Monday, 16 September 2013

So, it all comes down to money then, this NPF3?



A quick selection of quotes from several NPF3 Consultee responses to encourage readers to delve deeper and gain further insights 

NB - keep going to the end to find a little 'local flavour'


RICS

'...Some of our members felt that the NFP3 fell short of their expectations.  Throughout the  document, there are too many references to “aspirations”.  Aspirations to make something  happen cannot, by definition be a “Plan”.  Therefore, the Scottish Government must make NPF3 more than aspirational; it should be evidenced-based.'



Full RICS response HERE

RTPI

'...The Royal Town Planning Institute (RTPI) is the champion of planning and the planning profession. We work to promote the art and science of planning for the public benefit.  We have around 2,200 members in Scotland and a worldwide membership of nearly 23,000.'

'...RTPI Scotland believes that planning has an important role in supporting Scottish Government’s ambitions on sustainable development, sustainable economic growth engagement, climate change, place making and well located new development.  We are pleased that Scottish Government is committed to the 3rd National Planning Framework (NPF3) and revised Scottish Planning Policy (SPP) and that it recognises the key role 
they can play and the added value that they can bring.' 

'...We are pleased to hear that the finalised NPF3 will include an Action Programme along the lines of those in strategic and local development plans.  This should help ensure that the document promotes development which is deliverable. 

However, there is still a need to make the connection between aspirations set out in NPF3 with resources that can enable these to be delivered.  This is why it is vital that the document is embedded across Scottish Government and used in the forward planning of 
Key Agencies, utility companies, investors and communities.  It also means that we need to look beyond the planning system as the only tool in delivering development - NPF3 should better link together development proposals with resourcing and paving initiatives including Tax Incremental Financing, Compulsory Purchase Orders and Prudential Borrowing.  This will also require a more explicit link between development and infrastructure provision.


Full RTPI response HERE

COSLA

'...Whilst we note that NPF3 is not a spending plan, in our view it needs to be aligned with other investment strategies and policy frameworks – National Transport Strategy, Second Report on Proposals and Policies, Zero Waste Plan etc. There is no reference to the broader context of demographic change and the impact that this will have on land use planning, whether in relation to an increasingly ageing population, areas of potential population growth and population decline. All plans should be evidence based. By providing this contextual information NPF3 can ensure that its proposals will achieve its aspiration as a statement of ‘Ambition, Opportunity and Place’.'


Full COSLA response HERE

CBI - The Voice of Business Scotland

'...We welcome the draft NPF3’s overriding acknowledgement that all planning should be considered through the prism of the need for economic recovery.'


Full CBI response HERE

Architecture+Design Scotland


'...We welcome the strong commitment within the NPF3 to high quality placemaking and we look forward to playing our part in supporting local and central government and other practitioners in the implementation of the policy once it is published by Ministers.'



Full A+DS response HERE

WWF Scotland

'...The NPF3 should describe the duelling of the Perth to Inverness railway line as a 
national priority. The current single track line with limited passing places does not allow the rail line to compete with the road network and offers a poorer alternative for freight movement. If journey times are to be significantly reduced then duelling the line is 

necessary....'

'...Emissions from aviation and shipping are included in the Climate Change Act, so any expansion of capacity in these sectors must not be allowed to undermine the delivery of 
this important legislation. WWF Scotland therefore does not support the inclusion of national developments that will result in an increase in the number of flights from Scotland’s priority airports.'


Full WWF response HERE

SCDI

'...While the intentions set out in the MIR are generally supported, the ability to finance and deliver NPF3’s ambitions is a concern. The final document should make links between the aspirations identified and the expected resources, including where further information on access to finance and funding mechanisms can be found. Public sector investment alone will be insufficient to match the ambitions. Private sector investment and partnership will be necessary to stimulate and deliver many key projects. The final version of NPF3 should identify and explore innovative ways of securing additional private capital to fund Scotland’s infrastructure at a reasonable 

long-term cost.'

'...Paragraph 4.22 of the MIR recognises that “connections and transport infrastructure are key to a successful future for towns and cities”, and the recognition of some of the key infrastructure challenges facing cities is welcome and could be expanded upon. In particular, Inverness (which is currently missing from this section) and its efforts to accommodate significant growth and respond to the challenges of infrastructure constraints should be included alongside Scotland’s other cities.'


Full SCDI response HERE

Planning Democracy

'...Planning Democracy's NPF2 research identified several communities who did not know about proposals for large-scale national developments on their doorstep, or who did not understand that a development's designation as a 'national' would mean they could not question the need for the development later in the process. Although improved in some ways, the methodology remains much the same.'

Full PD response HERE

Cycling Scotland

'...Cycling Scotland feels that the NPF3 should, indeed, provide a more tangible vision of what future cities and town centres should look like. As discussed above, the vision and policies are in place (Designing Streets, Creating Places, Town Centre Review process, Cycling Action Plan for Scotland, etc.). However, there remains a gap between the actual delivery of places and development that adheres to the policies and aims set out in these documents.'


