of the guidance is primarily to support Policy H7 – New Housing in the Open Countryside of the Local Plan. It seeks to clarify the policy by using good practice examples and explanatory diagrams to aid applicants. It defines that the key elements of the determination process are siting, location and design of new housing. The SPG is split into 3 main sections which relate to different types of housing development in the countryside. The first is concerned with developing housing within existing rural communities, the second with redeveloping existing buildings or re-use of derelict buildings and finally the building of new housing in open countryside. Each section has specific guidance relating to the individual characteristics of the different types of new build. Detail is given in each section regarding the character of existing surroundings and specific types of building. This supplementary information provides a base that new housing development must comply with in order to respect the aesthetics of the existing landscape or buildings
4.1.4 Forestry Strategy The Forestry Strategy aims to promote and enhance Moray’s forestry as an important resource. The strategy encourages the new planting of forestry areas, with the aim of achieving a number of benefits in terms of landscape, biodiversity, access etc. New planting is also encouraged in Countryside Around Towns as an opportunity to significantly improve the environment of urban areas and access recreational opportunities. The Forestry Strategy specifically aims to:
• Support the local economy;
• Conserve and enhance the environment; and
• Enhance the quality of life of communities.
4.1.5 Parking Standards The SPG aims to supplement Policy T5 – Parking Standards of the Local Plan. It defines a background to parking and transport issues which have been derived from The Moray Local Transport Strategy. The SPG recognises that Moray’s rural attributes and peripheral nature relate to a heavy reliance on road travel and car usage. In addition, Moray’s historic market towns and large catchments areas are also noted as having a significant impact on parking issues. In particular, the possibility of putting too much pressure onto on –street parking could have an adverse effect on the historic built environment, tourism, cycling and walking safety.
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Given these sensitive considerations the SPG proposes that the Council should adopt parking standards that encompass both maximum and minimum standards together which is consistent with the provisions of SPP17. However, these minimum standards are not explicitly defined in the document or in the local plan. Furthermore, it is not clear if the maximum parking standards are to be the same as is outlined in SPP 17. This lack of detail and concise guidance posed problems in the appraisal of this SPG. The assumption was made that only maximum parking standards as outlined in SPP 17 were proposed for the purpose of the appraisal.
4.1.6 Trees and Development This SPG aims to safeguard and integrate trees within new developments. This guidance outlines a three stage process which is required at the outset of the planning and design stages for a new development. Stage 1 requires a tree survey to be carried out for development proposals on sites designated in the Local Plan which contains trees. Stage 2 involves the integration of trees into the development; this stage identifies trees that should be retained. Stage 3 outlines how the existing trees can be incorporated in a positive way in the site layout.
4.2 Compliance with the SEA Directive/Regulations The European Directive 2001/42/EC (EC/2001) and the Environmental Assessment of Plans and Programmes (Scotland) Regulations 2004 require an Environmental Report to be completed.
Schedule 2 of the Regulations defines the content of the Environmental Report in the following Table 4.2
Table 4.2 Schedule 2 of the SEA Regulations: Information for Environmental Reports
1. An outline of the contents and main objectives of the plan or programme, and of its relationship with other relevant plans and programmes.
2. The relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programmes.
3, The environmental characteristics of areas likely to be significantly affected.
4. Any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of particular environmental importance, such as areas designated pursuant to Council Directive 79/409/EEC on the conservation of wild birds (a) and the Habitats Directive
5. The environmental protection objectives, established at International, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental consideration have been taken into account during its preparation.
6. The likely significant effects on the environment, including short, medium and long-term effects, permanent and temporary effects, positive and negative effects and secondary, cumulative and synergistic effects, on issues such as:-
(a) biodiversity
(b) population
(c) human health
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(d) fauna
(e) flora
(f) soil
(g) water
(h) air
(i) climatic factors
(j) material assets
(k) cultural heritage, including architectural and archaeological heritage;
(l) landscape; and
(m) the inter-relationship between the issues referred to in sub-paragraphs (a) to (l).