Full Cycling Scotland response HERE

Scottish Property Federation

'...The NPF3 is ambitious as its title states and this is welcome. One note of  caution however is that the fiscal crisis has produced a very risk averse modern investment environment and it may be difficult to attract inward investment into perceived secondary market areas...'

'...The impact of the fiscal crisis upon the economy and financial services is well documented. For the property industry the impact of the fiscal crisis was already apparent in late 2007 to early 2008. However the sector had become heavily leveraged with lenders. The impact of the crisis was to reduce commercial property values by some 44% between 2008 and late 2009. This loss of value has not been recovered in many instances and indeed, has been under further pressure for secondary property since 2009 while prime property has begun to recover.The market is therefore becoming more polarised in terms of value. Consequently there has been an enhanced emphasis upon prime properties and this may well have a considerable bearing on development investment in the near future. At the same time new restrictions upon lending to real estate and a continued reluctance to take the risk of speculative development will inhibit the willingness of the private sector to take the risk of commercial property development or investment. This may have a direct consequence for the willingness of private investors to venture much beyond well-known and safe areas of investment.'

'...No plan is effective unless it is delivered, even if the plan is subsequently adapted. The NPF will therefore not materialise without a realistic plan for investment in infrastructure. Constraints upon both public and private sources of finance will mean the aspirations of NPF will be challenging for years to come, but it is still important for NPF to link to the Infrastructure Investment Plan.' 


Full SPF response HERE


And a little more 'Local Flavour'


HITRANS

'...It is disappointing that the ‘reasonable alternatives’ to the preferred options in the proposed framework are set out separately in the Environmental Report. Development Plans must present reasonable alternatives up front in the development plan and we would therefore expect a national planning framework to do the same to aid the transparency of the process.'

'...NPF3 does not identify any road or rail improvements (except High Speed Rail which will have little or no direct benefit for the North of Scotland) as proposed national developments. HITRANS is disappointed that these strategic transport projects have not been identified as proposed national developments and continues to press for their inclusion as national developments (with support from the partners identified 
above) for the reasons outlined below.'

'...HITRANS also welcomes the continued identification of Inverness and the Inner Moray Firth as an Area for Co-ordinated Action. It is, as stated, an area identified for major change and investment. The specific, additional reference to West Link is welcomed but this should perhaps be broadened to include other strategic, Inverness City, transport improvements. For example the STPR and National Infrastructure Plan includes an A9/A96 connection improvement. All these strategic City transport improvements are to facilitate sustainable economic growth without compromising place making objectives. For example, West Link 
will allow peripheral expansion of the City without increasing city centre congestion and its environmental quality impact.'

Full HITRANS response HERE

Turnberry Consulting

'...I write...to provide comments on behalf of Highlands and Islands Airports Ltd. (HIAL) and Inverness Airport Business Park Ltd. (IABP)...we request that the Draft NPF3 is amended to identify Inverness Airport Business Park (IABP) as an initiative for business investment in conjunction with enhancement of Inverness Airport...we request that the draft NPF3 is amended to carry forward the commitments in NPF2 (para 214) to dualling of the A96 Nairn and creation of a transport interchange at Dalcross.'


Full TC response HERE

Moray Estates

'...Tornagrain should be specifically recognised in NPF3...request... identify Tornagrain for its contribution to delivering new homes and setting the standard for new community design in the region.'

'...Tornagrain in located adjacent to Inverness Airport and Inverness Airport Business Park.  The level of development planned for the A96 Corridor is dependent on infrastructure  improvements coming forward, particularly the dualling of the A96 and creation of a new rail halt at Dalcross.  The link between planned growth and a commitment to delivering these infrastructure projects was clear in NPF2.  The loss of that link within the current draft of NPF3 is of concern to the estate as it suggests that these projects are no longer priorities for the Government.  The Estate considers that these infrastructure projects are of national importance and need to be aligned with the spatial strategy for the region...we request that the draft NPF3 is amended to reaffirm the Government's commitment to bringing forward the dualling of the A96 and the creation of a new rail halt at Dalcross over the short to medium term'

Full ME response HERE

Nairn West CC

'...Regarding key airports, the inclusion of Inverness airport as a national development is essential (para 5.36). 

This is not just a matter of capacity. Both Inverness and Aberdeen airports illustrate a failure of strategic planning in the past. Neither has an appropriately-located rail link for the terminal. Neither has efficient and convenient trunk road access. Neither has any kind of multi-modal interchange.

...It is unrealistic to turn the sow's ear into a silk purse. But Inverness airport seriously needs major improvement .

...On High Speed Rail, an upgraded service between the Central belt and London would be of indirect benefit to the Highlands. But improvements in the Highland mainline and in the Aberdeen-Inverness service (as noted in para 5.2 and map 23) would be of greater direct value.

 ...Highland the increasing growth and centralisation of services in Inverness is exacerbating the depopulation and decline of the rural hinterland. 

Full NWCC response HERE




[List of NPF3 MIR Consultation Responses here ]

No comments:

Post a Comment