7. The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme.
8. An outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information.
9. A description of the measures envisaged concerning monitoring in accordance with regulations
10. A non-technical summary of the information provided under paragraphs 1 to 9.
Further guidance is also provided in Circular 2/2004: ‘Strategic Environmental Assessment for Development Planning; the Environmental Assessment of Plans and Programmes (Scotland) Regulations 2004.
Paragraph 19 of the Circular refers to the content of the Environmental Report. Paragraph 19 makes it clear that there is no statutory provision for as to the form the Environmental Report should take but guidance is given in Annex B of the Circular. Annex B is broadly similar to what is detailed above in Box 2.4.
The Council has sought to develop an approach that is consistent with the overall objective of the SEA Directive, namely,
“to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development.”
4.3 Treatment of Alternatives An alternative option has also been considered to implementation of the SPG, which is a ‘business as usual’ approach. This option relates to the existing policy framework in place which is mainly the Moray Local Plan.
The main outcomes of the appraisal of the SPG and ‘business as usual’ option are summarised in the following section.
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5. Result of Appraisal
5.1 Overview The following section presents a summary of the findings of the appraisal of each SPG considered. The completed appraisals are presented in Appendix D
5.2 Development Requirements In appraising the Development Requirements SPG two options were considered. The first option appraised the environmental impacts if this SPG was not implemented and ‘business continued as usual’ the second assessed the impacts such this SPG be implemented. It is considered that the most sustainable option would be the implementation of this SPG as it represented a move towards the achievement of the majority of the objectives. While the appraisal for the ‘business us usual’ option resulted in a move away from the achievement of 8 of the objectives. The appraisal has shown that the most sustainable option would be to implement the SPG on Development Requirements
It is considered that this supplementary planning guidance could be strengthened by reference to appropriate measures to address flood related issues. Although the SPG encourages the use of energy efficiency measures in the designing of houses, the guidance does not make any reference to the use of sustainable design and construction methods. The SPG encourages the provision of amenity and play areas but does not mention the provision or safeguarding of green space. This SPG protects existing landscape features but does not encourage the use of landscaping schemes and design elements within new developments. This SPG is specifically related to development requirements for new housing developments, This SPG could benefit from a more general approach to the provision of guidance on development requirements, in accordance with policy IMP1.
5.3 Wind Energy In the appraisal of the two options it has been determined that the implementation of this SPG would result in a significant move towards the achievement of a number of the objectives, especially in relation to the proportion of energy generated from renewable sources. It is considered that if this SPG was not implemented they would be an uncertain impact on energy efficiency and climate changes. It was also considered that without this SPG there would be a move away from the achievement of two of the objectives. It has been shown through the appraisal of this SPG that the most sustainable option would be to implement the SPG on wind energy.
The SPG on wind energy could benefit from stronger linkage with Policy ER1 and ER2 of the Local Plan. The SPG could be strengthened through consideration of birds and migration patterns. It could be perceived that as the SPG designates such a large number of sites as unsuitable for wind farm developments. Large areas are unlikely are designated because of the high quality environmental assets of the area. Developers may be deterred from building such
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developments within the Moray area. Perhaps guidance could be added to show that development will not be permitted in the outlined areas unless it can be demonstrated that there will be an adverse impact on biodiversity, the natural and built environment and the landscape of the area.
5.4 Housing in the Countryside The appraisal of both options displayed the supplementary nature of this topic by highlighting a majority of ‘no relationship’ scores with our environmental based sustainability objectives. The business as usual option produced 3 negative relationships and no positive conclusions. Implementing the SPG faired marginally better producing 1 positive relationship and 2 negatives. One of these negative conflicts can become positive through the mitigation and inclusion of clear guidance relating to increasing energy efficiency and the promotion of energy generated from renewable sources (Objective 3). In conclusion, the SPG option is deemed to perform better than the business as usual option but would benefit from the strengthening of guidance on the use of sustainable construction, design and technologies.
The appraisal has therefore shown that the most sustainable option would be to implement the SPG in order to supplement Policy H7 – ‘New Housing in the open Countryside’ of the Local Plan.
The appraisal has also shown that mitigation to include guidance that promotes the use of energy-efficient technologies as outlined in SPP3 and SPP15 would improve the environmental performance of the SPG. The need for the implementation of such requirements in the SPP’s is a recognition that dwellings in the open countryside are on balance significantly less sustainable (from an environmental perspective) than more centralised development. Guidance should include the encouragement of sustainable construction and the use of energy efficient and sustainable technologies. Consideration should be given to Scottish Homes’ ‘Sustainable Design Guide’.
5.5 Forestry Strategy The appraisal of both options for the Forestry Strategy has shown that this SPG should be implemented. The appraisal of the ‘business as usual’ option showed a move away for the achievement of the majority of the objectives. While the appraisal of Option 2 demonstrated a positive impact or no relationship with all objectives, the appraisal has shown that the most sustainable option would be to implement the SPG on the Forestry Strategy.
The Forestry Strategy is a comprehensive document which appears to have considered all issues in relation to the development, protection and enhancement of Forestry within Moray. The SPG provides linkages with the Local Biodiversity Action Plan and access network. The SPG has a positive impact or no relationship with the objectives and therefore no modifications are suggested.
5.6 Parking Standards The options displayed the social and economic nature of this topic by highlighting a majority of ‘no relationship’ scores with our environmental based sustainability objectives. The lack of
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concise guidance relating to maximum and minimum parking standards also meant the appraisals produced the same negative relationships for similar reasons. If the SPG did include Moray’s own minimum parking standards relating to local circumstances then it would be a much more effective and potentially sustainable document.
The appraisal has shown that the most effective way to progress with the SPG on parking would be to provide guidance that is concise and explicitly defines the Councils standards.
The use of minimum parking standards is deemed to be an effective way of tailoring national guidance into the Council’s own situation. The use of a Class Use Table as used in SPP 17 may be a useful format to present the Council’s guidance. Furthermore, consideration should also be given to the cumulative effects of smaller scale development and development which is not defined within national guidance.
5.7 Trees and Development The appraisal has shown that the business as usual approach should be adopted with regard to the SPG on trees and development. It is assumed that without this SPG, the Town and Country Planning (Scotland) Act 1997 would still offer protection to existing trees through the designation of Tree Preservation Orders (TPO’s) and Conservation Areas, however there would be no requirement for the survey and safeguarding of trees not covered by TPO’s or in Conservation Areas. The SPG has no relationship with the majority of the objectives.
5.8 Effects of Supplementary Planning Guidance Documents on Overall Objectives
The following table summaries the impacts of all the plan policies against the issues of concern.
Table 5.8 Summary of the Impact of the Supplementary Planning Guidance
Air The SPG relating to parking standards is considered to have a negative impact on air quality. However, this is due to the assumption that only maximum standards will be implemented which may lead to an inadequate provision of parking and therefore increase congestion and air pollution. Mitigation could be effected by developing minimum parking standards.
The Forestry Strategy will have a positive impact on air quality within Moray as new planting will help to absorb carbon dioxide emissions
Landscape and Soil The Wind Energy SPG will have a positive impact on the landscape as it encourages the safeguarding and enhancement of International, national and locally designated areas. These sites are protected from wind farm developments as the SPG deems them unsuitable for such developments. The SPG will have a positive impact on soil quality as it specifies that ground should be restored to its original condition during the decommissioning of the wind farm.
The SPG on countryside housing seeks to ensure that housing does not significantly infringe on agricultural land by encouraging siting to be in appropriate locations in relation to existing land uses.
Biodiversity (Fauna and Flora)
The Wind Energy SPG will have a positive impact on biodiversity as it encourages the safeguarding and enhancement of species, habitats and natural heritage.
This SPG specifies areas which are unsuitable for wind farm developments due to their biodiversity value.
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The Forestry Strategy has a positive impact on biodiversity and aims to promote biodiversity within Moray’s forestry areas. The SPG has aims to safeguard and promote existing wildlife and habitats within forestry areas. Forestry in Moray is identified as providing important habitats for red squirrel and roe deer.
Climatic Factors The SPG relating to parking standards is considered to have negative impacts on air quality. This is due to the assumption that only maximum standards will be implemented which may lead to an inadequate provision of parking, increasing congestion, air pollution and greenhouse gas emissions. Mitigation to develop minimum parking standards may resolve this impact.
The SPG for Wind Energy could have a positive impact on reducing the emission of greenhouse gas emissions from the area through encouragement of renewable energy generation developments. Whether this will be significant will be in proportion to the scale of the proposed development.
The Forestry Strategy will positively impact on the climate as the encouragement of new planting, especially in Countryside Around Towns would help to reduce greenhouse gas emissions. The Forestry Strategy also outlines opportunities for the use of Biomass to generate energy using forestry waste produces and poor quality timer.
The SPG for countryside development and development requirements could all make a positive contribution to the reduction in Green House Gas emissions through the use of sustainable design and construction techniques that will seek to reduce the energy consumption requirements per capita. Depending on specification it could also reduce embodied energy associated with the construction of properties.
Cultural Heritage (including architectural and archaeological heritage)
The Forestry Strategy aims to conserve and enhance the built environment through the identification of culturally sensitive sites; this will have a positive impact on the cultural heritage of Moray.
Human Health The Supplementary Planning Guidance will have no impact on human health.
Material Assets The SPG on Development Requirements and Housing in the Countryside and could have potentially negative impacts on material assets since they do not explicitly encourage the use of sustainable technologies, sustainable construction and renewable energy sources. However, these could be mitigated through changes to the SPGs.
The SPG for Wind Energy could potentially have a positive contribution to the economic performance of the area (through the additional temporary employment) required during construction of any wind farms.
The Forestry Strategy has a positive impact on material assets, it provides protection against development on prime quality agricultural land and aims to maximise the wood resources within the Moray area.
Population The Supplementary Planning Guidance will have no impact on population
5.9 Conclusions In broad terms the Supplementary Planning Guidance performs well against the environmental objectives and it provides a robust framework from which to progress sustainability within the Council area. Many of the individual SPGs make a positive contribution towards the environmental objectives and the proposed changes refer predominately to improvements in the accompanying text. . In particular the SPG promotes:-
• The use of renewable energy sources;
• Strengthening the role of rural settlements;
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• Protection of the natural and built environment of the Moray Area.
However, consideration should be given to promoting the following in the plan:-
• The promotion of development on previously developed land;
• The provision and enhancement of green space;
• Higher standards in design and sustainable construction methods; and
• A stronger commitment to alternative modes of transport;
• Statement of Compliance.
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6. Monitoring Framework
6.1 Proposal for Monitoring the Implementation of the Moray Development Plan
Article 5.1 and Annex 1(i) require that the Environmental Report should include “a description of the measures envisaged concerning monitoring in accordance with Article 10.” monitoring of the implementation of the SPG should be designed to “identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action. ”We therefore feel that it important that the monitoring framework also takes into account the implementation of the SPG’s.
We have identified issues in Table 6.1 which may require monitoring; some of these effects are already being monitored by Moray Council as part of the annual monitoring reports. However we have also suggested a format for documenting how the monitoring process should be managed in Table 6.2.
Table 6.1 Issues That May Require Future Monitoring
1. Number of wind farm application being received and being approved
2. Number of planning consent being issued for housing in the countryside
3. The use of sustainable construction and design methods.
4. Monitor the provision of open space
5. Take up of brownfield land
Table 6.2 Documenting the Monitoring Data
What needs to be monitored
Indicator Source of information
Are there any gaps in existing information and how can these be resolved?
When should remedial action be taken?
What remedial action could be taken?
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Appendix A Relevant Plans & Programmes
Appendix B Baseline Information
Appendix C Sources of Information
Appendix D Supplementary Planning Guidance – Appraisal Matrix
